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GRI 3: Material Topics
Disclosure GRI 3-1

Process to determine material topics

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 how it worked out which sustainability topics matter most for its reporting. In practice, that means setting out the process used to identify, assess and prioritise topics, rather than simply listing the final topics themselves. The focus is on showing that the organisation has a clear, reasoned approach to deciding what is material for its business and stakeholders.

The practical emphasis is on the scope and consistency of that process across the organisation. A good explanation should make clear whether the assessment covered the whole business, relevant subsidiaries, operations and value chain, or only selected sites or functions, and why that scope was chosen. It should also help a reader understand how the organisation reached its conclusions, so the material topics are seen as the result of a structured process rather than a one-off judgement.

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
Materiality process A plain account of the steps used to decide which sustainability topics matter for reporting, including the main stages, criteria used, and how the conclusion was reached. Materiality assessment paper, workshop notes, scoring model, decision log, reporting committee papers. Sustainability reporting
Impact identification method How the organisation looked for both current and possible future effects, good and bad, on the economy, environment and people, including human rights effects, across its own operations and wider business links. Impact mapping, risk and opportunity registers, due diligence outputs, value chain reviews, human rights assessments. Sustainability / Human rights / Risk
Impact ranking basis The rule or method used to decide which impacts were treated as more important for the report, and the factors used to rank them. Scoring criteria, prioritisation matrix, materiality workshop outputs, governance approval papers. Sustainability reporting
Input sources The groups and specialists whose views fed into the material topic assessment, named clearly enough to show who was consulted and in what capacity. Stakeholder engagement log, interview list, consultation records, expert adviser list, workshop attendance sheets. Sustainability reporting / Stakeholder engagement
+ Show GRI 3-1 sub-elements (LRA working checklist)

How to prepare it

1Set out the method you used to decide which topics matter for the report, so the reader can see the overall approach rather than just the end result.
2Map where the organisation may cause or contribute to good or bad effects, including those that are already happening and those that could happen, across its own operations and wider business links.
3Cover effects on the economy, the environment and people, and make sure any human-rights-related effects are included in that review.
4Rank the topics for reporting using your significance assessment, and keep enough working papers or notes to show why some issues were placed ahead of others.
5List the outside voices that shaped the assessment, naming the stakeholder groups and any subject-matter specialists whose input informed the process.
6Before finalising, check the wording and evidence against the official source so the narrative matches the underlying assessment and nothing required has been left out.
Request the data

Request the materiality assessment evidence

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

What process did we use to decide which sustainability topics matter most for reporting, and who helped shape that view?

Use your organisation’s own language first, then map it to the reporting terms. For example, if you talk about a risk review, impact scan, stakeholder listening exercise, or topic ranking, use those internal labels in the request and evidence pack rather than framework wording. This is a training template only; adapt it to your organisation and check the official source before sign-off.

Weak request

Please send the GRI 3-1 material topics process and stakeholder evidence.

Why it fails: It uses framework language only, so the owner may not know which internal files to pull. It also does not say what period, scope, topic-ranking method, or evidence types are needed, so the response is likely to be incomplete.

Better request

Please send the files from our topic-ranking exercise for [period], including the steps used to identify and rank the issues we treat as most important, the scoring or judgement used to place them higher or lower, and the stakeholder and expert inputs that informed the exercise. Include the final topic list, scope, owner, and approval date.

Formal email template
Subject: Request for materiality assessment evidence for [reporting period]\n\nDear [name/team],\n\nWe are preparing the sustainability report for [reporting period] and need the evidence pack for the topic-ranking exercise. Please share the materials that show:\n- the steps we followed to identify the topics we treat as most important for reporting;\n- how we looked at both downside and upside effects, including effects on people, the environment, the economy, and human rights, across our own operations and wider business links;\n- how we decided which topics were placed higher or lower in the final list; and\n- which stakeholder groups and subject-matter experts informed the process.\n\nPlease include the source files, any scoring or ranking sheets, workshop notes, survey outputs, and the final topic list, together with the period covered, the business areas in scope, the owner, and the date of approval.\n\nIf helpful, you can return the information in the table below. Please adapt this to your organisation’s own terms and check the official source before sign-off.\n\nMany thanks,\n[preparer name]\n[team]
Short Teams / Slack version
Hi [name/team] — could you send over the materiality / topic-ranking evidence for [period]? We need the files showing how topics were identified, scored and prioritised, plus which stakeholders and experts fed into the process. Please include the final topic list, source notes, and the scope covered. Thanks.
Industry examples
Manufacturing

Context. A plant-based group uses a quarterly risk and impact review with operations, HSE, procurement, and site leadership.

Adapted request. Please share the evidence pack from the quarterly issue review for [period], including the workshop notes, scorecards, and final ranked list showing how we identified the issues most important for reporting across our sites and supply chain, and which employee, supplier, and technical voices informed it.

Example response. Attached: Q4 issue review deck, site workshop notes, supplier survey summary, ranked topic matrix, and approval email. Scope: UK plants and tier-1 suppliers. Consulted: site managers, HSE leads, procurement, two supplier panels, and an external technical adviser.

Financial services

Context. A regulated group uses a governance-led annual review with risk, compliance, investor relations, and customer teams.

Adapted request. Please provide the annual issue-prioritisation pack for [period], including the method used to identify and rank the topics we report on, the basis for the ranking, and the investor, customer, employee, and specialist input that shaped the outcome.

Example response. Attached: annual prioritisation paper, risk register extract, customer feedback summary, investor meeting notes, and committee minutes. Scope: group operations and key business relationships. Consulted: customer insight team, investor relations, compliance, and an external policy adviser.

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 the practical steps used to decide which topics matter most, including how impacts were identified, assessed and ranked, and which stakeholder groups and subject-matter experts contributed to the process.

Context note

Set out what the figures and summaries show about the organisation’s most important issues, including the kinds of effects considered and how the final shortlist reflects the areas judged most significant.

Fluctuation statement

If the shortlist or ranking changed from the prior period, explain whether that was driven by new evidence, different stakeholder input, changes in operations or business relationships, or a revised view of significance.

Content index entry
GRI 3-1 Process to determine material topics — [location / page] / [notes]
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Preparation tools & forms

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
The information reported for this disclosure reconciles to the underlying source records.What is reported cannot be traced back to the systems or documents it was drawn from, or does not tie out to them.calculation_workbook reconciling the reported value to source_system_export
The information reported for this disclosure is current as at the reporting date.The disclosure reflects a different period, a cut-off before the reporting date, or stale data carried over from a prior period.approval_record showing the data cut-off date and the period covered
The scope behind the information reported for this disclosure is applied consistently.Parts of the organisation are silently in or out of scope, or the scope differs from the prior period without that change being explained.methodology defining the scope and a site_register of what it covers
Everything in scope is included in the information reported for this disclosure — nothing material is left out.Parts of the population that should be reported are omitted, understating or overstating the disclosure.site_register of the full population vs the calculation_workbook of what was actually included

Evidence pack to prepare

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.
Common gaps

Mistakes to avoid when collecting the data

Wrong owner
The request goes to the wrong team or person, so the process is described by someone who did not actually run the topic review or gather the input.
Framework language instead of business terms
The data is collected using sustainability-framework labels rather than the organisation’s own operational names, which makes the process hard to trace back to how work is really done.
Scope left vague
No one pins down which activities and business relationships are included, so the materiality work ends up covering some parts of the business while missing others.
Timing basis not fixed
The team mixes information from different reporting periods or cut-off dates, so the process description does not match one clear time basis.
Mixed counting basis
Inputs are combined using different ways of counting or grouping, which makes the underlying evidence inconsistent and the prioritisation hard to defend.
Source labels lost
Original file names, interview tags, workshop notes, or other source markers are stripped away, so the team cannot show where each input came from.
Separate groups merged
Views from different stakeholder groups or expert groups are rolled together when they should stay distinct, which hides who said what and weakens the trail.
Evidence metadata missing
The team keeps the content but drops the date, owner, version, or similar context, so the evidence cannot be checked properly later.
No sign-off trail
The final process summary is used without a clear review and approval record, so nobody can show who checked the inputs before publication.

Where judgement is often needed

Acquisitions and disposals during the year
State the cut-off you used for bringing newly bought or sold businesses into the impact review, and explain whether you used opening, closing, or average scope for the period.
Different local definitions for the same issue
If countries or business units use different labels or thresholds, explain the common rule you applied to compare them and how you handled any local exceptions.
Operations near the boundary of control or influence
Explain how you treated sites, joint arrangements, agents, contractors, and other linked parties that sit close to your direct control, and why they were included or left out.
Choosing the timing basis for the review
Disclose whether the assessment was built on year-end data, a rolling view, or another date basis, and note any material events that were brought in or left out because of that choice.
Measured figures versus estimates
Where direct counts were not available, say which figures were estimated, what method was used, and which parts of the review still rely on measured data.
Rounding and small differences
Explain the rounding rule used in the summary and confirm that any rounded figures still reconcile to the underlying totals within a sensible tolerance.
Protecting personal data in stakeholder input
If feedback from workers, communities, or other groups was combined to avoid identifying individuals, say how the information was grouped and whether that aggregation affected the conclusions.
Using internal teams and outside specialists
List the functions, committees, advisers, or other specialists whose views shaped the topic review, and make clear what role each played in the judgement.
Examples

Illustrative examples

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

Illustrative (synthetic) example — Food processing

We ran a materiality review for this synthetic example by mapping our own operations and key suppliers, then screening 18 possible topics through site data, incident logs, customer feedback and a short external scan. We then ranked the topics by the scale, likelihood and reach of their effects, giving priority to the 7 matters with the most significant current or likely effects on our economic, environmental and social impact, including human-rights-related issues in our workforce and supply chain. - Views from 42 people shaped the process: 12 employees, 8 supplier representatives, 6 customers, 4 community members, 4 investors, 2 trade union representatives, 2 NGO specialists, 2 academic advisers and 2 legal experts. - In total, 26 actual or possible effects were logged: 15 negative and 11 positive; 9 related to people and rights, 8 to the environment and 9 to economic outcomes, with 17 arising in our own sites and 9 linked to business partners.

Synthetic illustration only. Shows a plain-language account of the steps used to decide what matters most, the sources used to spot effects across operations and business partners, the basis for ranking them, and the stakeholder/expert input that informed the review.

Illustrative (synthetic) example — Business services

For this synthetic example, we combined a desk review of contracts, complaints, project records and risk registers with workshops across our offices and a check of partner activities to build the longlist of topics. We then narrowed the list to 5 priority matters by comparing the size, chance and persistence of each effect, including both harmful and beneficial outcomes for the business, the environment and people, and any rights-related consequences in our service chain. - The process drew on 31 voices: 10 staff, 5 client representatives, 4 subcontractor contacts, 3 community organisations, 3 investors, 2 human-rights advisers, 2 environmental consultants and 2 sector specialists. - We recorded 20 effects overall, split between 12 negative and 8 positive; 10 concerned people and rights, 5 concerned the environment and 5 concerned economic performance, with 13 traced to our own activities and 7 to relationships with other parties.

Synthetic illustration only. Demonstrates a different plausible reporter using a similar materiality approach, with distinct inputs, a clear ranking basis, and explicit identification of the groups and specialists whose views informed the outcome.

Company reports

How companies report GRI 3-1

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

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 a materiality analysis relevant to the disclosure, with specific values reported on page 56 and references to human rights and business guidelines on page 59. The report highlights material topics such as energy transmission reliability and capacity building, indicating a focus on stakeholder impact and sustainable development goals (p.59, p.71, p.75). However, there is no quotable evidence found for narrative items (a-ii) and (b), suggesting some aspects of the disclosure remain unaddressed or unclear in the report.
PharmaEssentia Corporation
Pharmaceuticals / Biotech / Life Sciences · Taiwan · 2024
Open report →
PharmaEssentia Corporation’s 2024 Sustainability Report covers the identification of material topics, highlighting stakeholder perspectives and human rights impacts from corporate operations as significant factors in determining these topics (p.17). The report details the process of assessing impacts on organizational operations and stakeholder concerns, with references to materiality assessments and management approaches (p.17, p.19). However, the report lacks explicit evidence on certain narrative elements such as item (a-ii) and item (b), which are not found in the document.
GeelongPort
Water Transportation — Ports and Services · Australia · 2025
Open report →
GeelongPort’s Sustainability Report 2025 includes a materiality assessment where impacts on sustainability topics are ranked by stakeholder importance, with eight topics identified and ranked from 1 to 8 (p.17). The report also addresses management of material topics, including potential negative impacts on local communities and cybersecurity, referencing GRI 3: Material Topic 2021 (p.17, p.88). However, no specific information was found regarding narrative item (b), indicating a gap or lack of clarity in that area.
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Check your understanding

Scenarios to work through

A group has run a double-materiality workshop, but the draft report only lists the final topics and a short note that management reviewed them. The team also has interview notes from suppliers, workers and an external labour-rights adviser, plus a scoring sheet for impacts.

QWhat extra explanation should the report include so a reader can see how the topic list was built?
Reveal model answer →

A manufacturer has mapped environmental and labour issues in its factories, but it has not considered distributors, contract logistics providers or outsourced maintenance teams. The draft materiality note says the review covered “our operations” and stops there.

QIs that enough, or does the explanation need to go wider?
Reveal model answer →

A retailer has ranked topics using a scoring model that combines severity and likelihood, but the draft only says the team “used a risk matrix”. The board wants the report to mention every workshop attendee, including junior staff who only joined one session.

QWhat should the report actually make clear about prioritisation and the people consulted?
Reveal model answer →

A services company has identified both negative and positive effects on workers and communities, but the draft report only discusses harms. It also mentions that an external consultant helped, but does not say whether employees, customers or community representatives were consulted.

QHow should the preparer adjust the narrative before sign-off?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 3-1
within GRI 3: Material Topics
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

For GRI 3-1 Material Topics, what should I have ready before I start drafting the disclosure on this page?+
How do I use the GRI 3-1 Material Topics page to turn my materiality assessment into a disclosure draft?+
What evidence should I collect for GRI 3-1 Material Topics so the file is assurance-ready?+
What are the four assurance claims I need to check for GRI 3-1 Material Topics?+
What common mistakes does the GRI 3-1 Material Topics page warn about?+
How should I describe the impact identification method for GRI 3-1 Material Topics in a way that is usable for reporting?+
What does the page mean by the impact ranking basis for GRI 3-1 Material Topics, and how do I use it?+
Who should own the data for GRI 3-1 Material Topics, and how do I assign responsibilities?+
How do I use the Prep & Assurance workbook for GRI 3-1 Material Topics?+
What can I use the printable Library Card PDF for on the GRI 3-1 Material Topics page?+
Are there example disclosures for GRI 3-1 Material Topics on the page that I can use as a model?+
More questions this page can help with
What inputs do I need to gather for GRI 3-1 Material Topics before I write the disclosure?How do I document the materiality process for GRI 3-1 Material Topics in my evidence pack?What should I include in the GRI 3-1 Material Topics evidence pack for assurance review?How do I use the step-by-step how-to-prepare section for GRI 3-1 Material Topics?What narrative starters does the GRI 3-1 Material Topics page give for drafting the disclosure?What visualisation ideas are suggested for GRI 3-1 Material Topics draft output?How do I write the GRI content-index line for GRI 3-1 Material Topics using this page?What are the most common reporting gaps in GRI 3-1 Material Topics and how do I avoid them?How do I use the from company reports table on the GRI 3-1 Material Topics page?Can I use the synthetic quantitative example on the GRI 3-1 Material Topics page as a template for my own data?Does the GRI 3-1 Material Topics page give an exact ESRS, CSRD or ISSB mapping?How do I make GRI 3-1 Material Topics assurance-ready using the workbook and evidence pack?