Short answer
The answer, before the reasoning
Estimates are acceptable in GRI reporting when they are the best usable information available, are sufficiently accurate for the disclosure's purpose, and do not create false precision or conceal a material gap. The organisation should identify estimated data, explain the method, assumptions and limitations, retain evidence and review controls, and restate comparatives where a changed method materially affects previously reported information.
A reason for omission is appropriate only when the required information is genuinely unavailable or incomplete and no defensible estimate can meet the information need.
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Why this question matters
Few first-year sustainability reports are built entirely from measured, system-generated data. Scope 3 emissions may rely on spend or supplier proxies; workforce totals may require estimates where local systems do not align; supply-chain coverage may be extrapolated from samples; and biodiversity assessments often use secondary or modelled datasets before site-specific ecological surveys are complete. Treating all such information as prohibited would make many disclosures impossible. Treating every approximate number as acceptable would make the report unreliable.
The real reporting decision is therefore not 'estimate or no estimate'. It is whether the proposed estimate is fit for the decision and disclosure, whether the remaining uncertainty could change the reader's conclusion, and whether the organisation can explain and reproduce the method. A transparent estimate is a controlled reporting method. An unexplained number is only a data gap disguised as precision.
Quick orientation
- Applies to
- Any GRI disclosure that contains estimated, proxy, extrapolated or modelled qualitative or quantitative information.
- Primary decision
- Whether to use a defensible estimate, improve the method before publication, or apply an allowed reason for omission.
- Key sources
- GRI 1 reporting principles and reasons for omission; GRI 2 restatements and explicit estimate permissions; relevant Topic Standard guidance.
- Common confusion
- GRI does not require every number to be directly measured, but transparency about an estimate does not automatically make a weak estimate acceptable.
1. What the GRI Standards say about estimates
GRI 1 does not establish a universal numerical error threshold or a single hierarchy of acceptable estimates. Instead, it sets reporting principles that control the judgement. Under the Accuracy principle, the organisation reports information that is correct and sufficiently detailed for an assessment of its impacts. The accompanying guidance asks the organisation to identify estimated data and explain the underlying assumptions, techniques and limitations. Under Verifiability, the organisation should retain original sources, evidence supporting assumptions and calculations, internal controls, and clear explanations of uncertainty.
Comparability adds a time dimension. Methods and assumptions should be applied consistently. Where a new method, definition, acquisition, disposal or correction materially changes earlier information, GRI 2-4 requires the organisation to report the restatement, explain why it was made and describe the effect. Completeness prevents an estimate from being used to hide an omitted entity, location or impact that is necessary to understand the organisation's performance.
In practice
| Source-grounded principle or disclosure | Practical consequence for an estimate |
|---|---|
| GRI 1 - Accuracy | Identify which information is estimated; explain assumptions, techniques and limitations; ensure the margin of error does not inappropriately affect the user's assessment. |
| GRI 1 - Comparability | Maintain consistent methods and assumptions, or explain changes and present restated historical information when required. |
| GRI 1 - Completeness | Do not use aggregation, a proxy or a coverage threshold to omit information necessary to understand significant impacts. |
| GRI 1 - Verifiability | Retain source records, calculation logic, evidence supporting assumptions, review controls and an explanation of uncertainty. |
| GRI 1 - Requirement 6 | Use 'information unavailable / incomplete' only when a permitted reason for omission applies; specify what is missing, why and the remediation route. |
| GRI 2-4 - Restatements | Explain material changes caused by methods, definitions, errors, mergers, acquisitions or disposals, including the quantitative effect where relevant. |
| GRI 2-7 and 2-8 guidance | Where exact employee or non-employee worker figures cannot be reported, rounded estimates may be used and the methodology explained. |
In practice
2. Distinguish the main forms of estimated information
| Term | Working definition | Typical use — Main risk |
|---|---|---|
| Estimate | A value calculated from incomplete information using a stated method and assumptions. | A missing month's utility value derived from an established consumption pattern. — False precision or an assumption that is no longer representative. |
| Proxy | A substitute variable used because the direct variable is unavailable. | Spend used as a proxy for purchased-goods activity; floor area used for leased-site energy. — The proxy may correlate poorly with the impact being reported. |
| Extrapolation | Extension of observed data from a sample or partial period to a wider population or period. | Survey results extrapolated from responding suppliers to a defined supplier population. — Sample bias, incomplete population definition or unstable seasonality. |
| Modelled data | Information generated through a model combining datasets, parameters and assumptions. | Biodiversity pressure or ecosystem-condition screening based on geospatial models. — Model resolution or average conditions may not represent a specific site. |
| Secondary data | Information created by a third party rather than measured directly by the reporting organisation. | Government factors, lifecycle databases, industry datasets or supplier-specific reports. — Unknown methodology, outdated vintage or a boundary mismatch. |
| Measured data | Information directly observed through meters, counts, surveys or validated source systems. | Metered electricity, payroll headcount or monitored hectares restored. — Measurement is not automatically complete, correctly classified or within the reporting boundary. |
3. Decision criteria: usable estimate or unavailable information?
An estimate should be accepted because it can support the intended information need, not simply because it produces a number. The reporting team should first define the exact requirement, population, boundary, period and decision. It can then test the estimate against the criteria below. A weak result does not always mean omission: the method may be improved, the disclosure may be disaggregated, or a range may be more honest than a point estimate.
Figure 1. Decision logic for measured data, a usable estimate or a permitted reason for omission. This is an LRA implementation aid; the relevant disclosure requirement and GRI omission permissions must still be checked.
In practice
| Decision criterion | Questions to record | Red flag |
|---|---|---|
| Relevance | Does the method measure or reasonably approximate the information required by the disclosure? | The method answers a different question, such as spend instead of physical volume, without explaining the consequence. |
| Coverage | Which entities, sites, workers, suppliers, products, locations or time periods are represented? | A material population is absent and the missing share is not quantified or described. |
| Representativeness | Is the sample, factor, geography, technology, period or ecosystem representative of the population? | A national average is applied to a distinctive site or high-impact activity without a sensitivity test. |
| Replicability | Could another competent reviewer reproduce the number from the retained method and source data? | The result depends on undocumented spreadsheet adjustments or personal judgement. |
| Uncertainty | What range, known bias or sensitivity surrounds the result, and could it change the conclusion? | A single precise number is reported although plausible assumptions produce materially different outcomes. |
| Control | Who prepared, reviewed, reconciled and approved the estimate? | The estimate has no named owner, review evidence or reconciliation to a source population. |
| Timeliness | Is the information current enough for the reporting period, and how were data lags treated? | Old data are carried forward despite structural change, price volatility, workforce change or site closure. |
| Improvement route | Is there a proportionate plan to improve important estimates over time? | The same weak method is reused each year without a decision or milestone. |
When an estimate should not be used
The method is unrelated to the disclosure or impact and would mislead readers about what has been measured.
The uncovered population could contain significant impacts, but its size or characteristics are unknown.
Reasonable alternative assumptions produce results that would change a material conclusion and the uncertainty cannot be communicated meaningfully.
The calculation cannot be reconstructed because source data, factors, transformations or approvals have not been retained.
A legal, contractual or scientific judgement is being replaced by a generic numerical proxy outside the reporting team's competence.
The estimate is used to support a claim of achievement, reduction or effectiveness that the evidence cannot demonstrate.
4. Build an assurance-ready estimate record
A reported estimate should be managed as a controlled data point, not as a footnote added at the end of drafting. The record should allow a reviewer to trace the published value to its source population, method, assumptions, uncertainty, controls and future improvement. The same record also supports consistent treatment in the next reporting cycle.
Figure 2. Evidence stack behind a reported estimate. Each layer should be visible in the internal record even when only the material methodology and limitation are published.
In practice
| Estimate record field | What to capture |
|---|---|
| Disclosure requirement | Exact disclosure and sub-requirement, information need, unit and expected level of disaggregation. |
| Population and boundary | Entities, sites, people, suppliers, products, locations and period included; explicit exclusions and coverage percentage where meaningful. |
| Source data | System, file, survey, factor database or model version; extraction date; geography; technology; vintage and owner. |
| Method | Formula, allocation, proxy, extrapolation or model; conversion factors; thresholds; treatment of missing and abnormal observations. |
| Assumptions | Why the assumptions are reasonable; representativeness; material simplifications; alternative assumptions considered. |
| Uncertainty | Known bias, range, sensitivity, limitations and the possible effect on the published conclusion. |
| Controls | Preparer and reviewer; recalculation; reconciliation to source population; exception checks; approval date and evidence link. |
| Publication treatment | Where the estimate is identified; methodology and limitations disclosed; any reason for omission; Content Index reference. |
| Improvement and restatement | Owner, milestone, target data-quality level, next-year action and trigger for restating historical information. |
5. How to disclose the methodology and limitations
The public explanation should be proportionate to the estimate's significance and uncertainty. A routine low-risk estimate may need one clear methodology sentence. A major Scope 3, workforce, supply-chain or biodiversity estimate may require the population, coverage, factor or model source, assumptions, known limitations, sensitivity and improvement plan. The aim is not to publish every spreadsheet detail. It is to give information users enough context to understand what the value represents and what it does not represent.
In practice
| Disclosure element | Useful wording content | Weak shortcut to avoid |
|---|---|---|
| Identification | State that the data are estimated, extrapolated, proxy-based or modelled and identify the affected metric or population. | 'Data may include estimates' with no indication of which figures are affected. |
| Method | Explain the formula, sample, proxy or model and why it is appropriate for the purpose. | 'Calculated using industry methodology' with no identifiable method. |
| Boundary and coverage | State the population and period covered and, where helpful, the estimated share of the reported total. | Reporting a group total without explaining missing subsidiaries, suppliers or sites. |
| Sources and assumptions | Identify material factors, datasets, allocation rules and assumptions. | Listing a database name without its version, geography or application. |
| Uncertainty and limitation | Describe known bias, resolution, sensitivity or missing information and how it affects interpretation. | Generic language that all estimates are uncertain. |
| Controls | Where material, describe review, reconciliation or external verification status without overstating assurance. | Calling the estimate 'verified' because a manager approved the spreadsheet. |
| Improvement | Give the action, owner or time horizon for materially improving the estimate. | A vague promise to improve data quality in future. |
| Change and restatement | Explain method changes and their effect on trend or comparatives. | Presenting a changed series as an operational improvement. |
6. Controls, uncertainty and sensitivity
Uncertainty should be managed in proportion to decision sensitivity. Not every estimate needs a formal confidence interval. However, the reporting team should understand how the result moves when the most judgemental inputs change. Sensitivity analysis can reveal that a seemingly minor assumption drives the result, that a ranking of impacts is unstable, or that a published reduction is within the range of methodological uncertainty.
In practice
| Control | Purpose | Evidence retained |
|---|---|---|
| Population reconciliation | Confirms that the estimate covers the intended universe and that included and excluded items are understood. | Entity, supplier, worker, site or product census; reconciliation result; exception list. |
| Independent recalculation | Tests the formula and factor application without relying on the preparer's spreadsheet logic. | Reviewer calculation or automated control output. |
| Factor and model approval | Confirms the source is current, relevant and applied to the correct geography, technology and period. | Factor register, model version, technical-owner approval. |
| Sensitivity test | Shows whether alternative reasonable assumptions would change the disclosure or decision. | Scenario table, range or documented qualitative judgement. |
| Year-on-year bridge | Separates real performance change from coverage, factor, model or classification change. | Bridge analysis and restatement assessment. |
| Management challenge | Tests whether the estimate is consistent with operational knowledge and other records. | Review notes, variance explanations and sign-off. |
7. Restatements and the improvement plan
Improving an estimate is not merely a data-project objective. It can change comparability. Before replacing a proxy or model, the team should assess whether historical information can and should be recalculated on the new basis. If a change materially alters earlier reported information, the report should explain the reason, the effect and the treatment of comparatives under GRI 2-4. A lower emissions or incident figure after a methodology change must not be presented as operational improvement unless the evidence supports that conclusion.
Define the target state: measured, supplier-specific, site-specific, more representative secondary data, or a better model.
Prioritise estimates that are large, decision-sensitive, linked to targets or public claims, or likely to enter assurance scope.
Assign an owner, milestone and data-quality criterion rather than a generic promise to 'improve data'.
Test the new method in parallel with the old method where possible and quantify the effect.
Apply a documented restatement criterion and obtain approval before changing the published trend.
Update the methodology note, source register, calculation file, Content Index reference and AI-ready record together.
In practice
8. Applied examples across GRI reporting
| Area | Illustrative situation | Potential estimate — What should be disclosed or controlled — When it becomes un |
|---|---|---|
| GHG emissions | Primary activity data are unavailable for many purchased-goods suppliers. | Spend-based or average-data estimate, followed by physical or supplier-specific data for priority categories. — Category, population, spend coverage, factor source and vintage, allocation, estimated share, limitations and improvement plan. — The factor is unrelated to the purchased product mix, major suppliers are missing, or method change is presented as a reduction. |
| Workforce | Local systems cannot produce exact employee or non-employee worker counts at year end. | Rounded estimate to the nearest ten, or nearest hundred for populations over 1,000, where the relevant GRI 2 guidance is applied. — Methodology, basis of count, period, material fluctuations and affected categories. — The estimate combines incompatible definitions, excludes significant labour populations or cannot be reconciled to HR/payroll records. |
| Supply chain | The organisation does not have a complete supplier count or tier map. | Estimated supplier population or payment value based on procurement systems and defined inclusion rules. — Population definition, tiers, inactive/duplicate supplier treatment, currency basis, system limitations and reconciliation to finance. — The count mixes legal entities, sites and contracts or hides a major geography/system outside the estimate. |
| Biodiversity | Primary ecological condition data are not available for every site or sourced commodity. | Secondary or modelled geospatial data used for initial screening and prioritisation. — Dataset and version, spatial resolution, assumptions, limitations, primary/secondary/modelled classification and plan to improve accuracy. — The global model is used to assert a site-specific ecological outcome or to avoid investigating a high-risk location. |
| Incidents or grievances | A newly acquired subsidiary has only partial historical records. | A clearly bounded partial-year or sampled figure may support context, but not an invented full-year count. — Acquisition date, covered systems, missing period, comparability effect and remediation plan. — Extrapolation would conceal a known cluster of incidents or create an unsupported performance claim. |
9. Hypothetical example: first-year group estimate
The reporting team first defines the three separate populations rather than applying one blanket 'estimated data' label. For purchased-goods emissions, it uses spend-based factors for the acquisitions and supplier-specific physical data for strategic suppliers. For non-employee workers, it applies the estimate permission and rounding guidance in GRI 2-8, supported by contractor rosters and invoice records. For biodiversity screening, it uses a named geospatial dataset to locate potential high-risk sourcing areas and explicitly avoids describing the model as a site assessment.
The team calculates the estimated share of each total, performs sensitivity analysis on the largest Scope 3 factor, reconciles worker estimates to contractor spend and access records, and records the model resolution for biodiversity. It discloses the limitations next to the affected metrics and assigns separate improvement milestones: supplier activity data within twelve months, a harmonised contractor register by the next year end, and field assessment for two high-risk sourcing regions. The estimate records make clear that the three methods answer different information needs and carry different uncertainty.
10. Illustrative disclosure wording
Why this works: it identifies the affected figure, population, method, reason, factor basis, uncertainty, control, improvement action and comparative treatment. It does not imply that the estimate is exact, externally assured or evidence of emissions reduction.
In practice
Weak versus stronger disclosure
| Weak wording | Stronger wording | Why the stronger version is more useful |
|---|---|---|
| Some data were estimated where actual data were unavailable. | State the affected metric and population, the estimate's share, method, factor/model source, assumptions and limitation. | The reader can locate the uncertainty and understand its scale. |
| Industry averages were used. | Name the dataset/version, geography, technology or category mapping, and explain why it represents the population. | The method becomes reviewable rather than generic. |
| Data quality will improve next year. | Identify the owner, action, milestone and the priority population to be replaced or refined. | The improvement plan becomes testable and repeatable. |
| The reduction reflects better data and performance. | Separate the operational movement from the effect of changed factors, coverage or methodology and assess restatement. | The disclosure avoids an unsupported causal claim. |
In practice
11. Common mistakes
| MISTAKE 1 | Treating disclosure of the limitation as permission to use any estimate. |
|---|---|
| Why it happens | Teams assume transparency cures a method that is unrelated, incomplete or highly biased. |
| Why it matters | The report remains inaccurate or misleading even though the methodology note is long. |
| Correction | Apply relevance, coverage, representativeness, sensitivity and control criteria before deciding to publish the estimate. |
| Evidence of correction | Approved estimate assessment with documented acceptance, remediation or omission conclusion. |
In practice
| MISTAKE 2 | Using a precise point estimate where the uncertainty changes the conclusion. |
|---|---|
| Why it happens | A single number is easier to aggregate and design into a report than a range or caveat. |
| Why it matters | Readers infer a level of measurement accuracy that the evidence does not support. |
| Correction | Disclose a range, sensitivity or qualitative limitation and avoid unsupported ranking or target claims. |
| Evidence of correction | Sensitivity table and approved disclosure treatment linked to the affected metric. |
In practice
| MISTAKE 3 | Changing the method without assessing restatement. |
|---|---|
| Why it happens | The new number is viewed as better data rather than a break in the trend. |
| Why it matters | A methodological movement is mistaken for improved or deteriorated performance. |
| Correction | Prepare a year-on-year bridge, apply the restatement criteria and explain the quantitative effect. |
| Evidence of correction | Restatement assessment and GRI 2-4 approval record. |
In practice
| MISTAKE 4 | Applying one generic 'estimated data' note to unrelated disclosures. |
|---|---|
| Why it happens | The reporting team centralises methodology wording late in drafting. |
| Why it matters | Users cannot tell which data are estimated, how much is affected or which limitations matter. |
| Correction | Maintain metric-level estimate records and place material limitations next to the affected disclosure or a precise linked note. |
| Evidence of correction | Source register entries and tested cross-references for each estimate. |
In practice
12. Myth versus reality
| MYTH | A GRI report can contain estimates only when the relevant Topic Standard explici |
|---|---|
| REALITY | GRI 1 expressly anticipates estimated information through the Accuracy and Verifiability principles. Topic-specific guidance may provide additional permission or detail, but every estimate still needs to be fit for purpose, transparent and supported by evidence. |
| Why the confusion arises | Reporting teams often confuse the absence of a calculation template with a prohibition on professional judgement. |
| Practical consequence | The organisation should design a controlled estimate where it improves completeness, but use an omission explanation when no defensible estimate can meet the requirement. |
In practice
15. Related standards and indicator mapping
| Framework / disclosure | Relationship | Use in this article |
|---|---|---|
| GRI 1: Foundation 2021 - Accuracy | Direct | Core basis for identifying estimated data and explaining assumptions, techniques and limitations. |
| GRI 1: Foundation 2021 - Comparability | Direct | Consistency, contextual explanation and historical restatement when methods or definitions change. |
| GRI 1: Foundation 2021 - Completeness and Verifiability | Direct | Coverage, evidence, controls, original sources and uncertainty. |
| GRI 1: Foundation 2021 - Requirement 6 | Direct | Reason for omission when required information is genuinely unavailable or incomplete. |
| GRI 2: General Disclosures 2021 - 2-4 | Direct | Reasons and effects of restatements, including methodological and structural changes. |
| GRI 2: General Disclosures 2021 - 2-7 and 2-8 | Example | Explicit workforce estimate and rounding guidance where exact figures cannot be reported. |
| GRI 101: Biodiversity 2024 - Disclosure 101-4 guidance | Example | Identification of primary, secondary and modelled data, datasets, limitations and plans to improve accuracy. |
| GRI 102 / GRI 103 calculation disclosures | Implementation | Method, assumption, factor and model transparency for climate and energy metrics. |
Modelled biodiversity data can be used when it is fit for the reporting purpose and is identified transparently rather than presented as measured site fact. Explain the model, source, resolution, assumptions, coverage and limitations, retain reproducible evidence and review controls, and improve or withhold conclusions where uncertainty could materially change the reader’s understanding.
Questions
Questions people ask
Does GRI allow estimates?
Estimates are acceptable in GRI reporting when they are the best usable information available, are sufficiently accurate for the disclosure's purpose, and do not create false precision or conceal a material gap. The organisation should identify estimated data, explain the method, assumptions and limitations, retain evidence and review controls, and restate comparatives where a changed method materially affects previously reported information. A reason for omission is appropriate only when the required information is genuinely unavailable or incomplete and no defensible estimate can meet the information need.
When should information be treated as unavailable instead?
The organisation should identify estimated data, explain the method, assumptions and limitations, retain evidence and review controls, and restate comparatives where a changed method materially affects previously reported information. A reason for omission is appropriate only when the required information is genuinely unavailable or incomplete and no defensible estimate can meet the information need.
Must an organisation publish a confidence interval?
Not every estimate needs a formal confidence interval. However, the reporting team should understand how the result moves when the most judgemental inputs change. Sensitivity analysis can reveal that a seemingly minor assumption drives the result, that a ranking of impacts is unstable, or that a published reduction is within the range of methodological uncertainty.
Do better data always mean historical figures must be restated?
Improving an estimate is not merely a data-project objective. It can change comparability. Before replacing a proxy or model, the team should assess whether historical information can and should be recalculated on the new basis.
Can modelled biodiversity data be used?
Modelled biodiversity data can be used when it is fit for the reporting purpose and is identified transparently rather than presented as measured site fact. Explain the model, source, resolution, assumptions, coverage and limitations, retain reproducible evidence and review controls, and improve or withhold conclusions where uncertainty could materially change the reader’s understanding.
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