GRI Content Index
The GRI Content Index is a mandatory table listing every GRI disclosure addressed in your report — with page references, omissions, and reasons for any gaps. Without a compliant Content Index, your report cannot claim GRI alignment. Here is exactly how to build one.
The GRI Content Index is a mandatory table listing every GRI disclosure addressed in your report — with page references, omissions, and reasons for any gaps. Every GRI Content Index must include: the GRI disclosure number and title; the location of the disclosure in your report (page number, URL, or section reference); and for any omission — the reason (information unavailable, legal prohibition, confidentiality constraint) and an explanation.
What a compliant GRI Content Index contains
Every GRI Content Index must include: the GRI disclosure number and title; the location of the disclosure in your report (page number, URL, or section reference); and for any omission — the reason (information unavailable, legal prohibition, confidentiality constraint) and an explanation.
For GRI 2021 Standards, the index must also confirm which GRI Sector Standard applies (if any), and list the material topics determined through GRI 3.
The index must cover every Universal Standard disclosure (GRI 2 — all 30 disclosures) and every Topic Standard disclosure for each material topic. A complete index for a medium-sized company typically has 60–120 rows.
Handling omissions correctly
Omissions are permitted under GRI Standards but must be disclosed with a reason. GRI recognises four omission types:
Not applicable: The disclosure does not apply to your organisation (e.g. GRI 2-30 collective bargaining if you have no employees covered by collective agreements).
Information unavailable: You do not currently have the data — commit to collecting it.
Legal prohibition: Local law prevents disclosure.
Confidentiality constraint: Disclosure would cause commercial harm — requires justification.
Assurers and sophisticated stakeholders will scrutinise omissions. A pattern of 'information unavailable' across multiple disclosures suggests a data collection programme that needs investment.
The GRI-ESRS concordance table
GRI and EFRAG jointly publish a concordance table mapping GRI disclosures to ESRS datapoints. This is an invaluable tool for companies reporting both frameworks — it shows exactly where the same underlying data satisfies both a GRI disclosure and an ESRS requirement.
For your GRI Content Index, you can reference ESRS report sections as the location for disclosures that overlap — pointing to your CSRD sustainability report rather than a separate GRI report. This 'report by reference' approach reduces duplication significantly.
The concordance table is available free at globalreporting.org and efrag.org — download the current version as it is updated when ESRS are amended.
Frequently asked questions
Does the GRI Content Index need to be in the sustainability report itself?
No — it can be a standalone document published on your website and referenced from the report. Many companies publish their sustainability report as a PDF and the Content Index as a separate webpage or Excel file for easier navigation.
Can we claim GRI alignment without third-party verification of the Content Index?
Yes — GRI alignment does not require external verification. You can self-declare GRI alignment by publishing a compliant Content Index. Third-party verification of the Content Index is optional and provides additional credibility.
What is the difference between 'GRI-aligned' and 'GRI-compliant'?
GRI uses the terms 'with reference to GRI Standards' (partial use) and 'in accordance with GRI Standards' (full compliance with all mandatory requirements). The latter requires complete coverage of GRI 2 and GRI 3 plus all material topic standards. Most large companies target full 'in accordance with' status.