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GRI 207: Tax · 2019

Disclosure GRI 207-3

Stakeholder engagement and management of concerns related to tax

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 LRA educational guidance · Not issued or endorsed by GRI

To prepare this disclosure

4datapoints↓ 4claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain how it engages with stakeholders on tax matters and how it handles concerns or complaints that arise. In practice, the focus is on whether there is a clear process for listening to relevant parties, recording issues, and responding to them in a consistent way, rather than simply saying that tax is managed internally.

The practical question is how far this approach applies across the organisation. Report whether the process covers the whole business, relevant subsidiaries, and material jurisdictions, or only selected teams or flagship sites. The emphasis is on showing the scope of the engagement and concern-management process, and whether it is embedded enough to deal with tax-related issues wherever they arise.

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.

Have you decided which parts of your tax-related engagement story you will cover: dealings with tax authorities, public policy activity on tax, and how you gather and weigh outside views and concerns? Can you point to the internal source for each part of that story, so the wording you draft is traceable back to a policy, process note, or other record? Have you settled which stakeholder groups count for this disclosure, including external parties, and which concerns about tax will be treated as in scope? Do you know the basis and period your description will use, so the account matches the reporting year and the way your organisation actually operates? Have you agreed the working definitions you will use for terms like tax authorities, public policy advocacy, and stakeholder concerns, so the same meaning is used throughout?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Tax stakeholder approach A plain summary of how the organisation engages people and groups affected by its tax position, and how it handles tax-related concerns when they arise. Tax policy or governance papers, stakeholder engagement notes, issue logs, and any documented responses to tax concerns. Tax / Finance

Tax authority engagement How the organisation deals with tax authorities in practice, including the main channels, timing, and any routine or significant interactions. Correspondence with tax authorities, meeting notes, filing records, and internal tax compliance or controversy files. Tax / Finance

Tax lobbying approach How the organisation handles public policy activity on tax, including who is involved, what is covered, and how such activity is controlled or approved. Public affairs or government relations policy, lobbying registers, approval logs, and disclosures of tax-related policy positions. Public Affairs / Legal

Stakeholder feedback process The steps used to gather, review, and respond to views and concerns from stakeholders, including people outside the organisation. Consultation records, survey outputs, grievance or feedback logs, meeting minutes, and documented follow-up actions. Sustainability / Corporate Affairs

＋ Show GRI 207-3 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which parts of the business, which countries, and which tax-related activities will be covered in the write-up so the account is consistent across the disclosure.

2Define the topics you will treat as in scope: separate the organisation’s handling of tax-related stakeholder concerns, its dealings with tax authorities, its public positions on tax policy, and the way it gathers and weighs stakeholder views.

3Gather support for each part of the narrative: pull together internal policies, meeting records, correspondence, consultation notes, escalation logs, and any other material that shows how the approach works in practice.

4Draft the disclosure in plain language: explain the organisation’s method for engaging stakeholders on tax, how concerns are managed, how views are collected and assessed, and what the approach is with tax authorities and with public policy advocacy on tax.

5Record any gaps, exclusions, or changes in method: note where information is unavailable, where a topic is not relevant, or where the process has changed during the period, and explain the reason clearly.

6Check the final text against the source material: confirm that every required element is covered, the wording matches the underlying evidence, and nothing has been added, omitted, or overstated.

Request the data

Request the tax engagement and concerns log

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

How do we engage on tax matters, and how do we capture, review, and respond to stakeholder concerns about tax?

Use your organisation’s own terms first, then map them to this disclosure. For example, if you talk about HMRC, tax authority contacts, policy positions, issue logs, grievance channels, or external feedback in different ways, keep those internal labels in the request and only translate them at the reporting stage. Adapt this to your organisation and check the source disclosure before sign-off.

Weak request

Please provide the GRI 207-3 evidence showing stakeholder engagement and management of concerns related to tax, including the approach to engagement with tax authorities, public policy advocacy on tax, and the process for collecting and considering stakeholder views.

Why it fails: This uses framework language that may not match how the team works day to day, so the owner may not know which files, logs, or meetings to pull. It also bundles several topics without telling them what internal records count as evidence or what period and boundary to use.

Better request

Please send the tax team’s own records for [period] that show: how you handle contact with tax authorities; any tax policy or consultation work; and how you capture, review, and respond to outside views or concerns about tax. Include the relevant logs, notes, submissions, meeting records, or trackers, and note the entity in scope, source file, date, and outcome for each item. Use your internal labels; we will map them later. Please adapt this to your organisation and check the source disclosure before sign-off.

Formal email template

Subject: Request for tax engagement and concerns evidence for [reporting period]

Hello [name],

We are preparing the sustainability reporting pack for [reporting period] and need your help with the tax engagement and concerns evidence.

Please share, for the entities and activities in scope:
- a short description of how the tax team engages with external counterparties on tax matters;
- a short description of how the organisation handles external views or concerns about tax;
- any records that show engagement with tax authorities;
- any records that show public policy or consultation activity on tax;
- any process notes, logs, trackers, or examples showing how stakeholder views are collected, reviewed, and acted on.

Please use your team’s own wording and file names where possible. If you use different internal labels, that is fine — we will map them later.

A possible LRA training template for the return is attached. Please adapt this to your organisation and check the source disclosure before sign-off.

Could you send the completed pack by [date]? If anything is not available, please note the gap and the reason.

Thank you,
[preparer name]

Short Teams / Slack version

Hi [name] — could you send over the tax engagement / concerns evidence for [period]? We need your team’s own logs, notes, or examples showing how you deal with tax authority contact, policy/consultation activity, and external feedback or concerns about tax. Use your internal terms; we’ll map them later. Please share by [date].

Industry examples

Consumer goods

Context. A group tax team manages tax authority correspondence, consultation responses, and issue tracking across several countries.

Adapted request. Please share the group tax logs and supporting files for [period] showing contact with tax authorities, any consultation or policy submissions on tax, and the process used to capture and resolve external concerns about tax. Use your own team labels for the logs and topics.

Example response. A spreadsheet listing 14 records across 6 entities, with dates, counterparties, topic labels, status, outcomes, and links to meeting notes, submission drafts, and approval emails.

Infrastructure / utilities

Context. A regulated business has a small tax function that records regulator and authority interactions, plus community and investor questions about tax.

Adapted request. Please provide the tax engagement tracker, correspondence file, and any notes showing how external questions or concerns about tax were reviewed and handled during [period]. Include authority meetings, policy consultation activity, and the outcome of each issue.

Example response. A folder index with 9 items: 3 authority meetings, 2 consultation responses, 2 stakeholder queries, and 2 closed issues, each with date, owner, summary, and resolution status.

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

This section can explain which stakeholder groups were included, what counted as a tax-related concern or policy input, and how the organisation gathered, reviewed and recorded those views.

Context note

These figures describe the organisation’s approach to listening on tax matters, including how it engages with authorities, handles concerns and takes part in policy discussions.

Fluctuation statement

If the pattern changed from the prior period, the reporter can note whether that was driven by a wider set of stakeholders, a different engagement route, or a change in how concerns were collected and assessed.

Content index entry

GRI 207-3 Stakeholder engagement and management of concerns related to tax — [location / page] / [notes]

Download Centre

Preparation tools & forms

Professional preparation tools for GRI 207-3 — 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

01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We said how we handle tax-related concerns raised by people who may be affected, and how those concerns are taken into account in our reporting.An assurer will check whether the statement is supported by a real process rather than a general narrative, and whether the report overstates the extent to which concerns were actually gathered or acted on.Stakeholder engagement logs, issue trackers, meeting notes, correspondence records, internal summaries of concerns, and the draft-to-final reporting trail showing how concerns were reflected in the disclosed figure or narrative.

We explained our usual way of dealing with contact from tax authorities, based on the process we actually use in practice.An assurer will probe whether the described approach matches day-to-day practice, whether it covers the relevant entities and periods, and whether any exceptions or escalations were omitted.Tax authority correspondence, case files, response templates, escalation procedures, meeting minutes, and evidence that the described process was followed for the period covered by the report.

We set out how we handle public-facing policy activity on tax matters, using the approach we applied during the reporting period.An assurer will test whether the description is complete and consistent with internal approvals, and whether advocacy activity was omitted, misclassified, or described more broadly than the evidence supports.Public affairs records, policy position papers, approval workflows, lobbying registers where applicable, communications logs, and internal sign-off showing the disclosed approach matches actual activity.

We described the steps we use to gather outside views and internal feedback, and how those inputs are weighed before the report is published.An assurer will look for evidence that the collection process was real, that relevant groups were included, that feedback was reviewed rather than ignored, and that the final wording reflects the underlying records.Consultation records, survey results, workshop notes, emails, feedback summaries, response matrices, internal review notes, and publication checks showing how inputs were considered and incorporated.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes 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.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The request goes to the tax team alone, even though the needed input sits with public affairs, investor relations, legal, or the local business lead.

Framework language only

People ask for input using disclosure labels instead of the organisation’s own terms, so teams cannot recognise what evidence is being sought.

Scope left vague

The data pull does not define which business units, countries, or stakeholder groups are in scope, so different teams report different populations.

Period basis mixed up

One team uses the reporting year while another uses calendar-year records or a different cut-off date, which makes the dataset inconsistent.

Counting basis not aligned

Some contributors count individual contacts, others count meetings or issues, and the final file blends unlike measures without a clear basis.

Source labels stripped out

Original file names, case IDs, meeting references, or log labels are removed during collation, so the trail back to the source is lost.

Separate groups merged

Input from tax authorities, policy advocacy, and wider stakeholder feedback is merged into one bucket even though each needs to stay distinct.

Evidence details missing

The pack contains the answer but not the supporting metadata, such as who supplied it, when it was captured, and which source record it came from.

No sign-off trail

Draft figures move forward without a named reviewer and approval record, so nobody can show who checked the data before it was used.

Where judgement is often needed

Group perimeter after a deal closes

If a business is bought or sold during the year, explain whether the write-up covers only the period and entities you controlled at the reporting date, or also includes earlier/later activity, and say how you handled any partial-year change.

Different tax labels in different countries

Where local teams use different names or categories for the same kind of tax discussion, map them to one internal description and disclose that mapping so readers can see what was included.

Which voices count as stakeholders

Set out whether you included only external parties or also internal groups that feed into the process, and explain any cut-off used for people or bodies close to the boundary of the topic.

How to treat informal contact with tax authorities

Decide whether routine queries, audits, advance discussions and other contact channels are all part of the same engagement story, then describe the scope you used and any exclusions.

How to treat policy input on tax

If your organisation speaks to public bodies or industry groups on tax matters, explain which activities you treated as policy input, how you separated them from operational tax dealings, and why.

Using estimates where records are incomplete

When some sites or countries cannot provide full detail, use a clear estimate method, state that it is an estimate, and explain the basis so the reader can judge its reliability.

Combining sensitive feedback into one summary

If comments or concerns could identify a person, team or location, group them at a level that protects privacy and say how you aggregated them while still showing the main themes.

Timing of the engagement narrative

Choose a consistent cut-off date for the year, then note any late-arriving concerns or follow-up actions that were known before sign-off but occurred after the main reporting period.

Rounding and small-number presentation

If you summarise counts of meetings, concerns or responses, apply one rounding rule across the report and explain it where small totals could otherwise be misleading.

Examples

Illustrative examples

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

Illustrative (synthetic) example — Retail and consumer goods

*Synthetic illustration only.* We run a tax engagement process that starts with a simple issue log, then routes material concerns from employees, suppliers, investors and community contacts to the finance lead and the audit committee, with 14 concerns recorded this year and 14 closed out or still being tracked. We also keep a standing contact channel with tax authorities, using scheduled meetings and written follow-ups for 6 matters during the year, and we set out our position on tax in public consultations and trade-group submissions when policy changes could affect our business. To gather views, we use surveys, supplier calls, investor meetings and a whistleblowing route; 240 stakeholders were approached, 178 responded, and 92% of responses were reviewed and fed into our tax risk and policy decisions.

This example shows how a reporter can describe the practical steps used to hear concerns, deal with them, stay in touch with tax authorities, and explain how it takes part in tax policy discussions. The figures are synthetic and internally consistent.

Illustrative (synthetic) example — Transport and logistics

*Synthetic illustration only.* Our group handles tax-related concerns through a central case tracker, with issues raised by employees, customers, lenders and local community representatives reviewed by the tax manager and escalated to the board risk committee when needed; 9 concerns were logged and all 9 were assessed, with 7 resolved and 2 still open at year-end. We maintain regular contact with tax officials through compliance meetings, clarification requests and response letters, covering 11 interactions in the period, and we take part in public debate on tax through consultation responses and industry association work where the topic affects our operations. Stakeholder views are collected through town-hall sessions, supplier forums, investor briefings and an ethics hotline; 126 people or organisations were invited to share views, 101 did so, and 84% of the feedback was considered in our tax planning and control updates.

This example illustrates a different reporter using a similar disclosure pattern: how concerns are captured and handled, how the business engages with tax officials, how it contributes to policy discussion, and how outside views are gathered and used. The numbers are made up for training purposes and remain internally consistent.

Company reports

How companies report GRI 207-3

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

Hero MotoCorp Limited

Automobiles and Components · India · 2025

Open report →

Hero MotoCorp Limited’s 2024-25 sustainability report provides a covered narrative on its approach to stakeholder engagement, including a list of GRI indicators assured on a limited basis (p.163), and details on policy commitments related to business ethics with specific references to embedding these policies and processes (p.167). Partial information is available on the company’s tax policy and approach, with supporting context but no headline values (p.138), as well as on stakeholder engagement mechanisms and understanding stakeholder concerns, though without explicit headline data (p.28). The report does not clearly present comprehensive headline values for tax or stakeholder engagement metrics, indicating some gaps in quantitative disclosure.

CJ Cheiljedang Corporation

Food Production — Agricultural · South Korea · 2024

Open report →

CJ Cheiljedang Corporation’s Sustainability Report 2024 includes coverage of policy commitments and embedding these commitments, with relevant information found on pages 56-57, 63, 67-68, 79, and 88, and processes detailed on pages 23-25, 41-46, 56-57, 79-80, and 93-95 (p.116). The report also addresses stakeholder engagement and management of concerns related to tax on page 119. However, there is no clear evidence or quotable information regarding the methodology or narrative for item (a-i), nor is there any found for item (a-iii), indicating gaps in these specific areas.

Bangchak Corporation Public Company Limited

Oil and Gas · Thailand · 2025

Open report →

Bangchak Corporation Public Company Limited’s Integrated Sustainability Report 2025 provides a reported value related to stakeholder engagement and management of tax concerns on page 213, referencing pages 81-83 for detailed discussion (p.213). The report partially covers the company’s tax policy context on page 81, highlighting transparency, fairness, and value creation for stakeholders, but does not provide headline values or complete narrative for all sub-items, with no evidence found for narrative item (a-iii) (p.81). Overall, while the report addresses tax governance and stakeholder engagement in tax matters, some specific details and headline figures remain unclear or missing.

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Check your understanding

Scenarios to work through

A group finance team has a standing quarterly call with the tax authority, but the draft disclosure only says the team 'keeps in touch with regulators'. Separately, the company has a public position paper on tax lobbying that was approved by the board last year.

QHow should the preparer separate these two strands so the disclosure clearly covers both the way the company deals with tax authorities and its stance on tax-related policy lobbying?

Reveal model answer →

A sustainability manager has collected comments from investors and a local community group about the company’s tax transparency, but the tax team has not logged how those comments were reviewed or what changed as a result. The draft report only mentions that feedback was 'heard'.

QWhat should the preparer check before finalising the disclosure about how stakeholder views and concerns are gathered and taken into account?

Reveal model answer →

The tax function has a complaints inbox for suppliers and NGOs, while the legal team separately handles whistleblowing matters. In the draft, both are grouped under 'stakeholder concerns', even though only the supplier and NGO feedback relates to tax matters.

QHow should the preparer decide what belongs in the tax-related concerns section and what should stay out?

Reveal model answer →

A group has a formal engagement calendar with tax authorities in three countries, but one smaller market only has ad hoc contact when a query arises. The draft says the company has a 'standard global engagement model' without explaining the difference.

QWhat judgement should the preparer make about whether the disclosure needs to reflect variation in how engagement is handled across locations?

Reveal model answer →

Framework references