The completion of the GRI Standards' new Climate Change Standard (GRI 102) and Energy Standard (GRI 103) marks a milestone in strengthening corporate accountability for climate action. These standards provide a comprehensive framework that reflects the latest science and is aligned with the Paris Agreement.

The GRI is a disclosure framework that emphasizes "impact materiality," focusing on an organization's impact on the economy, the environment, and people. The latest revision places particular emphasis on how climate change measures should take into account not only environmental and financial profits, but also social aspects.

This article explains the specific disclosure requirements and practical considerations that will help practitioners effectively comply with these new standards.

Positioning and application rules of GRI 102/103 (practical requirements)

When complying with the GRI Standards, it is important to understand the required level of disclosure.

• Shall: Items that must be complied with as requirements
• Should: This is a recommended item.
• Can: Indicates possibility or choice.

The basis for compliance with the GRI Standards is for practitioners to ensure that they comply with requirements that begin with "shall." *1

Additionally, as a GRI compliance rule, if it is difficult to disclose a specified material (important) Issue, it is permitted not to disclose it by stating the reason for omission. However, there is a condition that sufficient information should be provided to enable stakeholders to determine the impact related to this material Issue. *2

Climate Change Standard GRI 102: Transition Planning and Just Transition Disclosure Requirements

A major feature of GRI 102 is that it restructures existing standards and requires disclosure of transition plans for both "mitigation" and "adaptation."

Transition Planning for Mitigation (GRI 102-1)

Disclosures regarding mitigation plans should cover the following elements:

Adaptation Plan (GRI 102-2)

Disclosure of adaptation plans requires not only the description of climate-related financial risks and opportunities (areas covered by TCFD, IFRS S, and SSBJ), but also the impacts that will arise from those risks and their responses. This reflects the dual structure of GRI, which places emphasis not only on financial materiality but also on impact materiality.

As with mitigation plans, organizations must also disclose the scenarios, methodologies, expenditures, and responsible organizations used, as well as how they will assess and manage the impacts of implementing their adaptation plans on people and the environment.

Measuring Just Transition (GRI 102-3)

A "Just Transition" is the idea that the transition to a low-carbon economy should be carried out while simultaneously taking into account the impact on people, such as workers, local Community, and indigenous peoples, as well as the environment and biodiversity.

To help practitioners translate this principle into transition plans, GRI 102-3 requires disclosure of the following specific labor-related indicators:

• Number of New employees hired for transition and adaptation
• Number of employees whose contracts have ended (reductions in staff)
• Number of rehired employees
• Number of employees who have received skill-upgrading and risk-rescue training
• For the above items, also state the number of non-employee workers (such as contract workers).

In addition, they must assess the impact of implementing their transition plans on people, the environment and biodiversity, and disclose measures to mitigate those impacts.

GRI 102 Technical Disclosure Requirements for GHG emission amount, Removals, and Credits

Disclosure of GHG emission amount is in accordance with the GHG Protocol and requires substantial alignment with the latest standard (SBTi's Corporate Net Zero Standard).

GHG emission amount target (GRI 102-4)

• Target Settings: Disclose short-, medium-, and long-term reduction targets in absolute emission amount and relative to the base year. Targets must demonstrate alignment with 1.5°C and be substantially SBTi compliant.
• Separation of scope: You have the option to report Scope 1, 2 and 3 separately or to combine Scope 1 and 2 targets.
• Scope 3 disclosure: Provide detailed information on which categories (15 categories) are included and in what quantities.
• Progress analysis: Analyze and disclose whether reductions are the result of your own efforts or other external factors.

Points to note when calculating emission amount(GRI 102-5, 102-6)

• What is not included: When calculating GHG emission amount, GHG removals, GHG trading (offset such as carbon credits), and avoided emissions are not included.
• Biogenic CO2: Biogenic CO2 emission amount , which are typically treated as "zero emission amount ", must also be reported separately.
• Emission intensity: Indicates the emission amount per unit. The denominator (product unit, revenue, sales, etc.) is determined by the organization, but evidence must be provided.
• Factors and methodology: The criteria, methodology, calculation tools and source of the factors used must be stated.

GHG Removal and Carbon Credits (GRI 102-9, 102-10)

When organizations use GHG removals or carbon credits, they are required to be highly transparent.

Energy Standard GRI 103: Supply Chain Measurement Requirements

GRI 103 is based on accurate disclosure of the Energy figures that form the basis for calculating GHG emission amount .

• Energy Policy: Disclose policies and commitments regarding consumption reduction, Energy efficiency and transition to renewable Energy.
• Consumption Breakdown: Disclose total fuel consumption with a detailed breakdown by renewable and non-renewable sources.
• Significant Value Chain Consumption: Disclose the total amount of Energy Energy of the entire upstream and downstream value chains.
• Intensity indicator: As with GHG, the amount of Energy per unit (Energy intensity) is calculated and disclosed.
• Factors behind reduction: Clarify and disclose whether the reduction is due to the company's own efforts or external factors.

Alignment with ISSB/ESRS/ TCFD

GRI 102/103 was developed with an awareness of consistency among global disclosure standards, and practitioners will be able to report more efficiently by understanding its relationship with other major standards.

• GHG Protocol / SBTi: GRI 102's emission amount disclosure framework is based on the GHG Protocol, and Settings are required to be substantially closer to SBTi compliance (aligned with 1.5°C).
• IFRS S2: GRI (Impact Disclosure) and IFRS S (Risk and Opportunity Disclosure) have agreed in a Memorandum of Understanding (MOU) that they can disclose the same figures to each other.
• SSBJ (Japan): GRI's GSSB has also signed an MOU with SSBJ, agreeing to jointly Create guidance for disclosure, using impacts, risks, and opportunities interchangeably.
• CSRD/ESRS (Europe): The European disclosure standard, ESRS, was Create with reference to the GRI Standards in part, and the data points are mapped in a manner that is almost identical.

Application period and practical points

The new GRI 102/103 standards will officially come into effect on January 1, 2027, but early adoption is encouraged. They have already been translated into Japanese and are available for download from the GRI website.

Climate change is no longer a "sideshow" but a "daily headline," and companies are being called upon to be transparent and accountable for their environmental impact. GRI 102/103 will be a catalyst for generating robust, decision-useful data for this purpose. It is important for practitioners to quickly review the specific disclosure items of the new standards (especially transition plans, just transition, and detailed emission amount management) and clarify the calculation methodology.

<Reference source>
・GRI (Global Reporting Initiative) Official Japanese Standards https://www.globalreporting.org/how-to-use-the-gri-standards/gri-standards-japanese-translations/
*1 "GRI 3: Material Topics 2021"
*2 “GRI 1: Basics 2021”
• GRI "GRI Topical Standards Project on Climate Change and Energy"
https://globalreporting.org/standards/standards-development/topic-standard-for-climate-change-and-energy/
• GRI "Purpose of Revision"
https://globalreporting.org/media/rtbcu3ba/gri-topic-standards-for-climate-change-final-project-proposal.pdf