GRI Materiality Assessment
GRI requires organisations to identify their material topics through a formal materiality assessment process. Under GRI 3 (2021), this process is more rigorous than previous versions — requiring genuine stakeholder engagement and documented justification for all material topic determinations.
GRI requires organisations to identify their material topics through a formal materiality assessment process. Step 1 — Understand the organisation's context: Map your activities, business relationships, and the sustainability context in which you operate.
The four steps of GRI 3-1
Step 1 — Understand the organisation's context: Map your activities, business relationships, and the sustainability context in which you operate.
Step 2 — Identify actual and potential impacts: Identify the actual and potential positive and negative impacts your organisation has on the economy, environment and people across your value chain.
Step 3 — Assess the significance of impacts: Evaluate each impact based on its significance — severity (scale, scope, irremediability) for negative impacts and scale and scope for positive impacts.
Step 4 — Prioritise the most significant impacts: Determine which impacts are sufficiently significant to be material topics for reporting purposes.
Stakeholder engagement in GRI materiality
GRI 3 explicitly requires organisations to engage with affected stakeholders in the materiality process. This is not optional — box-ticking stakeholder surveys do not meet the requirement.
Stakeholders include: employees and worker representatives; communities affected by your operations; suppliers and value chain partners; customers; civil society organisations; investors and shareholders.
The engagement must be genuine — stakeholders must have the opportunity to raise topics that the organisation had not previously identified. If stakeholders raise a topic, you must assess whether it is material and explain your conclusion.
GRI 3 vs old GRI materiality matrix
The 2021 revision eliminated the traditional materiality matrix (importance to stakeholders vs importance to business). This is a significant change.
The old matrix conflated financial materiality (business importance) with impact materiality (stakeholder concern), leading to confusion with ISSB and SASB financial-materiality approaches.
GRI 3 now focuses exclusively on impact significance — how significant are your actual and potential impacts? The stakeholder perspective informs the assessment but does not create a separate axis.
Frequently asked questions
Do we need a formal materiality matrix for GRI?
No — GRI 3 (2021) eliminated the traditional materiality matrix. You need a documented process for identifying and prioritising material topics, but the output format is flexible.
How many material topics should we have?
There is no required number. Some organisations have 5, others have 25. The number should reflect the complexity of your business and the significance of your impacts — not a desire to appear comprehensive.
Can we use our CSRD materiality assessment for GRI?
Yes — the impact materiality dimension of your CSRD double materiality assessment directly satisfies GRI 3-1 requirements. Use your CSRD assessment as the basis for GRI and save significant duplication.