Short answer
The answer, before the reasoning
A GRI 102 transition-plan disclosure connects climate impacts with policies, actions, scientific alignment, targets, expenditure, governance, strategy and progress. It also addresses consequences for workers, non-employee workers, communities, Indigenous Peoples and biodiversity.
A mature plan is not required before reporting: if no plan exists, explain why, the steps under way and the expected timeframe rather than presenting an ambition or project list as an approved plan.
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PUBLIC ARTICLE
In practice
FORMAT
| FORMAT | LANGUAGE | VERSION |
|---|---|---|
| Deep Guide | British English | 1.0 • 1 August 2026 |
A transition-plan disclosure is an operating model, not a slogan
GRI 102: Climate Change 2025 brings the organisation’s climate narrative, quantitative metrics and social consequences into one reporting architecture. A transition plan is not demonstrated by a single net-zero sentence. The disclosure needs to show how significant climate-change impacts are translated into policies, actions, targets, capital and operating decisions, oversight and progress. It also needs to explain who may be adversely affected by the transition and how those impacts are identified, prevented, mitigated and addressed.
The disclosure should therefore be drafted from controlled planning evidence, not from a communications deck. Strategy, finance, operations, human resources, procurement, community relations, public affairs and sustainability teams may all hold part of the evidence. The reporting owner’s task is to reconcile those parts into one honest account of the current plan, including what has not yet been decided.
Figure 1. A transition plan sits at the intersection of climate science and impacts, governance and expenditure, adaptation, and a just transition for affected people and places.
Quick orientation
- APPLIES TO Organisations for which climate change is a material topic and which
- PRIMARY DECISION Whether the organisation has an approved transition or adaptation plan, what maturity level can be evidenced, and which gaps must be disclosed.
- KEY SOURCES GRI 102: Climate Change 2025, especially Disclosures 102-1 to 102-3,
- COMMON CONFUSION Treating a target, scenario, project list or high-level decarbonisation ambition as a complete transition plan.
Rule
EFFECTIVE DATE
GRI 102 is effective for reports or other materials published on or after 1 January 2027. Organisations adopting it earlier should state the edition used and ensure that related climate and energy datasets are prepared on compatible boundaries.
What Disclosure 102-1 expects from the transition plan
Disclosure 102-1 should be approached as a structured reconciliation. Each element must be supported by evidence, and the parts must agree with one another. A plan cannot credibly claim alignment with a pathway while the expenditure, operating actions and public-policy positions point in a different direction.
In practice
| Plan element | What the disclosure should explain | Evidence to retain — Frequent weakness |
|---|---|---|
| Climate impacts and policy response | Which significant climate-change impacts the plan addresses and which policies and actions respond to them. | Materiality evidence, impact register, approved policies and action portfolio. — The plan describes financial risk only and does not identify external impacts. |
| Scientific alignment and scenarios | How the plan is aligned with limiting warming to 1.5°C and which scenarios, assumptions or pathways were used. | Scenario files, modelling assumptions, source references and specialist review. — A 1.5°C label is used without showing the pathway, boundary or dependencies. |
| Strategy and operating model | How the plan affects business strategy, products, assets, sourcing, technology and operational decisions. | Strategy papers, asset plans, procurement rules and management approvals. — A sustainability programme sits outside core strategy. |
| Targets and progress | The GHG-reduction, fossil-fuel phase-out and other mitigation targets, baselines, time horizons, progress and deviations. | Target register, inventory, baseline approvals, progress dashboards and corrective actions. — Targets are presented without boundary, base year or current performance. |
| Actions and dependencies | The principal actions, sequencing, external dependencies, enabling conditions and barriers. | Implementation roadmap, contracts, technology assessments and dependency log. — A project list is presented without timing, responsibility or expected contribution. |
| Expenditure and capital allocation | The total expenditure associated with the plan and its percentage of total expenditure, together with the basis used. | Approved budgets, capital plan, finance reconciliation and classification method. — Only selected ‘green capex’ is shown, with no denominator or reconciliation. |
| Governance and accountability | Who oversees, approves, implements and reviews the plan and how progress is escalated. | Board and committee terms, minutes, role descriptions, management reporting. — Generic board oversight is claimed without evidence of decisions or review. |
| Just transition and engagement | How the organisation identifies and addresses impacts on workers, non-employee workers, communities, Indigenous Peoples and biodiversity, and how engagement informs decisions. | Workforce plans, agreements, engagement records, community assessments and remedy actions. — Consultation activity is reported as proof that the transition is fair. |
| Public-policy consistency | How lobbying, trade-association positions and other public-policy engagement are consistent with the plan. | Membership register, position review, escalation and remediation records. — The report is silent on conflicting advocacy. |
Rule
ABSENCE IS REPORTABLE
If the organisation does not have a transition plan, the response is not to present an aspirational target as a substitute. GRI 102 requires it to explain why the plan is absent, the steps being taken to develop one and the expected timeframe. The same principle applies to the adaptation-plan disclosure.
In practice
Transition plan, adaptation plan and just transition: three connected but distinct disclosures
| Component | Primary focus | Typical evidence — Do not confuse with |
|---|---|---|
| Transition plan — 102-1 | Mitigation of climate-change impacts and transformation of strategy, operations and capital towards a lower-emissions pathway. | Targets, policies, actions, scenarios, expenditure, governance, engagement and progress. — A net-zero commitment, a GHG inventory or a list of efficiency projects. |
| Adaptation plan — 102-2 | Response to actual and potential physical climate impacts and the resilience of affected people, ecosystems, assets and operations. | Location-specific physical-impact assessment, adaptation actions, expenditure, governance, milestones and monitoring. — Business continuity alone, or an enterprise risk heat map with no impact response. |
| Just transition — 102-3 and 102-1 links | Distributional and rights-related consequences of mitigation and adaptation for workers, non-employee workers, communities and Indigenous Peoples. | Workforce transitions, reskilling, terminations, redeployment, pay, agreements, affected locations, engagement and remedy. — A general diversity programme, philanthropy or consultation with no decision trail. |
What just-transition evidence should show
A just-transition disclosure needs to move from principle to affected groups, locations and outcomes. The organisation should identify where closures, technology changes, fuel switching, asset repurposing, new sourcing models or adaptation measures could affect people. It should then show the engagement and response, not merely the existence of a policy.
In practice
| Evidence area | Illustrative GRI 102-3 data | Control question |
|---|---|---|
| Workforce movement | New hires, terminations, redeployments and workers receiving upskilling or reskilling in connection with the transition. | Are the populations and transition-related causes defined consistently across HR systems? |
| Workers who are not employees | Changes affecting contractors, agency workers and other controlled or materially affected workers. | Does the analysis exclude people because they sit outside the employee payroll? |
| Pay and living standards | Basic pay in relation to cost-of-living information for relevant workers or locations. | Are the benchmark, geography, period and worker population transparent? |
| Affected communities and Indigenous Peoples | Locations where transition actions affect communities or Indigenous Peoples and the nature of the impact. | Is the location list connected to actual projects and impact evidence? |
| Agreements and engagement | The proportion or coverage of locations subject to agreements and the process by which engagement influenced decisions. | Is engagement evidence linked to modifications, safeguards, remedy or benefit-sharing? |
| Outcomes and grievances | Observed effects, grievances, remediation, unresolved issues and lessons for the plan. | Does the disclosure report adverse outcomes and not only activities completed? |
Connect the narrative to GHG metrics, energy data and capital allocation
The transition-plan section should not operate as an isolated narrative. The stated pathway must reconcile to the organisation’s GHG targets, emissions inventory, removals and other climate metrics under GRI 102, and to the energy-consumption, intensity and reduction information under GRI 103. Where the plan assumes renewable electricity, electrification, energy efficiency, fuel substitution or supplier decarbonisation, those assumptions should be visible in the relevant datasets and action tracking.
In practice
| Narrative claim | Expected reconciliation | Red flag |
|---|---|---|
| “We will halve emissions by 2030.” | Target boundary, base year, scopes and gases; current gross emissions; actions and expected contribution; target progress. | The report shows a target but no comparable current-year inventory. |
| “Capital is aligned to the transition.” | Plan expenditure value, percentage of total expenditure, classification rule and finance reconciliation. | Only a small project subset is labelled without a total-expenditure denominator. |
| “We are moving to renewable energy.” | GRI 103 source split, contractual instruments, site coverage, residual non-renewable energy and double-count controls. | Certificates or contracts are discussed without underlying consumption. |
| “The transition will create quality jobs.” | Job creation and loss by location, job type, worker category, pay conditions, skills programme and engagement. | Gross job creation is reported while closures and contractor impacts are omitted. |
| “Communities support the project.” | Stakeholder identification, engagement method, concerns, agreement coverage, modifications and unresolved matters. | Attendance at a meeting is presented as consent or support. |
A four-level maturity test
Plan maturity is not a formal GRI scale. It is an implementation aid that helps prevent overstatement and gives reviewers a consistent basis for disclosure wording.
In practice
| Level | Evidence state | Appropriate disclosure stance — Next control |
|---|---|---|
| 1 — No mature plan | Targets or intentions may exist, but no integrated plan has been approved. | State that no transition plan currently exists; explain why, current development steps and expected timeframe. — Assign executive sponsor, define scope and prepare an approval roadmap. |
| 2 — Framework in development | Governance, analytical work and potential actions exist, but major assumptions, expenditure or decisions remain open. | Describe the development status, confirmed elements, unresolved decisions, dependencies and planned approval date. — Create decision log, scenario basis, costed action portfolio and stakeholder plan. |
| 3 — Approved plan | Governance body has approved a coherent plan with targets, actions, expenditure and responsibilities. | Report the approved boundary, assumptions, actions, affected groups, expenditure, milestones and current progress. — Embed monthly or quarterly performance, deviation and change controls. |
| 4 — Implemented and monitored | Actions are under way and outcome evidence, deviations and corrective actions are available. | Report progress and adverse effects as well as achievements; explain material changes to the plan. — Independent challenge, assurance readiness and periodic plan refresh. |
A reusable ten-part drafting structure
1. State the plan’s status, approval date, boundary, time horizon and relationship to the reporting period.
2. Describe the significant climate-change impacts the plan addresses, including affected activities and value-chain relationships.
3. Explain the scientific basis, scenarios, assumptions and dependencies, including how 1.5°C alignment has been assessed.
4. Set out targets, baselines, milestones, current performance and any missed or revised milestones.
5. Describe the principal actions, sequence, owners and expected contribution, separating committed actions from options under evaluation.
6. Report plan expenditure, the share of total expenditure and the classification and reconciliation method.
7. Explain governance oversight, management responsibilities, review frequency and decisions taken during the period.
8. Identify affected workers, workers who are not employees, communities, Indigenous Peoples and biodiversity, and explain engagement and response.
9. Describe the relationship to the adaptation plan, public-policy positions and material external dependencies.
10. Disclose limitations, unresolved decisions, data gaps, deviations and the next formal review or approval date.
Illustrative disclosure where the plan is incomplete
The organisation should not label the modelling work as a completed transition plan. It can give a useful GRI 102 response by describing the confirmed targets and actions, the governance process, the scenarios considered, the open capital decisions, current expenditure, affected locations and the work programme and expected timeframe for approval.
Hypothetical scenario
HYPOTHETICAL SCENARIO
A cement producer has a 2050 net-zero ambition and approved 2030 Scope 1 and Scope 2 targets. It has modelled several technology pathways but has not approved a full transition plan because the timetable and capital implications of carbon capture remain unresolved. Two plants may be repurposed, affecting employees, contractors and nearby communities.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
| Weak wording | Stronger, fact-based wording |
|---|---|
| “Our net-zero transition plan is aligned with 1.5°C and will create green jobs.” | “At 31 December 2026, the Group had not approved an integrated transition plan. The Board has approved 2030 Scope 1 and Scope 2 targets and the electrification programme for three grinding sites. A 1.5°C pathway assessment and options appraisal for kiln technology and carbon capture were completed during the year, but final investment decisions for Plants A and B remain outstanding. £42 million of 2026 expenditure, representing 3.1% of total capital and operating expenditure as defined in our methodology, supported approved transition actions. Workforce and community assessments have begun at the two potentially affected plants; no closure decision has been taken. Management expects to submit the integrated plan for Board approval in Q4 2027.” |
Rule
WHY THE STRONGER WORDING WORKS
It separates approved facts from options, gives a reporting-date status, identifies expenditure and denominator, names affected locations, avoids claiming outcomes that have not occurred and provides a decision timeframe. It still requires company-specific verification and adaptation.
Greenwashing risks and common reporting errors
• Calling a long-term ambition a transition plan when there is no approved action, expenditure or governance architecture.
• Claiming 1.5°C alignment without identifying the scenario, assumptions, boundary or treatment of residual emissions.
• Presenting gross investment in selected projects without the total-expenditure denominator required by the disclosure.
• Reporting only emissions reductions while omitting adverse impacts created by mine closure, asset retirement, land use or new infrastructure.
• Treating workforce reskilling activity as evidence that all job losses, contractor impacts and pay consequences have been addressed.
• Reporting stakeholder meetings without concerns, decisions, agreements, unresolved issues or remedy.
• Using future-tense claims as though funding, technology, permits and supply contracts were secured.
• Failing to reconcile the transition narrative with GHG inventory trends, energy data, strategy and public-policy engagement.
Rule
MYTH VERSUS REALITY
Myth: A company cannot report under GRI 102 until it has a mature transition plan. Reality: GRI 102 contains a transparent route for an organisation without a plan. It must explain the absence, current development steps and expected timeframe. Honest disclosure of immaturity is stronger than re-labelling a target or project list as a completed plan.
Readiness
Reviewer checklist
- • ☐ Plan status, boundary, approval and time horizon are explicit.
- • ☐ The disclosure begins with significant climate-change impacts, not only enterprise risk.
- • ☐ Scientific alignment and scenarios are supported by methods and assumptions.
- • ☐ Targets reconcile to current GHG metrics and the plan’s actions.
- • ☐ Expenditure value and share of total expenditure reconcile to finance records.
- • ☐ Approved actions are distinguished from proposals, dependencies and assumptions.
- • ☐ Governance evidence shows actual review and decisions during the period.
- • ☐ Workers, non-employee workers, communities, Indigenous Peoples and biodiversity are considered where affected.
- • ☐ Engagement evidence shows influence, agreements, unresolved concerns and remedy.
- • ☐ Adaptation, energy, public policy and capital-allocation narratives are consistent.
- • ☐ Gaps, deviations and missed milestones are reported in balanced language.
- • ☐ Absence of a plan is handled through the explicit GRI 102 route, not hidden through vague wording.
Bottom line
GRI 102 turns the transition plan into a test of organisational coherence. The climate target, business strategy, expenditure, energy data, workforce decisions, community engagement and public-policy positions need to tell the same story. An organisation can report credibly at an early maturity stage, but only if it is precise about what has been approved, what remains uncertain and when the missing decisions will be made.
Official source anchors
The source set below should be rechecked as part of the pre-publication update control. Normative conclusions in this article are based on the current official editions listed here.
1. GRI 102: Climate Change 2025. Official requirements and guidance for transition plans, adaptation, just transition, climate targets, GHG emissions and removals. Open official source
2. GRI 102: Climate Change 2025 — Frequently Asked Questions. Official implementation clarifications and transition information. Open official source
3. GRI 103: Energy 2025. Official energy disclosures supporting climate-plan actions and performance. Open official source
4. GRI 3: Material Topics 2021. Official basis for identifying significant climate-change impacts and reporting their management. Open official source
5. GRI Standards — English language. Official access point for current Standards, effective dates and publication versions. Open official source
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