GRI Maps the Air Pollution Disclosure Gap
Air pollution is widely referenced in corporate reporting, but far less often measured in a way that supports consistent disclosure. GRI’s latest analysis puts that gap into focus and shows where reporting practice remains uneven across sectors and pollutants.
Global Reporting Initiative (GRI) has published new analysis on how large listed companies report air pollutants. The paper links current practice to the ongoing update of the GRI Topic Standard for Air Pollution and to the wider standard-setting process around pollution disclosures.
The central gap is between narrative acknowledgement and quantified disclosure.
What GRI Analysed
The report, The air pollution reporting gap: Evidence from 1,000 organizations across high-emitting sectors, reviews 2023-2024 sustainability and annual reports from 1,000 publicly listed companies across 8 emissions-intensive sectors. These include agriculture, pharmaceuticals, transport, construction, metals processing, construction materials, chemicals and mining.
The study separates a “mention” from a “disclosure”. A mention is a narrative reference to a pollutant without quantitative data. A disclosure is a named pollutant accompanied by an emissions value or similar metric. That distinction is central to the findings. The methodology also excluded GRI content indices, on the basis that they can signal alignment with a framework without demonstrating substantive disclosure in the main body of the report.
Status and Relevance
This publication is research and analysis, not a mandatory reporting requirement or an enforcement action. In the study, GRI 305: Emissions 2016 Disclosure 305-7 (GRI 305-7) serves as an existing reference point for assessing current practice. The paper links its findings to the ongoing update of the GRI Topic Standard for Air Pollution, but it does not describe any new disclosure requirement as adopted or in force.
For sustainability reporting, the findings suggest that the issue is not a lack of reporting as such, but a lack of pollutant-specific quantified disclosure in otherwise mature reporting environments.
What the Findings Show
The main pattern is clear: mentions consistently exceed disclosures. In other words, companies refer to pollutants more often than they report quantified values for them. Nitrogen oxides (NOx) and sulphur oxides (SOx) dominate reporting across the sample, while particulate matter appears less often and other pollutants are much less visible. Hazardous air pollutants (HAPs) and persistent organic pollutants (POPs) remain especially rare, with only a very small share of organisations mentioning or quantifying them.
The context is important. Most firms in the sample published a sustainability or annual report, 57% used GRI, and among GRI users only 43% used GRI 305-7. The issue, then, is not the absence of reporting, but the narrower use of pollutant-specific quantified disclosure.
This gap may reflect an early stage of practice, where a pollutant is recognised as relevant before measurement and reporting processes are consistently in place.
The relationship with GRI is positive but not complete. Firms not using GRI reported an average of 0.46 pollutants, those referencing GRI without formal use reported 1.14, and those using GRI formally reported 1.61. At the same time, GRI 305-7 referencing is not a reliable proxy for disclosure quality on its own.
Sector Differences
The sector picture is also uneven. Agriculture, pharmaceuticals, transport, construction and metals processing generally show lower levels of pollutant-specific reporting, while construction materials, chemicals and mining show relatively higher and more consistent reporting. In transport, for example, around half of organisations mention NOx, but fewer than 30% provide quantified disclosure. In construction materials, the gap between mention and disclosure is the narrowest across the eight sectors.
Chemicals stands out in a different way. It shows the highest use of GRI 305-7 and is one of only two sectors where HAP and POP reporting appears at all. Even so, narrative mention still tends to run ahead of quantified disclosure.
That sector variation matters because the source does not assume that every pollutant is material in every case. It states that the analysis did not evaluate firm-level materiality assessments or the specific reasons for omissions in individual reporting contexts.
Practical Implications for Reporting
The practical issue is not whether air pollution is mentioned, but whether the report contains measurable information that supports verification, comparison or trend analysis. Many disclosures still rely on broad statements about emissions management, while quantified pollutant data are less common. Narrative acknowledgement without quantification may amount to a form of symbolic transparency.
The implications run through governance, data and disclosure design. Where air pollution appears in sustainability strategy or narrative disclosure, organisations need clarity on whether pollutant-level monitoring exists and who owns the underlying reporting process.
The same applies to data, methods and controls. The gap is not simply one of wording, but of whether measurement systems, methodologies, emission factors and data trails are robust enough to support quantified disclosure in the report itself. Where methodologies are cited, they are often named but not explained, leaving limited visibility on calculation approaches in the report body.
Disclosure design also matters. Emissions data often sit in portals, websites or separate filings, while methodological references are frequently external and only briefly cited. That creates information fragmentation and raises a drafting question about whether pollutant data, methodology references and narrative claims are being brought together coherently in the reporting package.
Sequencing is part of the issue. Some firms expand pollutant tracking over time, which means organisations need clarity on what can be supported now, what still depends on maturing systems, and how those changes are explained across reporting cycles.
What to Watch Next
The balanced takeaway is that air pollution reporting is developing, but not yet consistently institutionalised. Companies often signal awareness of pollutant impacts before they produce a stable pattern of quantified disclosure.
The immediate point to watch is GRI’s next standard-setting step. The analysis sits within the ongoing update of the GRI Topic Standard for Air Pollution and the wider standard-setting process, including exposure drafts, public comment periods and stakeholder engagement. Until then, the practical question is whether current disclosures can move from general emissions language to pollutant-specific evidence.
Uncertainty remains. The analysis does not determine whether gaps reflect limited relevance, measurement constraints or differences in reporting maturity in individual cases. The practical focus therefore remains on how pollutant data are measured, explained and integrated into reporting.
