GRI 101: Biodiversity 2024 · Topic Standard · Cross-sectoral
Disclosure GRI 101-3
Access and benefit-sharing
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.
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Reviewed by
Dr Ross Kurinko · GRI Certified Trainer
To prepare this disclosure
2 datapoints ↓
4 claims to verify ↓
5 evidence areas ↓
3 report examples ↓
Disclosure focus
This disclosure asks an organisation to explain how it approaches access and benefit-sharing where it uses biological resources or related traditional knowledge. In practice, the report should make clear whether the organisation has identified relevant activities, what policies or processes it uses, and how it manages permissions, agreements, and any sharing of benefits that may arise.
The practical focus is on the organisation’s real-world coverage, not just a single flagship site or one-off project. Readers should be able to see whether the approach applies across the business, which parts of the organisation are in scope, and how consistently the organisation applies its process where access and benefit-sharing issues are relevant. This is educational guidance only and should be checked against the applicable reporting requirements.
* 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 |
|---|---|---|---|
| Compliance process | Capture a plain description of the steps the organisation uses to meet access and benefit-sharing rules and related measures, including how those steps are applied in practice. | Policy or procedure notes, compliance workflow, legal review records, and any internal controls or checklists used to manage access and benefit-sharing obligations. | Legal / Compliance |
| Voluntary biodiversity actions | Capture a plain description of any voluntary actions the organisation has taken to support access and benefit-sharing beyond what the law requires, including action taken where no relevant rules or measures exist. | Project notes, programme descriptions, partnership records, board or management approvals, and other internal evidence showing the voluntary nature of the actions. | Sustainability / ESG |
Show GRI 101-3 sub-elements (LRA working checklist)
- Set out how the organisation checks it is meeting the relevant access-and-benefit-sharing rules and controls.
- Set out any extra steps the organisation takes to support access-and-benefit-sharing beyond what the law requires, or where no such rules and controls exist.
LRA working checklist - paraphrased; see official source
How to prepare
- Set the reporting boundary first: decide which parts of the business, sites, activities, and value-chain relationships are in scope for this disclosure, so the same boundary is used consistently when gathering the two required descriptions.
- Separate the two content streams early: one for how the organisation manages compliance with access-and-benefit-sharing rules and measures, and another for any voluntary actions that go beyond legal duties or apply where no such rules and measures exist.
- Define what will count as evidence for each stream: collect internal policies, procedures, approvals, records, and other source material that supports the process description and the voluntary-action description, rather than relying on unsupported narrative.
- Draft the compliance-process account in plain language: explain the practical steps the organisation uses to meet the relevant rules and measures, using the evidence to show how the process works in practice.
- Draft the voluntary-actions account separately: describe the extra steps taken beyond legal requirements, or the actions used where no applicable rules and measures are in place, and make clear that these are additional measures rather than compliance controls.
- Check the final wording against the official source and your evidence pack: confirm both descriptions are complete, any exclusions or scope changes are explained, and the published text matches the underlying records without adding unsupported claims.
Request the access-and-sharing evidence from Legal / Compliance
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What evidence can we use to explain how the organisation manages access-and-sharing obligations, and what extra steps it takes where it goes beyond the legal baseline or where no local rules apply?
Use your organisation’s own terms first, then map them to the disclosure. For example, if your teams talk about permits, permits-to-work, biodiversity approvals, local community agreements, or resource-use permissions, use those labels in the request and response. Keep the ask in business language, and only translate into the reporting wording at the end. Check the official source before sign-off.
Weak request
Can you send the GRI 101-3 evidence for access and benefit-sharing?
Why it fails: It uses framework language only, so the owner may not know which internal process, documents, or locations to pull together. It also does not ask for the practical details needed to explain how the process works or what extra actions are taken where the baseline is limited.
Better request
Can you send the documents and a short summary showing how we manage permissions, approvals, and any related sharing commitments in [site/jurisdiction] for [reporting period], plus any extra steps we take where local rules are thin or where we choose to go further? Please include the source, coverage, and any exclusions, using your team’s own terms.
Formal email template
Subject: Request for access-and-sharing evidence for [reporting period] Hi [name/team], I’m pulling together the sustainability reporting pack for [reporting period] and need your help with the material on how we manage permissions, approvals, and any related sharing or local benefit commitments. Please send: - A short plain-English summary of the process we use to stay aligned with the relevant rules and controls in [jurisdiction/site/project] - Any supporting documents that show how this is handled in practice (for example, procedures, registers, approvals, or governance papers) - Any examples of extra steps we take where local rules are limited or where we choose to do more than the minimum - The period covered, the business area/site covered, and the source of the information - Any gaps, exclusions, or caveats we should note Please use your team’s own terminology in the response, and I’ll map it into the reporting wording afterwards. If helpful, I can turn your notes into a short draft for you to review. Please send this by [date]. Check the official source before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name] — could you send over the access-and-sharing evidence for [reporting period]? I need a short summary of how we handle permissions/approvals and any extra steps we take beyond the baseline, plus any supporting docs, the period covered, and any gaps/exclusions. Please use your own team terms — I’ll map them for reporting. Check the official source before sign-off. Thanks.
Industry examples
Mining / Extractives
Context. A site team manages land access, exploration permissions, and community agreements across several jurisdictions.
Adapted request. Please send the site-level summary and supporting records showing how we handle exploration permissions, land-use approvals, and any community-sharing commitments for [reporting period], including any extra measures we take where local rules do not cover the issue in full.
Example response. The site provided a permit register, a compliance procedure, and a community agreement log. It also noted a voluntary local training and grievance follow-up process used at two sites where the legal framework did not set out a detailed engagement process.
Pharmaceuticals / Life sciences
Context. R&D teams use biological samples and external research materials under contract terms and local permissions.
Adapted request. Please send the summary and evidence showing how we manage permissions, contract terms, and any additional stewardship steps for [reporting period] across R&D and sourcing, including where we apply extra controls beyond the local baseline.
Example response. The team returned a materials approval procedure, supplier contract clauses, and a register of sample-use approvals. It also described a voluntary review step for new collaborations in locations with limited local guidance.
The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.
Draft your disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
We describe the basis used to compile the disclosure, including how we defined compliance checks and what we counted as additional voluntary action.
Context note
The figures and descriptions show how the organisation manages access-and-benefit-sharing in practice, both where formal rules apply and where it has chosen to go further.
Fluctuation statement
If the approach changed during the period, explain whether that was due to new legal requirements, changes in operating locations, or a shift in voluntary practice.
Content index entry
GRI 101-3 Access and benefit-sharing — [location / page] / [notes]
Download Centre
Professional preparation tools and forms for GRI 101-3. Each download includes a concise “How to use” guide.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We documented the steps we used to check that the disclosed process aligns with the relevant access-and-sharing rules, including how we identified the applicable rules and who reviewed the conclusion. | The assurer will test whether the process was actually followed, whether the right rules were identified for each case, and whether the review was independent and complete. | Procedure note or methodology paper; legal/regulatory mapping; review sign-off; internal emails or meeting notes showing the assessment; version history of the working papers; any gap log or issue tracker. |
| Where we went beyond legal duties, or where no specific rules applied, we recorded the extra actions we took and the basis for saying they were voluntary rather than mandatory. | The assurer will probe whether the reported actions were genuinely additional, whether the boundary between required and voluntary was applied consistently, and whether any omissions were justified. | List of voluntary measures; rationale memo for each measure; legal analysis showing the absence of a rule or the minimum required position; approvals from the responsible team; supporting project records, plans or implementation evidence. |
| We kept evidence showing how the coverage figure was built, including the source data, the scope choices we made, and the checks we carried out before publication. | The assurer will look for completeness of the population covered, consistency of scope decisions, and whether the figure can be traced back to reliable source records without unexplained adjustments. | Source datasets; scope boundary notes; calculation workbook; reconciliation to underlying records; data owner confirmations; pre-publication review checklist; change log for any manual edits or exclusions. |
| Before release, we ran internal quality checks on the disclosed information and resolved any anomalies we found, so the final version matched the approved working papers. | The assurer will test whether the final disclosure agrees with the approved numbers and narrative, whether exceptions were investigated, and whether the review was strong enough to catch material errors. | Final approval pack; quality-control checklist; exception log and resolution notes; sign-off from preparer and reviewer; comparison between draft and published version; evidence of corrections made before issue. |
Evidence pack to prepare
- The governing policy or written commitment behind this disclosure
- A methodology / definition note setting out how the disclosure was scoped and prepared
- Source-system exports the figures or facts were drawn from
- The internal approval / sign-off record for the disclosure before publication
- Minutes or records evidencing the relevant engagement or consultation
Common reporting gaps
- The information is presented without a date or as-at point.
- The scope or boundary of the statement is left undefined.
- Key terms are used inconsistently across the report.
- Material changes since the previous period are not disclosed.
- Assertions are made without supporting detail or a source record.
- Boilerplate is used that does not actually answer what is asked.
Mistakes to avoid when collecting the data
- Wrong owner
The team chases Legal or Sustainability for the answer when the real source sits with the function that handles permits, fieldwork, sourcing, or local partner agreements.
- Framework language only
People ask for information using disclosure jargon, so the business cannot map the request to its own controls, records, and day-to-day process names.
- Scope left vague
The data pull starts before anyone has fixed which sites, projects, suppliers, or countries are in scope, so the result mixes unrelated activity.
- Boundary not set
Records are gathered without deciding whether to include only the reporting entity or also other parts of the group, which leads to inconsistent coverage.
- Wrong time basis
The team uses a different period from the reporting cut-off, so the evidence reflects an earlier or later operating cycle than the disclosure period.
- Mixed counting basis
One dataset combines counts, cases, and narrative examples without separating them, so the numbers cannot be traced back to a single method.
- Source labels lost
Original file names, permit references, contract IDs, or case tags are stripped out during collation, making it hard to trace each item back to its origin.
- Separate populations merged
Legal-obligation cases and extra voluntary actions are rolled into one pool, even though they need to stay distinct for the final write-up.
- No evidence trail
The pack is assembled without keeping the underlying documents, metadata, and sign-off history together, so reviewers cannot see who checked what and when.
Where judgement is often needed
- What counts as the group you are reporting on after a buy-in or sale
Set a clear cut-off for acquisitions and disposals, explain which entities or activities are included for the period, and note any change in scope so readers can see why the process description moved.
- When local rules use different terms or tests
If country-level rules describe access permissions or benefit-sharing differently, explain the local rule set you followed in each place and how you translated that into one group-wide description.
- How to handle sites, projects, or teams that sit partly inside the scope
State the rule you used for borderline cases, such as including only operations with a direct link to the relevant activity, and disclose any exclusions that were made on that basis.
- Whether to describe the process from the current year or from the reporting date
Choose one timing basis for the narrative, apply it consistently, and say whether the description reflects year-end arrangements, arrangements in place during the year, or both.
- When to use estimates instead of direct records
If some parts of the process are not fully documented, explain where you relied on informed estimates, why that was necessary, and how you checked that the estimate was reasonable.
- How much detail to give when the underlying records are sensitive
Aggregate or generalise sensitive information where needed, but make clear what has been grouped together and whether any privacy limits affect the level of detail in the description.
- How to treat voluntary actions that go beyond legal duties
Separate actions taken because of law from extra steps taken by choice, and explain the basis for calling something voluntary so readers can tell the two apart.
- How to present rounding or simplification in the narrative
If you simplify counts, dates, or examples to keep the disclosure readable, say so and make sure the rounded presentation does not change the substance of the process description.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Food ingredients and agriculture · synthetic · written by LRA
This example shows how to describe the control process and then separate out extra voluntary actions, while keeping the figures internally consistent.
Synthetic illustration only. We run a supplier and site review each year to check that any land, genetic resource, or traditional-knowledge use linked to our operations has the right permissions, benefit-sharing terms, and recordkeeping in place.
- Our compliance check starts with a legal register, contract review, and sign-off from procurement, legal, and sustainability teams before any project can proceed.
- In the year, 18 of 18 relevant projects were reviewed; 18 were cleared, 0 were escalated, and 100% had documented evidence of the permissions and benefit-sharing terms needed.
- Beyond what the law requires, we also support local partners through training, shared field data, and two community research agreements, even where no specific rule applies.
Pharmaceuticals and biotechnology · synthetic · written by LRA
This example uses a different sector and a different control path, then adds voluntary measures taken even when no formal rule is in place.
Synthetic illustration only. We use a staged approval process to make sure any access to biological material or associated local knowledge is checked against the relevant rules, with legal review, ethics review, and final approval before use.
- During the period, 12 of 12 new material requests went through the full review route; 12 were approved with the required terms attached, 0 were rejected, and 100% were logged in our tracking system.
- Where the law does not set a specific rule, we still choose to share outcomes through local workshops, capacity-building support, and one voluntary benefit-sharing arrangement with a research partner.
- These extra steps are separate from our compliance checks and are intended to strengthen fair sharing in practice.
Draft output & visualisation ideas
How to turn the collected data into a draft disclosure. Suggested visuals and a GRI content-index line generated from this disclosure's datapoints.
Suggested visuals
- Compliance process overview — table: A side-by-side summary of the steps used to check alignment with access-and-benefit-sharing rules, including who is involved and what each step covers.
- Legal checks versus extra actions — stacked bar: How the organisation’s response is split between actions needed to meet legal requirements and additional voluntary measures.
- Coverage of voluntary measures — bar: The range or count of extra actions taken beyond what the law requires, or used where no relevant rules are in place.
- Process stages for compliance — line: The sequence of internal review, approval and follow-up steps used to manage compliance over time.
- Jurisdictional coverage — map: Where the organisation operates in relation to places with access-and-benefit-sharing rules and places without them.
From a number to a disclosure
What separates a figure from a disclosure.
Basic
We have a process to check access-and-benefit-sharing rules and we also take extra voluntary steps where there are no such rules or where we go beyond them.
Better
We use a documented review process for access-and-benefit-sharing compliance, and we also describe the voluntary steps we take when local rules are absent or when we choose to do more than the law asks.
Best
For the year ended 31 December 2025, we applied our access-and-benefit-sharing review process across all relevant activities and took additional voluntary measures in two cases where no local rules applied and in one case where we went beyond legal duties, because we wanted to reduce risk and support fairer sharing outcomes.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 101-3 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
 |
Godrej Properties Limited | Real Estate · India | 2025 | Partial | p. 63 →p. 264 →p. 209 → | Integrated Report 2024-25 → | KPMG | |||||||||
Evidence in Godrej Properties Limited’s reportWhat the report shows Godrej Properties Limited's Integrated Report 2024-25 includes a specific reported value of "2" on page 211 and details an additional 22.46 percent profit sharing of GVLLP by giving exit to its joint venture partners on page 233. The report also references compliance with occupational health and safety standards and biodiversity impact identification, though these are not clearly linked to the main disclosure datapoints. Notably, the report lacks detailed narrative explanations or contextual information for these values, making some aspects unclear.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
|
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Sumitomo Forestry Co., Ltd. | Home Building · Japan | 2025 | Exact | p. 529 →p. 131 →p. 454 → | Sustainability Report 2025 → | EY; BSI | |||||||||
Evidence in Sumitomo Forestry Co., Ltd.’s reportWhat the report shows Sumitomo Forestry Co., Ltd.'s Sustainability Report 2025 provides coverage on access and benefit-sharing (ABS) related to biodiversity impacts, with specific references to identification of impacts and locations on page 529. The report also notes on page 131 that there were no particular regions of concern related to genetic resources held by Indigenous peoples. However, the report does not clearly detail the processes or outcomes of ABS agreements, and further specifics on direct benefits or compliance mechanisms remain unclear.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
|
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Home Product Center Public Company Limited | Retailing · Thailand | 2025 | Exact | p. 199 →p. 109 →p. 171 → | Sustainability Report 2025 → | EY | |||||||||
Evidence in Home Product Center Public Company Limited’s reportWhat the report shows Home Product Center Public Company Limited’s Sustainability Report 2025 covers actions taken related to anti-competitive behavior, referencing specific pages (263-264) and management of material topics (p.200). The report also highlights leadership roles in promoting effective and beneficial practices, with supervisors expected to lead, train, and coach (p.117). However, details on the specific outcomes or metrics related to anti-competitive behavior and compliance with laws such as Thailand’s PDPA are mentioned but not fully detailed or quantified in the provided extracts (p.192).
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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Check your understanding
A cosmetics business uses a plant extract sourced from a country where biodiversity rules apply. The sustainability team has a written process for checking permits, contract terms, and local conditions before any new sourcing deal is approved.Should the disclosure explain that process, and what level of detail is useful for a reader?
Model answer. Yes. The narrative should set out, in plain terms, how the organisation checks that sourcing and use of biological materials stay aligned with the relevant access-and-sharing rules, including the steps, controls, and responsibilities involved. It should be understandable to a reader without copying legal language.
Why this matters. Describe the practical control process that keeps sourcing aligned with the applicable rules.
A food company buys a seed ingredient from a supplier in a place where there are no access-and-sharing rules in force. The company still has a contract clause asking the supplier to share benefits if local rules appear later.Does this belong in the part of the disclosure about extra actions beyond legal duties or where no rules exist?
Model answer. Yes. This is the kind of voluntary step that can be described separately: action taken even though there is no current legal framework, or action that goes beyond what the law already asks for. The explanation should make clear that the company is acting proactively rather than simply following a legal minimum.
Why this matters. Include voluntary measures taken when there is no legal framework or when the organisation goes further than the law.
A biotech firm has two sourcing routes for the same material. One route is covered by local access-and-sharing rules and the other is not. The reporting team has one paragraph that mixes both routes together without saying which controls apply to which.How should the disclosure be handled so a reader can tell the difference?
Model answer. The reporting should separate the two situations clearly. One part should explain the process used where legal access-and-sharing rules apply; another part should explain any voluntary steps used where there are no such rules, or where the organisation chooses to do more than the law demands. Mixing them together would make it hard to see what is legal compliance and what is voluntary practice.
Why this matters. Keep legal compliance measures distinct from voluntary actions so the reader can see which is which.
A personal-care company has no direct ownership of the plant material it uses, but it does approve suppliers and sets sourcing conditions. The team is unsure whether the narrative should focus only on the supplier’s obligations or also on the company’s own checks and follow-up.What should the disclosure emphasise in this situation?
Model answer. It should emphasise the organisation’s own approach: how it screens suppliers, sets expectations, monitors compliance, and records any extra steps it takes to support fair sharing of benefits. The point is to explain the company’s process and actions, not just to restate what a supplier says it will do.
Why this matters. Report the organisation’s own controls and voluntary actions, not only the supplier’s promises.
Analyse this disclosure across real reports
See how companies actually report GRI 101-3 — drawn from their own published reports, with the exact pages, and an LRA AI-assistant that works through it with you. Available to LRA Community members and to students throughout their platform access.
Related framework references
How this disclosure maps across the major reporting frameworks.
→
ESRSRelated
ESRS E4
Biodiversity and Ecosystems — closest topical match (post-Omnibus ESRS catalogue).
→
IFRSNo equivalent
—
No direct IFRS S1/S2 topical equivalent.
Related & explore
Questions this page answers
For GRI 101-3 Biodiversity, what data do I need to gather before I start drafting the disclosure?
The page says to prepare two datapoints: your compliance process and any voluntary biodiversity actions. Use those as the starting point for scoping, then build the draft from the step-by-step preparation section. ↑ section
How do I use the step-by-step 'how to prepare' section for GRI 101-3 Biodiversity in practice?
Use it as a working checklist to move from scoping to data collection, then into drafting. The page is designed to help you prepare the disclosure rather than just describe it. ↑ section
Who should own the GRI 101-3 Biodiversity data collection in my organisation?
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can evidence the compliance process and voluntary biodiversity actions. The workbook can help you assign and track that ownership. ↑ section
What evidence should I keep in the pack for GRI 101-3 Biodiversity assurance?
The page includes an evidence pack with five items for assurance readiness. Use that pack to support the four claims to verify and keep the disclosure audit trail together. ↑ section
What are the four assurance claims I need to check for GRI 101-3 Biodiversity?
The page says there are four claims to verify, each with a claim, risk and evidence angle. Use those as the basis for your assurance review and make sure the evidence pack supports them. ↑ section
What are the common reporting gaps or mistakes to avoid when drafting GRI 101-3 Biodiversity?
The page lists common reporting gaps and mistakes to help you spot weak points before sign-off. Use that section to check whether your draft is missing scope, evidence, or a clear link back to the datapoints. ↑ section
How can I turn the GRI 101-3 Biodiversity data into a draft disclosure?
The page includes a draft-output section with visualisation ideas, narrative starters and a GRI content-index line. That gives you a practical route from collected data to a first draft. ↑ section
Can I use the GRI 101-3 Biodiversity workbook and printable library card to prepare the disclosure?
Yes. The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf, both intended to support preparation and assurance readiness. ↑ section
Are the example disclosures on the GRI 101-3 Biodiversity page real company examples or synthetic?
The page says the illustrative example disclosures are synthetic. They are there to show how the disclosure can look in practice, including a quantitative table where relevant. ↑ section
How do I use the 'From company reports' table on the GRI 101-3 Biodiversity page?
Use it as a reference point for seeing where the topic appears in real published reports. It links to pages where the topic is disclosed, which can help you compare structure and presentation. ↑ section
What is the closest ESRS correspondence for GRI 101-3 Biodiversity, and can I reuse the data?
The page says the closest ESRS correspondence is ESRS E4 (Biodiversity and Ecosystems). You can treat the data as reusable for cross-framework work, but the page does not say the requirements are identical. ↑ section
More questions this page can help with
- GRI 101-3 Biodiversity checklist: what should be in my evidence pack?
- How do I scope GRI 101-3 Biodiversity compliance process data for reporting?
- What voluntary biodiversity actions should I capture for GRI 101-3 Biodiversity?
- How do I assign ownership for GRI 101-3 Biodiversity data and evidence?
- What are the most common mistakes in GRI 101-3 Biodiversity reporting?
- How do I use the GRI 101-3 Biodiversity workbook to build a draft?
- What does the GRI 101-3 Biodiversity draft-output section include?
- How do I make GRI 101-3 Biodiversity assurance-ready?
- What should I check before finalising GRI 101-3 Biodiversity disclosure?
- Where can I find example disclosures for GRI 101-3 Biodiversity?
- How does GRI 101-3 Biodiversity relate to ESRS E4 data reuse?
- What does the plain-language explainer for GRI 101-3 Biodiversity help me do?
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Sources, status and disclaimer
This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.
