Short answer
The answer, before the reasoning
“In accordance” is the comprehensive GRI reporting route and requires compliance with all nine requirements in GRI 1. “With reference” is a selective route for reporting specific GRI information and requires a content index, the prescribed with-reference statement and notification to GRI.
An organisation that cannot meet all nine in-accordance requirements must not describe itself as partly in accordance or GRI compliant; it may use the with-reference route if it meets all three requirements for that claim.
Choose the reporting route that the organisation can support with evidence and process.
At a glance
The practical distinction
Reporting in accordance is the comprehensive GRI route. It is available only when the organisation meets all nine requirements in GRI 1, including applying the reporting principles, reporting GRI 2, determining and reporting material topics, selecting relevant Topic disclosures, handling omissions, publishing the content index, using the prescribed statement and notifying GRI. Reporting with reference is for selected GRI information used for a specific purpose and has three requirements: content index, statement of use and notification.
The route is therefore a decision about the scope of the claim, not just the amount of content. A technically strong climate appendix can be reported with reference to selected GRI disclosures. It does not become an in-accordance GRI report unless the organisation has completed the wider materiality, Universal Standards, Sector Standards, omission and governance architecture required by GRI 1.
The nine requirements for reporting in accordance
The three requirements for reporting with reference
GRI 1 also recommends applying the reporting principles and explaining management of impacts using GRI 3-3 for topics reported with reference. Those recommendations improve quality, but they do not convert the route into an in-accordance claim.
LRA comparison matrix. Refer to GRI 1 for the full requirements and the exact prescribed statements.
Decision matrix
Four common use cases
Case 1: mature annual impact report
A multinational has a controlled materiality process, applies relevant Sector Standards, reports GRI 2 and GRI 3, selects Topic disclosures, manages omissions and completes the full index. The in-accordance route is the natural claim, provided the final review confirms all nine requirements.
Case 2: first-year climate disclosure
A company publishes selected Scope 1, Scope 2 and target information using GRI disclosures but has not completed a GRI materiality process or GRI 2. It should use the with-reference route rather than “partly in accordance”.
Case 3: regulatory cross-reference
An organisation reports under a local climate or stock-exchange regime and cross-references selected GRI disclosures to improve interoperability. With reference can accurately describe the GRI use, while the underlying legal claim remains governed by the local regime.
Case 4: report intended to transition
A first-time reporter uses with reference in year one and builds the impact assessment, Sector Standard review, GRI 2 evidence and full content index needed for an in-accordance claim in year two. The transition is credible only if the year-one claim remains accurate and the development plan is documented.
Claims to avoid
Reasons for omission do not rescue every gap
The in-accordance route permits only four reasons for omission, and not for every disclosure. The route cannot be preserved by inventing a fifth reason such as “data not prioritised”, “commercially sensitive” without a specific constraint, or “poor performance”. Nor should “not applicable” be used because a policy or process does not exist. Where the requirement applies, the organisation can often report that the item does not exist.
A practical route-selection process
Common mistakes
Reader checklist
☐ The intended reporting purpose and claim are documented.
☐ All nine in-accordance requirements or all three with-reference requirements have been tested.
☐ The correct content-index architecture is used.
☐ Applicable Sector Standards and material-topic decisions are documented where required.
☐ Only permitted omissions are used and non-omittable disclosures are complete.
☐ The prescribed statement is copied from the current GRI 1 edition and completed accurately.
☐ The report, index, basis of preparation and notification use the same route and period.
☐ No hybrid phrases such as “partly in accordance” or “GRI compliant” remain.
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
- Any organisation using GRI disclosures in a sustainability report, annual report, website, questionnaire or regulatory filing.
- Primary decision
- Which reporting route supports the intended claim and what minimum process is required.
- Key source
- GRI 1: Foundation 2021, sections on reporting in accordance and reporting with reference.
- Common confusion
- “With reference” is not a lower-quality version of “in accordance”; it is a different, selective reporting claim.
In practice
1
| 1 | Apply the reporting principles. Use the GRI principles that support quality and |
|---|---|
| 2 | Report GRI 2. Report all General Disclosures; reasons for omission are unavailable for Disclosures 2-1 to 2-5. |
| 3 | Determine material topics. Identify the organisation’s most significant impacts and use applicable Sector Standards. |
| 4 | Report GRI 3. Explain the process, list material topics and report how each material topic is managed. |
| 5 | Report relevant Topic disclosures. Select disclosures that are relevant to the organisation’s impacts for each material topic. |
| 6 | Provide permitted reasons for omission. Use only the four prescribed reasons where omissions are allowed and explain them as required. |
| 7 | Publish the GRI content index. Provide the full traceability structure, including Sector Standard information and locations. |
| 8 | Provide the prescribed statement of use. Use the exact GRI 1 wording with the organisation’s name and reporting period. |
| 9 | Notify GRI. Send the required notification information, including links and the statement of use. |
Rule
CLAIM BOUNDARY
If even one of the nine requirements is not met, the organisation cannot claim that the reported information has been prepared in accordance with the GRI Standards. It may be able to report with reference if all three requirements for that route are met.
In practice
Requirement
| Requirement | What it means in practice |
|---|---|
| Publish a GRI content index | List the selected disclosures, titles, source Standards and exact locations; identify the GRI 1 edition and include the correct statement. |
| Provide the prescribed statement of use | Use the with-reference wording in GRI 1 and insert the organisation’s name and reporting period. |
| Notify GRI | Provide the legal name, index link, report link where relevant, statement of use and contact details. |
In practice
Decision point
| Decision point | In accordance | With reference |
|---|---|---|
| Purpose | Comprehensive picture of the organisation’s most significant impacts and their management. | Selected GRI information for a specific purpose, topic, regulation or data request. |
| Materiality | Determine material topics under GRI 3 and report the required GRI 3 disclosures. | Not a formal condition of the route, although the organisation should avoid implying comprehensive impact coverage. |
| Universal Standards | GRI 1, all GRI 2 disclosures and GRI 3 requirements form the core architecture. | GRI 1 governs the route; selected disclosures may come from any relevant GRI Standard. |
| Sector Standards | Apply available Sector Standards to determine material topics and what to report. | Use selected Sector content only where relevant to the stated purpose. |
| Topic disclosures | Report those relevant to impacts for each material topic, including Sector-linked logic. | Report only the selected information cited in the index. |
| Omissions | Use only the four permitted reasons where allowed; include the required explanation. | Do not use omissions to disguise an incomplete in-accordance claim; list the information actually reported. |
| Public claim | Use only the prescribed in-accordance statement after all nine requirements are met. | Use only the prescribed with-reference statement after all three requirements are met. |
In practice
Risky claim
| Risky claim | Why it is risky | Safer pattern |
|---|---|---|
| “GRI compliant” | GRI 1 specifies reporting routes and prescribed statements; “compliant” is ambiguous and can imply certification. | State the exact in-accordance or with-reference route only after testing its requirements. |
| “Partly in accordance” | There is no hybrid reporting route in GRI 1. | Use with reference and explain the selected scope. |
| “GRI-based report” | The phrase does not tell users which requirements were met. | Use the prescribed statement and a transparent content index. |
| “Aligned with GRI” | May imply broader application than the evidence supports. | Describe the specific disclosures used and the reporting route. |
Rule
NON-OMITTABLE DISCLOSURES
Reasons for omission are not permitted for GRI 2 Disclosures 2-1 to 2-5 or GRI 3 Disclosures 3-1 and 3-2. These are core elements of the in-accordance architecture.
In practice
| 1 | Define the intended claim. Decide whether the publication is meant to provide a |
|---|---|
| 2 | Test all applicable requirements. Use a requirement-level checklist; do not decide from report length or the number of indicators. |
| 3 | Review Sector Standards. For an in-accordance claim, confirm which Sector Standards apply and how every listed topic was assessed. |
| 4 | Test omissions and locations. Confirm that each gap uses a permitted reason and that every index location is complete and accessible. |
| 5 | Align governance and publication. Ensure the basis of preparation, cover, index, board approval and notification all use the same route. |
| 6 | Record the transition plan. Where using with reference temporarily, define the evidence and process needed to move to in accordance without overstating the current year. |
In practice
Mistake
| Mistake | Consequence | Correction |
|---|---|---|
| Choosing the route after drafting | The publication may have the wrong architecture and missing evidence. | Lock the route during mobilisation and re-test at final approval. |
| Equating report length with comprehensiveness | A long report can still miss GRI 2, GRI 3 or Sector Standard requirements. | Review requirements, not page count. |
| Using omissions for non-existent processes | Misstates applicability and hides a management gap. | Report that the item does not exist where the requirement applies. |
| Combining prescribed statements | Creates an unsupported hybrid claim. | Use one correct statement for one route and one period. |
| Assuming assurance creates an in-accordance claim | Assurance scope and GRI reporting route are separate. | Test the nine GRI 1 requirements independently from assurance. |
Technical status
LEGAL AND TECHNICAL NOTE
This article explains the reporting routes in GRI 1: Foundation 2021. The exact prescribed statement of use should be copied from the current official GRI 1 text at publication. The article does not provide assurance over a reporting claim or determine whether a specific organisation has met all applicable requirements.
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