Short answer
The answer, before the reasoning
For an in-accordance report, the organisation must still report Disclosure 3-3 for every material topic, even where no GRI Topic Standard covers that topic. GRI 1 then recommends reporting additional information drawn from relevant Sector Standard recommendations, recognised external sources or disclosures developed by the organisation.
Those supplementary disclosures should be designed with the same rigour as GRI disclosures and aligned with authoritative intergovernmental instruments. The content index should use the real title and source of the disclosure — for example, “Company-specific metric: high-impact automated decisions reviewed” — rather than creating a false GRI number. Where a GRI Topic Standard covers only part of the impact, use the relevant GRI disclosures and add clearly labelled supplementary information for the remaining gap.
A coverage gap does not remove the GRI 3-3 requirement. It changes how the organisation selects supplementary disclosures and labels their source.
In practice
At a glance
| Question | Practical answer |
|---|---|
| What remains mandatory? | For an in-accordance report, Disclosure 3-3 must be reported for every material topic. |
| What replaces a missing Topic Standard? | Relevant additional sector disclosures, recognised external disclosures and/or carefully designed company-specific disclosures. |
| Can the organisation invent a GRI code? | No. Use a descriptive disclosure title and identify the actual source or state that it is company-specific. |
| What if GRI covers only part of the topic? | Use the relevant GRI disclosures for the covered impacts and supplementary disclosures for the residual gap. |
| What is the quality test? | The disclosure should be sufficiently rigorous, transparent and decision-useful to support an informed assessment of the organisation’s impacts. |
The governing GRI rule
GRI separates two questions. First, how does the organisation manage the material topic? Disclosure 3-3 answers this and applies to every material topic. Second, what topic-specific information allows users to understand the impacts? Relevant Topic Standard disclosures normally answer the second question, but a coverage gap does not make the topic disappear.
GRI 1 states that when Topic Standard disclosures do not provide sufficient information, the organisation should report additional disclosures. When the material topic is not covered by GRI Topic Standards at all, GRI 1 requires GRI 3-3 and recommends other disclosures from Sector Standards, other sources or disclosures developed by the organisation itself. GRI also expects those additional disclosures to have the same rigour as GRI disclosures and to align with expectations in authoritative intergovernmental instruments.
Rule
REQUIREMENT / RECOMMENDATION BOUNDARY
Requirement: report GRI 3-3 for each material topic in an in-accordance report. Recommendation: add topic-specific disclosures that make the impacts understandable. LRA implementation practice: document a structured source-selection and metric-design process so supplementary information is traceable and reviewable.
In practice
First diagnose the type of coverage gap
| Coverage situation | What it means | Reporting response |
|---|---|---|
| Full coverage | Relevant GRI disclosures address the significant impacts and information needs. | Report GRI 3-3 and the relevant GRI Topic Standard disclosures. |
| Partial coverage | A Topic Standard covers part of the material topic but not all impacts, affected groups, products or geographies. | Use the relevant GRI disclosures and add supplementary disclosures for the uncovered part. |
| No direct coverage | No current GRI Topic Standard contains suitable topic-specific disclosures. | Report GRI 3-3 and select external and/or company-specific disclosures. |
| Apparent gap caused by a broad label | The organisation’s topic label combines several impacts that are covered by different GRI Standards. | Decompose the topic into underlying impacts and test more than one Topic Standard before concluding there is no coverage. |
| Emerging or fast-changing topic | The impacts are material but recognised metrics and definitions are still developing. | Use qualitative and quantitative information, explain uncertainty and establish an improvement plan. |
A practical decision process
A company-specific metric needs a clear definition, boundary, method, period, owner, control and source label.
In practice
| # | Step | Action — Owner / input — Output / control |
|---|---|---|
| 1 | Define the material impact, not only the topic label | Describe actual and potential, negative and positive impacts, affected stakeholders, activities or business relationships and relevant locations. — Materiality lead + topic owner — Impact statement and scope record. |
| 2 | Test all relevant GRI coverage | Review applicable Sector Standards, Topic Standards and disclosures by underlying impact. A mixed topic may require more than one GRI Standard. — Technical reporting lead — Coverage map showing full, partial or no coverage. |
| 3 | Report GRI 3-3 | Prepare the management disclosure, including impacts, involvement, policies or commitments, actions, effectiveness tracking and stakeholder input. — Topic owner + reporting team — Traceable GRI 3-3 disclosure. |
| 4 | Identify information needs | Ask what users need to understand the scale, scope, trend, distribution, management and outcomes of the impact. — Reporting team + specialists — Disclosure specification. |
| 5 | Select the strongest available source | Prioritise relevant sector recommendations and authoritative intergovernmental or recognised technical sources before designing a new metric. — Technical lead + subject expert — Source-selection rationale. |
| 6 | Design residual company-specific information | Define the metric or narrative disclosure, boundary, method, period, assumptions, limitations, controls and owner. — Data owner + methodology owner — Controlled metric methodology. |
| 7 | Label and index transparently | Use the actual disclosure title and source. Identify company-developed information as company-specific and do not assign a GRI disclosure number. — Content-index owner — Accurate index entry and source reference. |
| 8 | Approve and improve | Obtain technical and governance review, retain the evidence trail and set an update trigger for new GRI or external guidance. — Governance approver + technical reviewer — Approval record and improvement plan. |
In practice
What GRI 3-3 must still explain
| GRI 3-3 element | Application where no Topic Standard exists | Typical evidence |
|---|---|---|
| Impacts | Describe the actual and potential positive and negative impacts represented by the material topic. | Impact inventory, incident data, research and stakeholder evidence. |
| Involvement | Explain whether the organisation is involved through its activities or business relationships and describe them. | Value-chain, product, service and contractual relationship maps. |
| Policies or commitments | State the policy or commitment, or transparently report that it does not exist. | Approved policy, code, commitment and governance minutes. |
| Actions | Explain prevention, mitigation, remediation and management of positive impacts. | Action plans, controls, remedy records and implementation evidence. |
| Tracking effectiveness | Explain the process, goals, indicators, progress and lessons learned. | Metric methodology, dashboards, evaluations and audit or review results. |
| Stakeholder engagement | Explain how stakeholder input informed actions and assessment of effectiveness. | Engagement records, grievance information, expert input and response logs. |
How to select recognised external sources
Source selection should follow the impact and information need. An external framework is not automatically suitable merely because its title resembles the material topic. Check its purpose, definitions, boundary, intended users, calculation rules and evidence expectations.
In practice
| Selection test | Reviewer question | Red flag |
|---|---|---|
| Authority | Is the source an intergovernmental instrument, recognised standard-setter publication, regulator requirement or robust technical methodology? | An unsourced blog or vendor score is the sole basis. |
| Impact fit | Does the disclosure describe the actual impact, affected group and boundary identified by the organisation? | A financial-risk metric substitutes for impact information. |
| Definition fit | Are terms, units and classifications compatible with the organisation’s impact statement? | A familiar label hides a different definition. |
| Methodological transparency | Can another competent reviewer reproduce or challenge the calculation? | The method depends on a proprietary black box with no explanation. |
| Completeness and balance | Does the source support negative outcomes, limitations and distributional effects as well as activities or commitments? | Only positive activity counts are reported. |
| Stability and maintenance | Is the source current, version-controlled and likely to be maintained? | The organisation cannot identify the edition used. |
Caution
DO NOT CREATE FALSE EQUIVALENCE
Using an external disclosure inside a GRI report does not turn it into a GRI disclosure, and similarity of subject matter does not prove equivalence. State the source and explain any adaptation.
Rules for company-specific metrics
A company-specific disclosure is useful when it fills an identified information gap. It should not be an easy metric chosen because the data already exist. Start from the impact and design the smallest set of information that enables an informed assessment.
Give the disclosure a descriptive title linked to the impact, not a pseudo-GRI number.
Define the numerator, denominator, unit, classification rules and treatment of zero or unknown values.
State the organisational, operational, value-chain, product, geographic and stakeholder boundary.
Identify the reporting period, baseline, comparative information and restatement policy.
Describe data sources, estimates, assumptions, exclusions and known limitations.
Assign a data owner, methodology owner, review control and evidence-retention rule.
Explain why the metric is decision-useful and how it connects to actions and effectiveness.
Set an improvement plan where the first-year metric is incomplete or relies on proxies.
In practice
How to label the disclosure in the content index
| Poor label | Why it is misleading | Transparent alternative |
|---|---|---|
| GRI 999-1 Responsible AI | It implies that GRI issued a disclosure that does not exist. | Company-specific disclosure: high-impact automated decisions reviewed. |
| GRI-aligned AI incidents | “Aligned” is undefined and hides the methodology and source. | AI incidents resulting in substantiated adverse impact — company methodology v1.1. |
| OECD AI metric | The source may provide principles rather than the exact metric used. | Company-specific metric informed by the OECD AI Principles; methodology described on page X. |
| See sustainability section | The location and disclosure identity are not precise. | Responsible use of automated decision systems, pages X–Y; source: company-specific disclosure. |
Illustrative case: responsible use of artificial intelligence
A financial-services group determines that adverse impacts from high-impact automated decisions are material. The impacts include unfair denial of services, discriminatory outcomes and insufficient routes for human review. No current GRI Topic Standard provides a complete set of topic-specific disclosures for this material topic. The group therefore reports GRI 3-3, reviews the OECD AI Principles and UNESCO Recommendation on the Ethics of Artificial Intelligence for relevant concepts, and develops a controlled set of company-specific metrics.
Illustrative supplementary disclosure
Illustrative wording — adapt to the organisation’s facts, reporting boundary and applicable requirements.
The wording below demonstrates structure only. It is not an official GRI disclosure or a universally suitable responsible-AI metric set.
The impact and affected groups are named before the metric.
GRI 3-3 and supplementary information are clearly separated.
External sources inform the methodology but are not presented as issuing the company metric.
Boundary, exclusions, data gap and remediation date are visible.
The wording expressly avoids creating a false GRI code.
In practice
| Information need | Illustrative disclosure | Methodological control |
|---|---|---|
| Exposure | Number and proportion of high-impact automated decision systems in active use. | Defined inventory, risk classification and system owner. |
| Assessment coverage | Proportion subject to documented impact assessment before deployment or material change. | Assessment criteria, approved exceptions and version control. |
| Affected people | Applications, customers or workers affected, disaggregated where lawful and meaningful. | Privacy controls, aggregation and explicit boundary. |
| Adverse outcomes | Substantiated incidents and complaints by type, severity and affected group. | Case definition, investigation status and non-duplication rule. |
| Remedy and review | Cases resulting in human review, correction, compensation or other remedy. | Traceable case outcomes and remedy classification. |
| Effectiveness | Trend in repeat incidents and independent test findings after corrective action. | Comparable period and explanation of methodology changes. |
Rule
ADAPTATION WARNING
Do not copy the figures, boundary or source selection. A real organisation must test its own impacts, jurisdictions, privacy constraints and applicable legal requirements.
In practice
Weak and stronger reporting
| Weak approach | Why it fails | Stronger approach |
|---|---|---|
| “There is no GRI Standard, so the topic is not reported.” | The materiality conclusion and GRI 3-3 requirement are ignored. | Report GRI 3-3 and design supplementary information for the uncovered impact. |
| A new “GRI” code is assigned internally. | The index falsely attributes the disclosure to GRI. | Use a descriptive company-specific title and the actual source field. |
| Only a policy statement is provided. | Users cannot assess exposure, outcomes or effectiveness. | Combine management information with impact-relevant metrics and limitations. |
| An external framework is copied wholesale. | The organisation has not tested purpose, boundary or relevance. | Select only relevant disclosures and document adaptation. |
| A first-year estimate is presented as complete. | The boundary and uncertainty are hidden. | Label estimates, explain assumptions and publish an improvement plan. |
In practice
Common mistakes
| Common mistake | Why it creates risk | Correction |
|---|---|---|
| Treating the absence of a Topic Standard as evidence that the topic is not material. | A significant impact is omitted from the report. | Keep the materiality decision separate from the availability of standardised disclosures. |
| Using the broad topic label to conclude that GRI has no coverage. | Relevant disclosures in several Topic Standards are missed. | Decompose the topic into underlying impacts and affected groups. |
| Inventing a GRI disclosure number or calling a company metric “GRI compliant”. | The content index creates a false standard-setting claim. | Use the real disclosure title and identify the source or company methodology. |
| Choosing metrics solely because data are easy to collect. | Activity data substitute for information about the material impact. | Start from user information needs and the impact pathway. |
| Using an external source without recording its edition or adaptations. | The disclosure cannot be reproduced or maintained. | Keep a source register, mapping note and methodology version. |
| Hiding exclusions in a technical appendix. | Headline metrics imply wider coverage than the evidence supports. | State material boundary and limitation information near the disclosure. |
In practice
Myth versus reality
| Layer | Statement |
|---|---|
| MYTH | If GRI has not issued a Topic Standard, the company can either leave the material topic out or create its own GRI indicator. |
| REALITY | Neither is correct. A material topic remains reportable. For an in-accordance report, GRI 3-3 still applies, and supplementary disclosures can come from other sources or be developed by the organisation. They must be transparently labelled and must not be presented as GRI disclosures. |
| PRACTICAL CONSEQUENCE | The reporting team needs a controlled coverage-gap and metric-design process, not a workaround in the content index. |
Readiness
Coverage-gap and metric-design checklist
- The material topic is defined by its impacts, affected stakeholders, activities and business relationships.
- All relevant Sector and Topic Standards have been checked at disclosure level.
- Full, partial or no GRI coverage is documented.
- GRI 3-3 is complete for the material topic or a permitted reason for omission is properly disclosed.
- The organisation has identified the information users need to assess the impact.
- External sources have been assessed for authority, impact fit, definitions, boundary and methodology.
- Company-specific metrics have clear definitions, boundaries, periods, methods, assumptions and limitations.
- Data and methodology owners, review controls and evidence-retention requirements are assigned.
- The content index uses the actual source title and does not fabricate a GRI code.
- Illustrative or voluntary supplementary information is clearly labelled and does not obscure required information.
- The disclosure explains material data gaps and the timetable for improvement.
- A technical reviewer and governance approver have signed off the current version.
- New GRI Topic Standards or official guidance are recorded as update triggers.
Sources
Primary sources
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