Short answer
The answer, before the reasoning
A GRI content index is required for both reporting in accordance with and reporting with reference to the GRI Standards. It identifies the reporting route, the GRI Standards and disclosures used, and the exact locations of reported information.
An in-accordance index also carries material-topic and Sector Standard information and permitted omissions. The index does not prove that the disclosures are complete: each location must still be tested against the underlying requirement and evidence.
The GRI content index is the traceability chain behind a credible reporting claim.
At a glance
Why the content index matters
A GRI content index is the controlled navigation layer between the organisation’s reporting claim and the information that supports it. It tells readers which GRI Standards and disclosures have been used, where the corresponding information can be found and, for an in-accordance report, how any permitted omissions have been handled. The index can sit inside a report or be published separately, but it must remain accessible and traceable.
The practical value goes beyond navigation. A well-built index exposes gaps early: an owner is missing, a location is too vague, an omission has no prescribed explanation, a Sector Standard reference has been overlooked, or a narrative claim cannot be reconciled to evidence. That is why the index should be built alongside the disclosure register throughout the reporting project rather than assembled on the final day.
What an in-accordance content index must contain
For reporting in accordance, the index carries the full reporting architecture. In practical terms, it should contain the following components:
The title “GRI content index”, the prescribed in-accordance statement of use and the edition of GRI 1 applied.
The applicable GRI Sector Standards, the organisation’s material topics and any Sector Standard topics judged not material, together with the explanation required by GRI 1.
Every disclosure reported, including its title and the GRI Standard or other source from which it comes.
The precise location of the reported information, using page, section, stable URL or another reader-usable reference.
Sector Standard reference numbers where applicable.
Disclosures listed for Sector Standard topics that were not reported, together with the required reason for omission.
All other permitted reasons for omission used for disclosures or individual requirements within disclosures.
What a with-reference content index must contain
The with-reference route is narrower. Its index identifies the selected GRI disclosures, their titles, the Standards they come from and the locations of the reported information. It also includes the prescribed with-reference statement, identifies the GRI 1 edition and supports notification to GRI. It does not turn a selective use of GRI into an in-accordance claim.
The anatomy of a strong index row
Each row should answer five different questions. Combining them in one vague cell weakens traceability.
Illustrative LRA visual. The working register may include additional internal control fields that are not displayed in the public index.
A practical eight-step workflow
Reasons for omission: what the index must show
Illustrative index entries
Weak versus stronger locations
Common mistakes and how to correct them
Reader checklist
☐ The reporting route and reporting period are locked and consistent across the publication.
☐ The GRI 1 edition and all applicable Sector Standards are identified.
☐ Every cited location is precise, accessible and complete.
☐ Material topics and Sector Standard topics judged not material are handled correctly.
☐ Only permitted omissions are used, with the required explanations.
☐ Disclosure titles, Sector reference numbers and locations have been technically reviewed.
☐ The public index reconciles to the internal disclosure register and evidence pack.
☐ Notification to GRI is prepared using the correct statement of use.
Free LRA template included with this package
The accompanying Excel workbook contains separate in-accordance and with-reference index sheets, a material-topic register, omission register, source register, controlled lists and readiness checks. It is an LRA implementation aid, not an official GRI template. Users should compare the workbook against the current GRI 1 requirements before publication.
Official sources and technical status
1. GRI 1: Foundation 2021. Open official source - Reporting routes, omissions, content index, statements of use and notification.
2. GRI Content Index Template and reporting tools. Open official source - Official GRI content-index support page.
Quick orientation
Quick orientation
- Applies to
- Organisations reporting in accordance with or with reference to the GRI Standards.
- Primary decision
- What must appear in the index, how each row should point to evidence, and how omissions should be recorded.
- Key source
- GRI 1: Foundation 2021, especially Requirements 6-9 and Appendices 1-2.
- Common confusion
- A content index is not a checklist that proves the underlying disclosures are complete.
Rule
REQUIREMENT VS IMPLEMENTATION PRACTICE
GRI 1 specifies what the content index must contain. Maintaining an internal disclosure register with owners, evidence, review status and control sign-off is an LRA implementation practice that helps the organisation meet those public requirements reliably.
In practice
Element
| Element | In accordance | With reference |
|---|---|---|
| Reporting claim | Comprehensive route; all nine GRI 1 requirements must be met. | Selected GRI information for a specific purpose; all three with-reference requirements must be met. |
| Material topics | List material topics and address applicable Sector Standard topics. | Not a condition of the route, although impact management information remains good practice. |
| Disclosure list | Reported GRI disclosures, titles, sources, locations, Sector references and omissions where relevant. | Selected GRI disclosures, titles, source Standards and locations. |
| Reasons for omission | Recorded where GRI 1 permits them and the organisation cannot comply. | Not a mechanism for claiming an incomplete in-accordance report; only information actually cited is listed. |
| Notification | Notify GRI of use and statement of use. | Notify GRI of use and statement of use. |
In practice
Column
| Column | Question it answers | Strong practice |
|---|---|---|
| Standard / source | Where does the requirement come from? | State the GRI Standard and edition, or the approved non-GRI source. |
| Disclosure | What exact information is being reported? | Use the disclosure number and title; identify a missing requirement within a disclosure where relevant. |
| Location | Where can the reader find the complete answer? | Give a page and section, or a stable URL with an identifiable heading. |
| Omission | Which permitted reason and explanation apply? | Name the prescribed reason; specify what is missing, why, and the action/time frame where required. |
| Evidence / review | Who owns the answer and has it been checked? | Keep this internal field in the working register, even if not shown publicly. |
In practice
1
| 1 | Lock the reporting route. Decide whether the organisation will report in accorda |
|---|---|
| 2 | Confirm the standards set. Record the GRI 1 edition, applicable Sector Standards and relevant Topic Standards. |
| 3 | Create a disclosure register. List each requirement, owner, evidence source, drafting location, review status and public index location. |
| 4 | Map locations precisely. Use page numbers, section titles, anchors or stable URLs. Avoid “sustainability section” or “website”. |
| 5 | Test completeness. Check that the cited location answers the whole requirement, not merely the topic in general. |
| 6 | Resolve omissions. Use only the four permitted reasons and provide the prescribed explanation; report available partial information. |
| 7 | Reconcile the claim. Confirm that the index, basis of preparation, report cover and notification use the same reporting route and period. |
| 8 | Perform final link and evidence QA. Test URLs, page references, disclosure titles, Sector references, approvals and version control. |
In practice
Permitted reason
| Permitted reason | What the explanation needs to do |
|---|---|
| Not applicable | Explain why the disclosure or requirement does not apply, or why a Sector-listed Topic disclosure is not relevant to the organisation’s impacts. |
| Legal prohibitions | Identify the specific legal restriction that prevents collection or public reporting. |
| Confidentiality constraints | Describe the specific confidentiality constraint; use this exceptionally rather than as a generic sensitivity label. |
| Information unavailable / incomplete | Specify what is missing and for which entities, sites or locations; explain why; describe actions and the expected time frame to obtain it. |
Rule
IMPORTANT EXCEPTION
Reasons for omission are not permitted for GRI 2 Disclosures 2-1 to 2-5 or GRI 3 Disclosures 3-1 and 3-2. A missing policy, process or committee is not automatically “not applicable”: where the requirement applies, the organisation can report that the item does not exist.
Hypothetical scenario
ILLUSTRATIVE WORDING - ADAPT TO FACTS
The examples below are written by LRA to teach structure. They are not official GRI templates and do not demonstrate compliance without checking the full requirement and the organisation’s facts.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
Standard / disclosure
| Standard / disclosure | Location | Illustrative index treatment |
|---|---|---|
| GRI 2: 2-2 Entities included in sustainability reporting | Annual report 2025, “Reporting boundary”, pp. 18-20 | No omission field. The cited section reconciles the sustainability boundary to the consolidated group and explains exclusions. |
| GRI 3: 3-3 Management of water as a material topic | Sustainability report, “Water impacts and management”, pp. 54-58 | The location covers policy, actions, effectiveness tracking and stakeholder engagement for this specific topic. |
| GRI 101: 101-7 Changes to the state of biodiversity | Biodiversity appendix, Table B-4 | Information unavailable / incomplete: ecosystem condition baseline is missing for two acquired sites; surveys are scheduled for Q2 2027. Available location and pressure data are still reported. |
In practice
Weak location
| Weak location | Why it fails | Stronger alternative |
|---|---|---|
| “Sustainability section” | The reader cannot identify the disclosure and reviewers cannot test completeness efficiently. | “Annual report 2025, Climate transition plan, pp. 86-91; target table p. 93.” |
| “Website” | The URL may change and the information may not be identifiable or version-controlled. | Stable URL plus page heading and access date; archive a publication copy. |
| One page for a multi-part disclosure | The citation may cover only one sub-requirement. | Use multiple locations or a range that demonstrably covers every relevant part. |
In practice
Mistake
| Mistake | Risk | Correction |
|---|---|---|
| Building the index after the report is designed | Late discovery of missing disclosures, weak locations and unresolved omissions. | Use a live disclosure register from mobilisation to approval. |
| Listing every disclosure in a Topic Standard | Creates the false impression that the organisation committed to disclosures that are not relevant to its impacts. | Select relevant disclosures under GRI 1 and document the judgement. |
| Using “not applicable” because data are difficult | Confuses relevance with data availability. | Use the correct reason and provide the required explanation, or report that an item does not exist where applicable. |
| Treating the index as evidence of disclosure quality | A correct reference can still point to a weak or incomplete answer. | Perform requirement-level content review and evidence testing. |
| Changing the route only in the statement of use | The index architecture and report claim become inconsistent. | Re-test the entire package against the selected route. |
Technical status
LEGAL AND TECHNICAL NOTE
This article explains GRI 1: Foundation 2021 and includes an LRA implementation workbook. It does not reproduce the official GRI template, provide assurance, or determine whether a specific report may claim to be in accordance. Recheck the current GRI 1 edition and official reporting tools before publication.
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LRA_GRI_Content_Index_Free_Template.xlsx
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Questions
Questions people ask
GRI “In Accordance” vs “With Reference”: What Is the Difference?
For reporting in accordance, the index carries the full reporting architecture. The with-reference route is narrower. Its index identifies the selected GRI disclosures, their titles, the Standards they come from and the locations of the reported information.
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The checklists as a working spreadsheet
Every checklist and table on this page, with empty status, owner and evidence columns for your team to fill in and keep.
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