GRI Content Index Review Checklist: 25 Checks before Publication

Technical status: source-grounded publication draft; final human technical review required before release.

The GRI content index is the navigation map of the reported information. Under GRI 1 Requirement 7, it must identify the reporting claim, GRI 1 edition, applicable Sector Standards, material topics, reported disclosures, sources, locations and reasons for omission, together with specific Sector Standard information. Requirement 8 sets the statement of use. These are not formatting preferences: they are part of the conditions for reporting in accordance.

A final review therefore has two jobs. It tests the index as a reporting artefact, and it tests the path from each row to the published disclosure. The second job is where many reviews fail. A page number can be accurate yet still lead to a heading, generic policy statement or partial answer. The reviewer needs to test the disclosure at requirement level.

Freeze the candidate publication set. Identify the exact report PDF, Content Index file, annual report, assurance report and web pages to be tested. Draft links are not acceptable evidence.

Assign independent row testing. The person who built the index should not be the only person who opens the references and judges completeness.

Test claims and architecture first. Resolve statement of use, period, applicable Sector Standards and material topics before checking hundreds of row locations.

Test by requirement, not only by disclosure. Break complex disclosures into their lettered and numbered requirements and record partial gaps.

Record evidence of pass. A check is complete only when the reviewer records what was opened, what matched and which version was tested.

Lock and archive. After approval, changes to report text, web pages, numbers or links trigger a targeted re-test before release.

Figure 1. The 25 checks are grouped into five publication gates.

Use the “pass evidence” column as the minimum record in the review file. A pass should be reproducible by another reviewer. The failure examples are diagnostic, not exhaustive.

The first five checks protect the highest-level claim. For reporting in accordance, GRI 1 gives the statement pattern: “[Name] has reported in accordance with the GRI Standards for the period [start and end dates].” The organisation should not improvise a stronger claim such as “GRI certified”, “fully compliant” or “approved by GRI”. The statement must describe the same reporting organisation and period as the report and GRI 2 disclosures.

Sector Standard applicability must be concluded before the index is final. If a Sector Standard applies, its title belongs in the index and its likely material topics need to be reflected in the material-topic assessment. A diversified group may need more than one Sector Standard.

The index is not the place to repair an unapproved material-topic list. Disclosure 3-2 and the index should present the same final list. If presentation labels differ for readability, maintain a controlled cross-reference so the reader and reviewer can see that the concepts are the same.

GRI 1 requires an organisation to review topics in applicable Sector Standards. Topics assessed as not material must be listed in the index with an explanation. For material topics covered by a Sector Standard, the organisation either reports the listed Topic Standard disclosures or provides the “not applicable” reason for omission and required explanation where Requirement 5-b applies. Separately, GRI 1 Requirement 5-a states that only Topic Standard disclosures relevant to the organisation’s impacts need to be reported. The review must distinguish these two situations.

GRI 1 guidance expects specific page numbers or links. Where information is spread across locations, all necessary locations should be included. The reviewer should click or open every reference in the final environment, not in an authoring system. A link to a policy can support a disclosure, but a policy rarely provides reporting-period results, effectiveness, limitations or stakeholder information by itself.

Figure 2. A valid Content Index row creates a tested chain from requirement to published evidence.

Create a temporary reviewer sheet with one row for each requirement inside the disclosure. Mark each element as reported, not applicable, omitted with a permitted reason, or unresolved. Then compare that sheet with the public Content Index. This catches the common situation where a row claims a complete disclosure while the report answers only one part.

GRI 1 permits four reasons for omission: not applicable, legal prohibitions, confidentiality constraints, and information unavailable/incomplete. Each has a required explanation. “Not material”, “data pending”, “commercial sensitivity” and “not disclosed this year” are not substitute labels. For information unavailable/incomplete, the explanation must identify the missing information, explain why it is missing, and describe the steps and expected timeframe to obtain it.

Reasons for omission are not permitted for Disclosures 2-1 to 2-5, 3-1 or 3-2. This makes the test especially important for reporting boundary, period, restatements, external assurance and material-topic process. If the required item does not exist - for example, a policy or committee - the organisation can often comply by reporting that it does not exist rather than treating the absence as an omission.

Where the organisation refers to external assurance, the wording must match the practitioner’s report: subject matter, criteria, reporting period, level of assurance, exclusions and limitations. A limited-assurance engagement over selected metrics does not support the unqualified statement “the sustainability report was assured”. Similarly, GRI’s Content Index Services review the presentation, accessibility and sampled implementation of Content Index requirements within the stated service scope; they are not an external assurance conclusion over all reported sustainability information.

A technically correct index can become wrong in the last 24 hours of production. Page reflow changes references, a web editor updates a policy, finance replaces a number, the assurance statement changes its scope, or a report PDF is renamed and re-uploaded. The final gate tests the whole publication set as a controlled version.

At minimum, reconcile organisation name, period, entities, boundary, material topics, policies, targets, quantitative values, units, base years and restatements across the report, annual report, index, assurance report and web pages. Links should be accessible without credentials and stable enough for the expected life of the report. If a web page is intended to remain live and change over time, retain an archived publication snapshot or date/version reference.

The reviewer should issue one of three outcomes: approve, approve with documented non-critical actions, or reject for revision. A wrong reporting claim, a prohibited omission, a missing Sector Standard requirement, a material requirement-level gap, a non-substantive location or a serious cross-document inconsistency is a rejection issue. Do not downgrade a critical technical problem because the publication deadline has arrived.