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GRI 103: Energy · 2025
Disclosure GRI 103-1

Energy policies and commitments

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain the energy policies and commitments that guide how it manages energy use. In practice, that means setting out the main principles, targets, or commitments it has adopted, and showing how these shape decisions about energy consumption, efficiency, and any related actions across the business.

The practical focus is on whether these policies apply broadly and consistently, not just at a few showcase locations. A useful explanation would make clear if the approach covers all operations, selected sites, or particular activities, and how the organisation ensures the commitments are put into practice rather than remaining high-level statements.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Energy policy contribution Capture the quantified amount showing how the organisation’s energy policies and commitments support lower energy use and related energy outcomes, using the same basis as the reported figure. Approved energy policy, commitment tracker, and the calculation file or KPI pack used to derive the number. Sustainability / Energy management
Impact count Capture the number of identified impacts linked to the organisation’s activities across financial, environmental and people-related effects, using one consistent counting rule and scope. Impact assessment register, materiality or risk review, and the summary sheet showing how the count was compiled. Sustainability / Risk
+ Show GRI 103-1 sub-elements (LRA working checklist)

How to prepare it

1Set the boundary for the topic you are reporting on, so it is clear which activities, sites, products, services or decisions are in scope and which are not.
2Decide what will count as relevant evidence for that boundary, using the source material that shows the topic’s effects or the organisation’s related policies and commitments.
3Gather the underlying records, calculations, notes or other support that show the topic’s links to reduced energy use, where that is the subject, or to wider effects on the economy, environment and people, where that is the subject.
4Turn the evidence into the disclosure content, either as figures or as a clear narrative, depending on what best fits the information available.
5Record any exclusions, assumptions, scope changes or methodological choices so a reviewer can see how the final disclosure was built.
6Check the draft against the official source material to confirm the scope, content and evidence trail still match the requirement before sign-off.
Request the data

Request the energy policy and commitment evidence from Operations

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What internal policy, commitment, or approved statement shows how our energy approach is intended to cut energy use and address wider effects on the business, environment, and people?

Use your organisation’s own wording first, then map it to the disclosure. Ask for the policy, commitment, or equivalent internal statement in the terms the business actually uses, rather than using framework language in the request.

Weak request

Please provide the GRI 103-1 evidence showing our energy-related policies and commitments and how they address energy consumption reduction and impacts on the economy, environment, and people.

Why it fails: This uses framework wording that many operational teams will not recognise, so it is easy to answer with the wrong document or an incomplete extract. It also does not ask for the internal name, owner, version, scope, or storage location, which are needed to verify the evidence.

Better request

Please send the current energy policy, commitment statement, or equivalent internal document for [business area], plus the owner, version, approval date, scope, storage location, and a short note on how it supports lower energy use and wider business, environmental, and people impacts. If your team uses a different name for this document, use that name and tell us how it maps to the reporting request.

Formal email template
Subject: Request for energy policy / commitment evidence for [reporting period]

Hi [name/team],

I’m pulling together the evidence pack for our sustainability reporting and need your help with the current energy policy, commitment statement, or equivalent internal document for [business area / boundary].

Please send:
- the latest version of the document or link
- approval date and version number
- the owner / approver
- the period and scope it covers
- any supporting note showing how it is used in practice
- any internal wording that explains how it supports lower energy use and addresses wider business, environmental, and people impacts

If the business uses a different term for this document, please use that term and tell me how it maps to the reporting request.

Please share by [date]. This is a draft training request; please adapt it to your organisation and check the official source before sign-off.

Thanks,
[Your name]
Short Teams / Slack version
Hi [name/team] — could you share the latest energy policy / commitment doc for [site/business area], plus version, approval date, owner, scope, and any note on how it supports lower energy use and wider impacts? Please use your internal document name if different. Needed by [date].
Industry examples
Manufacturing

Context. A plant team manages energy through site standards, maintenance routines, and production controls.

Adapted request. Please share the site energy standard or equivalent document for [plant/site], plus version, approval date, owner, scope, and a short note on how it supports lower energy use and wider impacts from production activity. If the team uses a different internal name, please use that name.

Example response. Internal document: Site Energy Standard v4.1; Approved: 12 Feb 2025; Owner: Plant Operations Manager; Scope: [Plant A] and [Plant B]; Source: Controlled documents library; Energy-use link: sets shutdown rules, compressed air checks, and equipment start-up controls; Wider impacts link: notes cost control, emissions reduction, and safer working conditions during maintenance.

Property / Facilities

Context. A facilities team manages offices, landlord interfaces, and building services.

Adapted request. Please send the current building energy policy or facilities commitment for [office portfolio], plus the owner, version, approval date, scope, storage location, and a short note on how it supports lower energy use and wider impacts across the estate. Use your internal document name if it differs.

Example response. Internal document: Facilities Energy Commitment v2.0; Approved: 03 Apr 2025; Owner: Head of Facilities; Scope: UK office portfolio; Source: Intranet policy page; Energy-use link: covers lighting schedules, HVAC setpoints, and tenant engagement; Wider impacts link: references operating cost, occupant comfort, and local environmental effects.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Define which energy-related policies and commitments are included, explain how you decided whether an item was relevant, and state the basis used to link each one to energy-use reduction and wider effects.

Context note

Set out what the figures show about how the organisation’s energy-related actions connect to lower energy use and to broader effects on the business, the environment and people.

Fluctuation statement

If the numbers change materially, explain whether this is due to new or revised policies, changes in coverage, operational shifts, or a different way of assessing the linked effects.

Content index entry
GRI 103-1 Energy policies and commitments — [location / page] / [notes]
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Preparation tools & forms

Professional preparation tools for GRI 103-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
Go deeper · GRI 103-1
Learn to prepare this disclosure end-to-end

This guide covers one disclosure. The GRI Standards Certified Training — taken as a bundle with an ESRS course — walks the full workflow: datapoints, evidence, drafting and assurance, with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We say the coverage figure was built from the full set of operations we chose to include, and that the inclusion and exclusion decisions were applied consistently across the reporting period.An assurer may test whether the boundary was set on a consistent basis, whether any sites or activities were left out without a clear reason, and whether the same approach was used throughout the period.Boundary memo or reporting methodology; list of included and excluded entities, sites, activities or programmes; management sign-off on scope decisions; prior-period comparison showing the same basis or documented changes.
We state that the disclosed figure reflects the relevant data we collected for the period, and that the underlying records were checked before publication for completeness and obvious errors.An assurer may probe whether the source data were complete, whether estimates or substitutions were used, whether calculations were accurate, and whether pre-publication checks were strong enough to support the published number.Source data extracts; calculation workbook or system output; data quality checks; reconciliation to primary records; exception logs; evidence of review and approval before release.
We explain that the figure is supported by evidence we retained, so the basis for the reported result can be traced back to the underlying records and working papers.An assurer may ask whether the audit trail is sufficient to trace the published figure back to source documents, whether evidence is contemporaneous, and whether the retained files support the judgement calls made in compiling the disclosure.Working papers; source documents; emails or approvals supporting judgement calls; version history; document retention index; traceability from final figure to source records.
We confirm that the disclosed activities were assessed for their likely effects on the business, the environment and local communities, and that the scope of the statement was set using that assessment.An assurer may challenge whether the impact assessment was complete, whether material effects were overlooked, whether the scope followed the stated assessment logic, and whether the conclusion is supported by evidence.Impact assessment or materiality analysis; criteria used to judge effects; workshop notes or stakeholder inputs; management review papers; mapping from assessed impacts to the final disclosure scope.
We say the final disclosure was reviewed before issue, including a check that the narrative matched the underlying records and that any assumptions or exclusions were clearly documented.An assurer may test whether the final text is consistent with the evidence pack, whether assumptions were properly explained, whether exclusions were transparent, and whether the review was sufficiently independent.Final draft and tracked changes; review checklist; approval records; documented assumptions and exclusions; cross-check between narrative, tables and source evidence; sign-off from responsible reviewers.

Evidence pack to prepare

Common reporting gaps

Units are missing or inconsistent across the figures.The reporting scope or boundary for the numbers is unclear.Estimates are not distinguished from measured values.Parts of the total are double-counted or omitted.Restatements of prior-period figures are not disclosed.The calculation method or data source is not documented.
Common gaps

Mistakes to avoid when collecting the data

Wrong owner
The team asks a policy writer or sustainability lead for the data when the real source sits with the energy manager, facilities team, or another operational owner.
Framework language only
People ask for answers in disclosure terms instead of the organisation’s own wording, so the source team cannot map the policy or commitment to how it is actually run.
Scope left vague
The collector does not pin down which sites, business units, or activities are in scope, so the evidence later mixes covered and uncovered parts of the organisation.
+ Show 6 more

Where judgement is often needed

Setting the reporting perimeter after a buy-in or sale
Decide which sites, teams and energy use sit inside the period’s scope after acquisitions or disposals, and explain any cut-off date or inclusion rule you used.
Using local labels versus one group-wide definition
Where countries use different names or meanings for the same energy policy ideas, map them to one internal definition and note any places where the local wording changes the interpretation.
Including borderline operations and shared facilities
Be explicit about whether jointly run sites, leased premises, contractors on your premises, or other near-boundary activities are counted, and describe the rule used for those calls.
+ Show 5 more
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Utilities

We set out how our energy policy and related commitments are designed to cut the power and fuel we use across operations. In this synthetic example, our annual energy use was 120,000 MWh, of which 78,000 MWh came from electricity and 42,000 MWh from gas; the reduction programme covered all sites, and 96,000 MWh (80%) of total use was within the scope of active efficiency measures. - We also explain the wider effects we consider from our energy choices, including economic, environmental and social impacts linked to how energy is sourced and used. - Those impacts are assessed for our own sites and key suppliers, with 14 material issues identified: 6 economic, 5 environmental and 3 social, all of which are synthetic and illustrative.

Illustrative only: shows how a reporter might describe energy-related policy commitments, the resulting reduction focus, and the broader impact areas considered.

Illustrative (synthetic) example — Food manufacturing

Our synthetic disclosure explains how our energy rules and commitments support lower consumption in production and logistics. For this illustration, total energy use was 84,000 MWh, split between 50,400 MWh of electricity and 33,600 MWh of gas; efficiency actions covered 63,000 MWh (75%) of total use, and 21,000 MWh of that covered amount came from process upgrades. - We also describe the economic, environmental and people-related effects that may arise from our energy decisions, including effects in our own operations and along the supply chain. - In this example, we screened 10 potential effect areas and judged 4 as economic, 3 as environmental and 3 as people-related; the figures are internally consistent and purely illustrative.

Illustrative only: shows a different sector framing the same disclosure around energy-use reduction and the range of possible impacts considered.

Company reportsReal published reports
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How companies report GRI 103-1 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Tata AutoComp Systems Limited
Automobiles and Components · India · 2025
Open report →
Tata AutoComp Systems Limited’s Sustainability Report FY 2024-25 includes numeric values related to energy policies and water discharge management on page 114, indicating coverage of environmental impact management. The report also addresses product stewardship as a very high-risk material topic with relevant data on page 21. However, specific details on the scope of energy-related activities excluded from Scope 1 or Scope 2 emissions are mentioned on page 58 but lack clear numeric data, and some environmental goals are outlined on page 14 and 30 without detailed quantitative progress indicators.
Valterra Platinum
Mining — Rare Minerals / Precious Metals / Gems · South Africa · 2025
Open report →
Valterra Platinum’s Sustainability Report 2025 includes specific numeric data on energy consumption and related policies, with detailed references on pages 63 and 64 outlining energy policies, commitments, and consumption figures for 2023 to 2025. The report also addresses employee-related topics such as safety, health, wellbeing, and talent management, with relevant data found on page 3. However, the report provides less clarity on the proportion of spending on local suppliers and local employment, which are mentioned on page 93 but without explicit numeric values or detailed findings.
Interconexión Eléctrica S.A. E.S.P.
Electric Utilities / IPP / Energy Traders · Colombia · 2024
Open report →
Interconexión Eléctrica S.A. E.S.P.’s 2024 Integrated Management Report includes numeric values related to policies or commitments on the material topic, with specific measures taken to manage these disclosed on page 144. The report also highlights the company’s commitment to improving environmental conditions, as noted on page 87. However, details on the scope of impacts and actions, such as political and institutional instability or asset life cycle stages, are mentioned but not clearly quantified or fully explained in the provided excerpts (pages 54 and 93).
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Scenarios to work through

A group has a written energy policy that focuses on cutting electricity use in offices and warehouses. The draft report also mentions that the policy is intended to reduce wider effects linked to energy use, but the team has not yet linked those effects to the business areas most likely to be affected.

QShould the disclosure explain both the energy-saving aim and the broader effects the policy may have on the business, and should those effects be tied to the relevant areas of impact?
Reveal model answer →

A preparer has a board-approved energy commitment that applies to all sites, but the supporting note only says the company is “committed to sustainability” and does not explain what the commitment is meant to achieve. The team is unsure whether that is enough for the report.

QIs a broad sustainability statement enough, or does the disclosure need a clearer link between the commitment and energy use reduction?
Reveal model answer →

The sustainability team has two separate internal documents: one on energy efficiency targets and another on community and environmental impacts from operations. They are drafting the disclosure and are unsure whether to mention both, since the energy policy touches both documents in different ways.

QWhen preparing the disclosure, should the team bring together the energy policy’s contribution to lower energy use and the related impacts on the business’s wider effects?
Reveal model answer →

A draft report says the company has an energy commitment, but it only lists technical measures such as LED lighting and smart meters. It does not say whether those measures are part of a policy or commitment that is meant to reduce energy use, nor does it mention any broader impacts.

QShould the disclosure stop at listing measures, or should it explain the policy or commitment behind them and the impacts that may result?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 103-1
within GRI 103: Energy
Open official source →
Primary
Related & explore
Go deeper · GRI 103-1
Learn to prepare this disclosure end-to-end

This guide covers one disclosure. The GRI Standards Certified Training — taken as a bundle with an ESRS course — walks the full workflow: datapoints, evidence, drafting and assurance, with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

FAQ

Questions this page answers

For GRI 103-1 Energy, what data do I need to gather before I start drafting the disclosure?+
How do I use the step-by-step 'how to prepare' section for GRI 103-1 Energy?+
Who should own the GRI 103-1 Energy data and evidence in practice?+
What should I include in the evidence pack for GRI 103-1 Energy to make it assurance-ready?+
What are the five assurance claims I need to verify for GRI 103-1 Energy?+
What are the common mistakes people make when reporting GRI 103-1 Energy?+
How do I turn the GRI 103-1 Energy data into a draft disclosure?+
Can I use the synthetic example disclosure on the GRI 103-1 Energy page as a template?+
What does the quantitative table in the GRI 103-1 Energy example show me?+
How should I use the Prep & Assurance workbook for GRI 103-1 Energy?+
What is the printable Library Card PDF for GRI 103-1 Energy used for?+
More questions this page can help with
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