Disclosure GuidesPillar guides, articles, FAQ and expert notes
Level 4 · Expert note·GRI · Disclosure guides
Partial GRI disclosures: reporting missing requirements without misleading readers
Report the information that is available, but do not present a disclosure as complete when a required item or required scope is missing. For reporting in accordance, identify the exact disclosure requirement that cannot be met, confirm that a reason for omission is permitted, and record the permitted reason and the required explanation in the Content Index. Additional voluntary information, an alternative KPI or a reference to a Topic Standard does not cure a missing requirement. If the missing item is one for which omissions are not permitted, an omission cannot support an in-accordance claim — the disclosure has to be corrected, or the reporting status reconsidered.
Who this is for
Written for content index owners, reviewers and assurance teams. It assumes the reader knows the standard and needs a defensible way to test someone else's work.
A revision of GRI 1 Requirement 5, 6 or 7. A new GRI interpretation on partial …
Published
9 Aug 2026
Knowledge Hub guide
Last reviewed
1 Aug 2026
A method, not an explanation
Partial GRI disclosures: reporting missing requirements without misleading readers
Report the information that is available, but do not present a disclosure as complete when a required item or required scope is missing. For reporting in accordance, identify the exact disclosure requirement that cannot be met, confirm that a reason for omission is permitted, and record the permitted reason and the required explanation in the Content Index. Additional voluntary information, an alternative KPI or a reference to a Topic Standard does not cure a missing requirement. If the missing item is one for which omissions are not permitted, an omission cannot support an in-accordance claim — the disclosure has to be corrected, or the reporting status reconsidered.
Why it matters
A disclosure can look substantial and still be incomplete
A disclosure can carry a great deal of information and still be missing one decisive element: a category, a geographic scope, a denominator, a methodology component or a required explanation. The risk grows when the Content Index lists only the disclosure number and a page reference, because nothing in that row tells the reader what was not reported.
GRI 1 addresses this at the level of a disclosure or a requirement within a disclosure. That precision is the whole point. A transparent partial disclosure remains useful; an unlabelled one creates a completeness problem and can put the reporting claim in question.
Quick orientation
What you are actually deciding
Applies to
Any disclosure where information, entities, sites, geographies, categories or required narrative elements are missing.
Primary decision
Is the item genuinely not required, permitted to be omitted, unavailable, replaced by voluntary information — or merely referenced without being fully reported?
Key source
GRI 1 Requirements 5 to 7 and Appendix 1; the Universal Standards FAQ on reasons for omission.
Common confusion
Treating some information about a topic as equivalent to reporting every requirement in the cited GRI disclosure.
Classification
Six situations that should never be mixed
Most partial-disclosure problems are really classification problems. Decide which of these you are in before writing anything into the Content Index.
Situation
What it means
Content Index treatment
Complete reported disclosure
Every applicable requirement and the required scope are reported.
List the disclosure with its location.
Incomplete requirement
The disclosure is relevant, but a required item or part of its scope is missing.
Specify the exact requirement, the permitted reason and the prescribed explanation.
Disclosure not relevant under Requirement 5-a
A Topic Standard disclosure does not address your impacts for the material topic, and no applicable Sector Standard requires it.
Do not list it, and do not write an omission entry for it.
Sector Standard-listed disclosure judged not relevant
The disclosure is listed for a material topic in an applicable Sector Standard but does not address your impacts.
List it, and use "not applicable" with an impact-based explanation.
Additional voluntary information
An organisation-developed KPI, another framework's datapoint or extra narrative supplements the reporting.
Label it as additional information, separately from the reported GRI disclosures.
A simple reference to a Topic Standard
The report mentions or draws on a Standard without reporting a complete named disclosure.
Do not list the disclosure as reported.
The rule
What is required, and what is not
What GRI 1 requires for an incomplete item
Where a reason for omission is permitted, the Content Index identifies the disclosure — or the specific requirement — that cannot be met.
One of the four permitted reasons is used, with the explanation prescribed for that reason.
For information unavailable or incomplete: what is missing, why, the steps being taken and the expected timeframe to obtain it.
Where only certain entities, sites or locations are missing, those parts are named rather than hidden inside a general limitation note.
The disclosure is checked against the list for which no reason for omission is permitted.
What an omission is not
Poor performance is never a reason for omission.
A policy, committee or process that does not exist is not automatically "not applicable" — where the disclosure asks whether it exists, report that it does not.
A different metric is not a substitute unless it supplies the required information, or is clearly labelled as additional.
A general data-quality disclaimer does not replace the requirement-level entry in the Content Index.
A broad statement that the organisation uses a Topic Standard does not establish that each listed disclosure has been reported.
Figure 1diagram
The review starts at the exact requirement and tests whether omission is permitted before any reporting status is approved. · London Reporting Academy
The method
Decision logic for partial information
This is the sequence to run over someone else's Content Index — or your own, before it is published.
Confirm why the disclosure is in scopeRelevant to your impacts, listed in an applicable Sector Standard, or selected for with-reference reporting.
Break the disclosure into its requirementsReview the individual requirements and the required scope, not the disclosure title.
Mark the status of each requirementComplete, not applicable on its facts, unavailable, confidential, legally prohibited, or simply not reported.
Check whether omission is permitted thereFor that disclosure and for that specific requirement — the two are not the same question.
Report what is available, and place the omission preciselyAt the exact missing requirement, not across the whole disclosure.
Test the location, the wording and the row togetherThe Content Index row must not imply more completeness than the underlying disclosure delivers.
Assess the reporting statusA non-permitted missing item blocks in-accordance reporting. Permitted omissions can coexist with the claim when every omission requirement is met.
In practice
Six situations and their correct treatment
Scenario
Correct treatment
Scope 3 data available for 70% of purchasing spend
Report the available calculation, identify the missing supplier categories or entities, and explain the gap with steps and an expected timeframe.
A human-rights policy commitment has not been developed
Report that the commitment does not exist, and optionally explain the plan to develop one. This is not an omission.
A Topic Standard has five disclosures; only two address the material impact
Report the two relevant disclosures. The other three need no omission entry unless an applicable Sector Standard lists them.
A Sector Standard lists a disclosure that is not relevant to your impacts
List the disclosure and give "not applicable" with a brief impact-based explanation.
The organisation reports a custom employee-wellbeing index
Identify it as an organisation-developed or other-source disclosure, and explain its method.
A with-reference report uses one part of a multi-part disclosure
Use a scope column or note to identify the reported requirement and the limitation. Do not present the whole disclosure as reported.
Hypothetical scenario
Illustrative wording — adapt to the actual disclosure
Reported information: available data for entities representing 82% of the required scope. Requirement omitted: the named requirement, for the remaining entities. Reason: information unavailable / incomplete. Explanation: identify the entities, the reason for the gap, the action owner and the expected reporting period for completion. This shows the structure of a defensible entry — it is not a universal compliant clause.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
The claim
When an in-accordance claim becomes hard to defend
Finding
Effect on the claim
The missing item is in Disclosure 2-1 to 2-5, 3-1 or 3-2
No reason for omission is permitted. The requirement has to be corrected for in-accordance reporting.
The Content Index names the disclosure but not the missing requirement
Requirement 6 is not met at the level of precision it demands.
The reason given is not one of the four permitted reasons
The omission does not meet GRI 1.
"Information unavailable" is used with no steps or expected timeframe
The prescribed explanation is incomplete.
Many central disclosures are omitted on exceptional reasons
The claim may remain technically available where each omission is permitted, but credibility and the comprehensive-picture objective both suffer.
Only additional voluntary metrics are reported
The underlying GRI disclosures have not necessarily been reported. With-reference wording may be the accurate claim.
Presentation
Weak versus stronger Content Index rows
Illustrative only — the pattern to copy is the precision, not the sentences.
Weak
Stronger
"305-3 — pages 45–46. Data is incomplete."
"305-3 [named requirement] — pages 45–46. Information unavailable / incomplete for [named entities or categories]. Reason, remediation steps and expected timeframe stated."
"GRI 403 used. See people chapter."
Reported requirements from the named disclosure are listed separately with exact pages; unreported requirements are not represented as complete.
"Not applicable — no policy."
The disclosure applies. The organisation reports that the policy does not exist, and explains the current plan where relevant.
"See alternative KPI."
The alternative KPI is labelled additional voluntary information. The GRI requirement is separately assessed and, if missing, handled through a permitted omission.
Common mistakes
What reviewers find most often
Reviewing disclosure numbers, but not the requirements inside them.
Using "not applicable" for an item the organisation should have but has not implemented.
Reporting available data without identifying the excluded entities or scope.
Assuming every unselected Topic Standard disclosure needs a reason for omission.
Using a voluntary KPI or another framework's datapoint as a silent substitution.
Listing a full disclosure in a with-reference index when only one requirement is reported.
Keeping omission detail in an internal gap log rather than in the public Content Index.
Myth
Any missing information automatically prevents reporting in accordance with the GRI Standards.
Reality
Permitted reasons for omission can be used while reporting in accordance, provided the exact disclosure or requirement and the prescribed explanation appear in the Content Index. The claim fails when the missing requirement is not identified, when the reason is not one of the four, or when the explanation is absent.
Review tests
Eight tests to run over a Content Index
Can the reviewer identify every individual requirement in the selected disclosure?
Does the reported information cover the complete required scope?
Is the missing part named in the Content Index, rather than only in the report narrative?
Is the reason one of the four permitted categories, with the correct explanation?
Is this a disclosure for which omission is permitted at all?
Is voluntary information clearly separated from reported GRI disclosures?
Does the Content Index row avoid implying complete reporting?
Does the final statement of use match the result of this review?
Self-check
Would a reader know exactly what is missing, without comparing the report against the Standard?
If the alternative KPI were removed, would the GRI requirement still be complete?
Is this a true omission — or should the organisation simply report that the item does not exist?
Would the same Content Index row be accurate for both an in-accordance and a with-reference claim?
Where this sits
Related requirements and next steps
GRI 1 Requirement 5
Selecting relevant Topic Standard disclosures, and handling Sector Standard-listed ones.
GRI 1 Requirement 6
Requirement-level omissions and the explanation each reason demands.
GRI 1 Requirement 7 and Appendix 1
Where omissions and locations sit in the Content Index.
GRI 2 Disclosures 2-1 to 2-5, GRI 3 Disclosures 3-1 and 3-2
The disclosures for which no reason for omission is permitted.
GRI 1 with-reference requirements and Appendix 2
Selected disclosures and the precise locations a with-reference claim needs.
Questions reviewers ask
Partial disclosures, in short
Can a GRI disclosure be partly reported?
Yes — report what is available. What you cannot do is present the disclosure as complete. Name the missing requirement, use a permitted reason for omission and give the prescribed explanation in the Content Index.
Can a reason for omission apply to just one requirement?
Yes, and that is the level GRI 1 works at. An omission belongs at the exact missing requirement rather than across the whole disclosure, and everything still reportable should still be reported.
Does missing data prevent reporting in accordance?
Not by itself. Permitted omissions can coexist with an in-accordance claim when each one identifies the requirement, uses one of the four permitted reasons and carries the required explanation. The claim fails when the missing item is one for which omission is not permitted, or when the entry is imprecise.
Do all unreported Topic Standard disclosures need an omission entry?
No. A Topic Standard disclosure that does not address your impacts for the material topic, and is not required by an applicable Sector Standard, is simply not listed. An omission entry is for a disclosure you would otherwise have to report.
Can a custom KPI replace a GRI disclosure?
No. An organisation-developed KPI or another framework's datapoint is additional information and should be labelled as such. The GRI requirement is assessed separately, and if it is missing it is handled through a permitted omission.
Technical status
Technical status
Current as at 1 August 2026, against GRI 1: Foundation 2021. Verify every example against the actual requirements of the cited Topic Standard before relying on it. Note the distinction this note keeps throughout: frequent permitted omissions do not automatically invalidate an in-accordance claim — technical validity and credibility are different questions.
It answers from this page, and reaches into the linked disclosure cards when your question is about the standard itself. Your first two answers are free without signing in.
Try
2 free answersAutomated · the LRA team is one click away
Go deeper · GRI
GRI Standards Certified Training
A full reporting cycle with a mentor: impact inventory, threshold, Topic Standard selection, Content Index and assurance readiness.
Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.
Reviewed by
Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
LRA educational guidance · Not issued or endorsed by GRI
