Disclosure focus
This disclosure asks an organisation to say whether it has been involved in legal action relating to anti-competitive behaviour, anti-trust, or monopoly practices during the reporting period, and to describe the outcome or current status where relevant. The focus is on giving a clear picture of any formal proceedings that could indicate competition-law risk, rather than on general policy statements or informal complaints.
In practice, the organisation should consider coverage across the whole business, not just a few well-known sites or business units. The reporting should reflect the full reporting period and the full scope of operations included in the report, so readers can see whether any legal cases arose anywhere in the organisation and how significant they were.
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
＋ Show GRI 206-1 sub-elements (LRA working checklist)
Summarise the final result of each concluded case, including any ruling or decision reached.
Count every case, open or closed, during the reporting period where the organisation was named in a matter about anti-competitive conduct.
Count every case, open or closed, during the reporting period where the organisation was named in a matter about breaches of anti-trust or monopoly law.
How to prepare it
1Set the reporting boundary first: confirm which entities, operations and time period are in scope for this disclosure, so you only count matters that fall within the period you are reporting.
2Define the two case types you will track, using your own internal labels for competition-related matters and for cases tied to anti-trust or monopoly rules, so the team applies the same test when deciding what to include.
3Gather the source records for each case, such as legal trackers, counsel updates, case logs and court or regulator papers, and make sure each item shows whether the matter is still open or has finished.
4Count the matters separately for each case type, then prepare the narrative on the finished cases by summarising the main result and any decision or judgment, using a clear and consistent basis for the figures.
5Record any exclusions, reclassifications or changes in how cases were treated from the prior period, so a reviewer can see why the current numbers and narrative differ from earlier reporting.
6Check the final disclosure against the official source and your evidence pack, confirming the counts, the case descriptions and the outcome summary all match the underlying records before sign-off.
Request the data
Request the competition-law case log and outcomes
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How many competition-related cases were open or finished in the reporting period, and what were the outcomes of the finished ones?
Use your organisation’s own labels first, then map them to this disclosure. For example, ask for the competition-law matters register, antitrust case tracker, or litigation log if that is how the team records these items. Keep the request in internal business language and check the source wording before sign-off.
Weak request
Please provide the GRI 206-1 numbers and narrative for anti-competitive behavior, anti-trust, and monopoly practices.
Why it fails: This uses framework language that many legal teams will not use day to day, and it does not say which internal register, boundary, status, or source evidence to pull. It also does not separate open matters from closed ones or ask for the outcome details needed for the finished cases.
Better request
Please pull the competition-law matters log for [reporting period] covering [entity/business unit], showing any open or closed cases where [organisation name] was named, plus the final result for closed items. Use your normal case categories, include the case reference, status, and source extract, and confirm if there were none.
Industry examples
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
Explain how you counted each matter, including whether you treated one case with several allegations as one item or more than one, and state the basis used to decide whether a matter was included in the period total.
Context note
Set out what the figures indicate about the organisation’s exposure to competition-related legal challenge, and summarise the main results of any finished cases so readers can see whether the matters were resolved, dismissed, or led to another outcome.
Fluctuation statement
If the number of matters changed materially, note whether this was driven by new filings, closures, or a change in how cases were classified, and link any movement to the outcomes of completed matters where relevant.
Content index entry
GRI 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for GRI 206-1 — 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.
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to Legal alone or Compliance alone, so the team that tracks cases, settlements, and external counsel never confirms the count.
Framework language in the ask
The data request uses GRI-style labels instead of the organisation’s own case categories, so people cannot map the ask to their day-to-day records.
Scope not pinned down
No one states which entities, regions, or case types sit inside the reporting boundary, so different teams pull different populations.
Wrong time basis
The team uses filing date, close date, or hearing date inconsistently, so some matters are counted in the wrong reporting period.
Mixed counting rules
Pending matters and finished matters are blended together without a clear rule, so the same case can be counted twice or missed.
Source labels stripped out
When case lists are copied into a tracker, the original file names, matter IDs, and status labels are lost, making later checks impossible.
Separate populations merged
Competition cases and monopoly-law cases are rolled into one bucket too early, so the two counts cannot be rebuilt cleanly.
Evidence trail missing
The spreadsheet holds numbers but not the supporting documents, dates, and reviewer notes, so no one can trace where the figures came from.
No sign-off record
The final extract is sent on without a named reviewer or approval date, so there is no clear trail showing who checked the figures.
Where judgement is often needed
Set the group boundary for newly bought or sold businesses
Decide whether to count matters linked to entities added or removed during the year using the reporting cut-off you apply for the rest of the group, and explain that basis if it changes the tally.
Map local competition laws to one internal classification
Where different countries use different legal labels or test thresholds, use a single internal rule for deciding whether a case sits in the anti-competition or market-dominance bucket, and describe that rule in plain language.
Choose how to treat matters that sit close to the reporting perimeter
If a case involves a joint venture, associate, branch, or other partly controlled operation, state the rule you used to include or exclude it and why that treatment fits your organisational boundary.
Decide whether to count each case once or by separate proceedings
When one investigation leads to several filings, appeals, or linked actions, set out whether you count the matter as one case or several and keep that approach consistent across the period.
Fix the timing rule for pending and finished matters
Use one clear date rule for when a matter enters or leaves the count, such as the date it is first identified or the date it is closed, and disclose that timing choice so readers can follow the numbers.
State how you handle incomplete or estimated case data
If the legal team cannot confirm a figure from records alone, use the best supported estimate, label it as such, and explain the source and any limits on accuracy.
Round numbers in a consistent way
Apply the same rounding method to all counts, make sure the rounded figures still tell the same story as the underlying records, and note the rounding basis if it affects the result.
Protect personal data when summarising outcomes
When describing the main result of a finished case, aggregate or anonymise details where needed so individuals are not identifiable, while still giving enough context to show the nature of the decision or judgment.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Consumer goods
Synthetic example only: during the year, we had one completed competition-law case and no open matters. The completed case ended with a settlement and a compliance undertaking; no fines were imposed.
This example shows how to report the count of competition-related cases, split between open and closed matters, and then briefly state the result of any closed case.
Illustrative (synthetic) example — Transport and logistics
Synthetic example only: we had two matters in total, both closed in the period, and none remained unresolved at year-end. One ended with no breach finding; the other concluded with a formal warning and a requirement to update our pricing controls.
This example shows a second way to present the same disclosure: separate the two legal-action categories, show whether each is open or closed, and summarise the outcome of completed cases.
Company reports
How companies report GRI 206-1
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
WuXi AppTec Co., Ltd.
Pharmaceuticals / Biotech / Life Sciences · China · 2024
WuXi AppTec Co., Ltd.'s Environmental, Social and Governance Report 2024 provides numeric data on anti-competitive behavior legal actions on page 103, indicating the company reports on legal actions related to anti-competitive behavior. The report also includes the voluntary employee turnover rate of 9.32% on page 75 and states that 87-89% of main operational sites have obtained ISO/IEC 27001 certification on page 82. However, the report does not clearly detail the outcomes or specific nature of these legal actions, and information on violations related to clinical trials is noted as zero but lacks further context (p.82).
Companhia Paranaense de Energia - COPEL
Electric Utilities / IPP / Energy Traders · Brazil · 2024
Companhia Paranaense de Energia - COPEL's Integrated Report 2024 provides specific data on legal actions related to anti-competitive behavior, stating there were no such legal actions taken, as noted on page 312. The report also mentions no human rights violations concerning Indigenous peoples in its operations during the reported period (p.217). However, some details remain unclear or missing, such as comprehensive information on organizational alignment expected by May 2025 (p.70) and broader context on legal cases beyond anti-competitive behavior.
Amadeus IT Group, S.A.
Hotels, Restaurants, Leisure, Tourism Services · Spain · 2025
Amadeus IT Group’s 2025 Non-Financial Report includes a policy addressing all types of discrimination and the management of diversity, as noted on page 214. However, no specific numeric values or detailed narrative disclosures related to certain aspects of the workforce or other sustainability metrics were found in the report. Additionally, while there is mention of actions and resources related to material sustainability matters such as data privacy (p.207) and business conduct policies concerning corruption or bribery (p.53), these do not provide further detail on the disclosure in question.
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Check your understanding
Scenarios to work through
During the year, your organisation was named in one live court case about alleged price coordination with competitors, and a separate regulator investigation about market-dominance rules was closed before year-end. The legal team has sent a summary, but the finance team is unsure whether both matters belong in the same disclosure.
QShould you count both matters in the period total, and how should you treat the closed investigation when describing the result?
Reveal model answer →Hide answer ↑Yes. Count every legal matter in the reporting period where the organisation was identified as involved, whether it is still ongoing or has finished. The live case goes into the count for competition-related conduct, and the closed investigation also goes into the count for market-power law issues if it concerned that type of breach. For the finished matter, add a plain summary of what happened at the end, such as the decision reached or the judgment given.
Why this matters · Include both open and closed matters in the period count, and give a short outcome summary for any finished case.
A subsidiary was the named party in a completed case about resale pricing, but the parent company was not listed in the court papers. Group reporting is being prepared at parent level, and the team is debating whether to include the case because the conduct happened in a controlled entity.
QDo you include the case in the disclosure for the reporting organisation, and what should you check before deciding?
Reveal model answer →Hide answer ↑Include it if the reporting organisation itself was identified as a participant in the legal action. If only a separate group entity was named, you need to check whether the reporting boundary for this disclosure covers that entity in the way your report is being prepared. The key point is to count matters where the reporting organisation is the identified participant, not to infer involvement from ownership alone.
Why this matters · Base the count on who was actually named in the legal action, and confirm the reporting boundary before including a group entity.
Your organisation received two letters in the same month: one from a competition authority opening an inquiry, and one from a court confirming that a case had been settled and closed. The draft report currently lists only the closed case because the team thinks unresolved matters should wait until next year.
QShould the open inquiry be counted this year, and what should the completed case include in the narrative?
Reveal model answer →Hide answer ↑Yes. If the inquiry is a legal action and the organisation has been identified as a participant during the reporting period, it belongs in the count even though it is not finished. The closed case also belongs in the count, and the narrative for that case should briefly explain the main result, such as settlement terms, a ruling, or another final decision.
Why this matters · Do not wait for closure before counting a live legal action; finished cases also need a short outcome note.
The legal team has prepared a table showing three competition-related matters and one market-power case. Two of the competition matters ended with no finding against the organisation, one is still ongoing, and the market-power case ended with a fine. The sustainability team is unsure whether the disclosure should only mention the fine because it is the most serious result.
QWhat should the disclosure cover for the completed matters, and how should the ongoing matter be treated?
Reveal model answer →Hide answer ↑The disclosure should cover the number of matters in each relevant category for the period, not only the most serious one. For the completed matters, give the main result for each finished case, including outcomes where there was no adverse finding as well as the case that ended with a fine. The ongoing matter is counted in the period total, but there is no final outcome to describe yet.
Why this matters · Report the full set of relevant legal matters for the period, and only summarise outcomes where a case has finished.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What data do I need to prepare for GRI 206-1 Anti-competitive Behavior on this page?+−
The page says to prepare three datapoints: competition case count, antitrust case count, and a short summary of case outcomes. Use those as the core inputs before drafting the disclosure.
How do I scope GRI 206-1 Anti-competitive Behavior for reporting purposes?+−
Use the page’s step-by-step preparation section to define the reporting scope around the two case counts and the outcomes summary. Keep the scope aligned to the evidence you can support in the workbook and evidence pack.
Who should own the GRI 206-1 data collection in practice?+−
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the person who can trace the case counts and outcomes back to source records. The workbook is there to help coordinate that handoff.
What evidence should I keep for assurance on GRI 206-1?+−
The page includes an evidence pack with five items for assurance readiness, plus five assurance claims to verify. Use those to build a file that links each claim to the relevant risk and evidence.
What are the five assurance claims on this page and how do I use them?+−
The page says there are five assurance claims to verify, each tied to a claim, risk and evidence check. Use them as a review list to test whether the disclosure is supported before it goes into a draft.
What are the common mistakes to avoid when drafting GRI 206-1?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot weak points before sign-off. In practice, use that section to check that your counts, outcomes summary and evidence pack all line up.
How do I use the Prep & Assurance workbook for GRI 206-1?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the preparation steps, capture the required datapoints and assemble the assurance evidence in one place.
What can I do with the printable Library Card for GRI 206-1?+−
The Download Centre also includes a printable Library Card in .pdf format. It is a quick reference for the disclosure, useful when you want the key datapoints and checks in a compact format.
How do I turn the GRI 206-1 data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a GRI content-index line. Use those to turn the case counts and outcomes summary into a first draft that is easy to review.
Can I reuse GRI 206-1 data for ESRS G1 Business Conduct reporting?+−
The page notes ESRS G1 (Business Conduct) as the closest correspondence, so the same underlying data may be reusable. Treat that as a cross-framework starting point rather than assuming the reporting needs are identical.
More questions this page can help with
GRI 206-1 Anti-competitive Behavior data points checklistHow to collect competition case count and antitrust case count for GRI 206-1GRI 206-1 case outcomes summary examples for draftingGRI 206-1 assurance evidence pack what to includeGRI 206-1 common reporting gaps and mistakesHow to use the GRI 206-1 workbook downloadPrintable GRI 206-1 library card downloadGRI 206-1 draft narrative starters and content index lineGRI 206-1 step-by-step preparation guidanceGRI 206-1 ownership and data responsibilityGRI 206-1 assurance-ready disclosure checklistGRI 206-1 ESRS G1 business conduct data reuse
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