ESG Reporting and Disclosure
Branch Foundation + Level 1 — Standards Architecture · GRI Application · ISSB S1 and S2 · EU Taxonomy

This unit covers the governance and legal architecture of each framework, establishing the authority behind each standard and the basis on which it creates disclosure obligations. GRI is produced by the Global Sustainability Standards Board (GSSB); GRI Standards are voluntary by default but have been incorporated by reference into mandatory frameworks in over 40 jurisdictions. ISSB standards are produced by the IFRS Foundation and become mandatory upon adoption by jurisdictional authorities. CSRD and ESRS are EU law and delegated acts, making them mandatory for in-scope entities with no opt-out. CDP is a registered charity operating a disclosure platform; CDP disclosure is voluntary for most companies but becomes commercially obligatory through supply chain member requirements.

The unit covers the interaction between frameworks when multiple apply simultaneously: the legal hierarchy, the interoperability provisions, and the commercial relationship logic. For an EU-listed company also subject to ISSB adoption requirements in a secondary jurisdiction and with major supply chain buyers requiring CDP disclosure, this hierarchy logic provides the foundation for the efficiency planning exercise in Unit B2.5.

This unit examines the operational application of materiality concepts across the four frameworks, building on the conceptual distinction introduced in F1. The comparison covers how each framework defines the starting population of potential topics, how the assessment process is conducted, and how the materiality determination controls what is disclosed. The unit works through a numerical example using a food and beverage company to illustrate how the same topic — packaging waste — receives different materiality determinations under each framework: material under GRI because of significant impact on waste generation; material under CSRD from both dimensions because of impact on ecosystems and financial risk from circular economy regulation; material under ISSB only if packaging-related regulatory costs are financially significant; and potentially surfacing in CDP through the supply chain engagement section.

This unit covers the GHG Protocol alignment of each framework and the assurance standards applied to disclosures under each — two dimensions where divergence creates practical compliance challenges. All four frameworks reference the GHG Protocol Corporate Standard for Scope 1 and 2, but they diverge in specific requirements: ESRS E1 requires both location-based and market-based Scope 2; ISSB S2 requires disclosure of the methodology used to calculate Scope 3 without mandating all 15 categories; GRI 305 requires disclosure of the 15 categories relevant to the organisation; CDP requires disclosure of all 15 categories at Leadership level with verification status for each. The unit maps these divergences into a specific data requirements comparison, identifying where a single calculation satisfies all frameworks and where additional steps are required. The assurance standards comparison covers ISAE 3410, ISAE 3000, and their practical implications for organisations preparing for CSRD sustainability statement assurance.

This unit covers three structural dimensions of the comparison matrix where frameworks diverge in ways that directly affect how disclosure practitioners approach their work. Forward-looking disclosure treatment covers targets, projections, transition plans, and scenario analysis outputs: CSRD and ESRS are the most demanding (requiring climate transition plans with investment and capex plans), followed by ISSB S2 (requiring forward-looking financial impact analysis), GRI (permitting but not requiring forward-looking targets), and CDP (requiring targets with science-based ambition evidence at Leadership level). Connectivity between sustainability and financial reporting is treated differently across frameworks — the IIRC connectivity principle, the ESRS requirement to disclose how sustainability risks affect financial statements, and GRI's focus on impacts rather than financial connectivity. The boundary treatment comparison covers the entity versus consolidated group question across all four frameworks.

This unit applies the comparison matrix to a structured decision tree exercise and a disclosure efficiency planning task. The decision tree guides a practitioner through a series of questions for a given entity: Is CSRD mandatory? Has the entity's primary listing jurisdiction adopted ISSB? Does the entity have institutional investor or lender requirements for TCFD-aligned disclosure? Does the entity have supply chain buyer requirements for CDP? Does the entity use GRI for voluntary stakeholder communication? The efficiency planning exercise uses the decision tree output to produce a data collection and analysis schedule that sequences activities to minimise duplication — identifying single-source activities that serve all applicable frameworks, multi-source activities that serve two or three frameworks with adaptation, and single-framework-only activities. The capstone deliverable is the completed comparison matrix, the decision tree output for the assigned entity profile, and the disclosure efficiency plan.

This unit maps the three-tier GRI Standards architecture introduced in 2021. GRI 1 (Foundation) establishes the reporting principles — accuracy, balance, clarity, comparability, completeness, sustainability context, timeliness, and verifiability. GRI 2 (General Disclosures) covers the organisational profile, governance, strategy, policies, stakeholder engagement, and reporting practice disclosures that apply to all reporting organisations. GRI 3 (Material Topics) covers the process for determining material topics and the requirement to disclose the list of material topics with explanation of how they were determined. The unit also covers the Sector Standards — a key innovation of GRI 2021 that identifies topics likely to be material for organisations in specific industries — and the Topic Standard structure covering the distinction between management approach disclosures and topic-specific metric disclosures.

This unit covers the GRI 3 material topics process in operational detail, working through the three steps with a case organisation in the manufacturing sector. Step 1 (understanding context) maps activities, business relationships, and the broader sustainability context. Step 2 (identifying impacts) builds a comprehensive list of actual and potential impacts across the value chain. Step 3 (assessing significance) applies GRI's significance assessment criteria: scale, scope, irremediability, and likelihood. The unit emphasises the practical distinction between Step 2 and Step 3 — Step 2 should cast a wide net without prejudging significance, as pre-filtering in Step 2 results in an incomplete universe of potential topics and a materiality determination that misses material topics.

This unit covers the topic boundary analysis required by GRI 1 and GRI 3, identifying where each material impact occurs: within own operations, upstream in the supply chain, downstream in product use and end-of-life, or in the affected community. The boundary analysis is documented in the material topics table in the GRI Content Index and drives both the scope of data collection and the scope of disclosure for each topic. The unit also covers the GRI 2 stakeholder engagement disclosures (GRI 2-29 and GRI 2-30) and governance disclosures (GRI 2-9 through 2-21), connecting to Track 1 Module 3.4 (engagement programme design) and Track 1 Module 3.3 (Board ESG Oversight Architecture).

This unit covers the application of GRI Topic Standards across the three categories, working through the disclosure requirements for six topic areas most commonly identified as material across a broad range of industries: GRI 305 (Emissions), GRI 302 (Energy), GRI 403 (Occupational Health and Safety), GRI 401 (Employment), GRI 405 (Diversity and Equal Opportunity), and GRI 205 (Anti-corruption). For each Topic Standard, the unit covers the management approach disclosures and the topic-specific metric disclosures, using the case organisation's data for continuity with the materiality and boundary work. The unit also maps the specific GRI disclosures that contribute to ESRS E1, E2, E3, S1, and G1 disclosures, providing a practical reference for organisations preparing both GRI-aligned voluntary disclosure and CSRD-mandatory disclosure.

This unit covers the preparation of the GRI Content Index — the navigation document that maps each GRI disclosure to the location in the sustainability report where it appears. The Content Index must include: the GRI 1 version used, a statement of use, each applicable GRI 2 disclosure with its location or omission reason, and each Topic Standard disclosure for each material topic. The unit covers format requirements and the treatment of partially reported disclosures. Disclosure omissions receive detailed treatment because they are one of the most frequently mishandled elements of GRI reporting — GRI Standards permit omissions only for legal prohibition, serious competitive harm, or information genuinely not available. The capstone deliverable is a complete GRI Content Index for the case organisation, including all applicable disclosures, location references, and any documented omissions with full explanatory text.

This unit covers the IFRS S1 general framework that governs all ISSB disclosures. IFRS S1 establishes that an entity must disclose information about all sustainability-related risks and opportunities that could reasonably be expected to affect the entity's cash flows, access to finance, or cost of capital over the short, medium, or long term. The materiality threshold is investor-oriented financial materiality — information is material if omitting or misstating it could influence the decisions of primary users of general purpose financial reports. Connected reporting is a central IFRS S1 requirement: sustainability-related financial disclosures must be made together with the financial statements, accessible at the same time, and connected in the sense that estimates, assumptions, and data used in sustainability disclosures are consistent with those used in financial statements. The unit covers the practical implications of this consistency requirement through a worked example.

This unit covers the preparation of the ISSB S2 governance disclosure, addressing board oversight and management responsibility for climate-related risks and opportunities. ISSB S2 paragraphs 6 through 9 require disclosure of: the governance body or individual responsible for oversight; how that body is informed about climate matters; how the governance body oversees target-setting and monitors progress; and the management role in assessing and managing climate risks, including reporting lines to the governance body. The unit maps both the alignment and the divergences between these requirements and the ESRS E1-GOV and ESRS 2 governance disclosures. It works through a governance disclosure draft using the board committee structure from Track 1 Module 3.3 as organisational context, ensuring practitioners who have designed board oversight architecture find direct application in this drafting work.

This unit covers the preparation of the ISSB S2 strategy disclosure — the most substantive section of an ISSB S2 report. The strategy section requires disclosure across four elements: the climate-related risks and opportunities identified over defined time horizons; the effects on business model and value chain; the effects on financial position, performance, and cash flows (current and anticipated); and the climate resilience of the entity's strategy as assessed through scenario analysis using at least two climate scenarios, one of which must be consistent with a 1.5 degree Celsius global average temperature increase. The unit covers what constitutes an adequate scenario analysis for ISSB S2 disclosure purposes at the Disclosure Analyst level, distinguishing the minimum requirement from the more sophisticated quantitative approaches covered in Track 5 Module 2.1 and Track 4 Module 2.3.

This unit covers the ISSB S2 risk management disclosure and the cross-industry metric disclosures required under paragraphs 29 through 37. The risk management disclosure describes the processes for identifying, assessing, prioritising, and monitoring climate risks and opportunities and how these processes are integrated into the entity's overall risk management framework. The cross-industry metric disclosures cover five categories: GHG emissions (absolute gross Scope 1, 2 market-based, and 3 in CO2e with methodology and consolidation approach), transition risk metrics (percentage of assets or business activities vulnerable to transition risks), physical risk metrics (percentage of assets or activities in locations subject to acute or chronic physical risks), climate-related opportunities metrics, and capital deployment metrics. The unit works through the calculation and disclosure format for each metric category using the case company's data from the GHG inventory exercises in F2 and Track 1 Module 2.1.

This unit covers ISSB S2's industry-based metric requirements, which draw on SASB Standards to provide sector-specific performance data relevant to investors. The metric selection process covers the case company's GICS classification, with three to five illustrative metric disclosures covering their data requirements and presentation formats. These are additional to, not substitutes for, the cross-industry metrics from Unit 1.2.4. The ISSB-ESRS interoperability mapping covers the official interoperability analysis published by the IFRS Foundation and EFRAG, identifying: ISSB S2 requirements that an ESRS-compliant entity can satisfy through ESRS disclosures (typically with minor reformatting), those where ISSB requires additional data points not covered by ESRS, and those where ESRS requires disclosures that go beyond ISSB requirements. The capstone deliverable is a complete ISSB S2 disclosure draft covering all four pillars for the case company, with the interoperability mapping table.

This unit covers the EU Taxonomy regulatory architecture: the Taxonomy Regulation (EU 2020/852), the Climate Delegated Act (covering climate change mitigation and adaptation objectives), the Environmental Delegated Act (covering the remaining four objectives), and the Article 8 Delegated Regulation (covering disclosure requirements for undertakings subject to NFRD and CSRD). The unit maps the NACE code system used to classify economic activities and explains how Taxonomy activity descriptions relate to NACE codes, noting that they do not map one-to-one and that professional judgment is required when a company's specific activity falls between activity descriptions. The eligibility determination exercise works through the NACE mapping and activity description matching process, covering enabling activities, transitional activities, and the EU Platform on Sustainable Finance's practical guidance on activity eligibility.

This unit covers the substantial contribution technical screening criteria for climate change mitigation — the most commonly assessed objective for manufacturing, real estate, and transportation companies. The criteria use a combination of technology-specific thresholds (such as lifecycle GHG emissions thresholds for defined activity types) and technology-neutral thresholds based on comparison to sector benchmarks. The unit covers the assessment methodology for three case activities: a manufacturing electrification CapEx (assessing electricity source against the low-carbon energy threshold), a real estate renovation (assessing the building's energy performance against primary energy demand thresholds), and a fleet electrification (assessing vehicle GHG emission performance against automotive thresholds). Evidence requirements for each threshold test are covered in detail — energy performance certificates, lifecycle assessment reports, grid emission factor documentation, and technical specification documents.

This unit covers the DNSH assessment for the six environmental objectives across all three case activities. The Taxonomy's Delegated Acts specify the DNSH criteria for each activity for each objective. The unit works through the full DNSH assessment matrix: for each case activity, it identifies the applicable DNSH criteria for each of the five non-contributing objectives, assesses compliance, and specifies the evidence required. The most complex DNSH assessments involve the biodiversity and ecosystems objective (requiring site-level assessment of impacts on protected areas and species) and the pollution prevention objective (requiring assessment of emissions of hazardous substances). The unit covers the DNSH compliance file structure — the evidence package required to demonstrate all DNSH criteria are satisfied — and addresses the practical situation where full documentation is not available and a gap analysis approach must be taken.

This unit covers the Minimum Social Safeguards (MSS) requirement, which applies at the company level rather than the activity level. MSS requires compliance with OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, ILO core conventions, and applicable national anti-corruption and tax transparency requirements. The unit covers the risk-based assessment methodology specified by the EU Platform on Sustainable Finance: organisations are assessed through analysis of their due diligence processes and the outcomes of those processes, rather than a simple documentation checklist. The MSS assessment exercise works through the four components — human rights due diligence (covering UNGP framework and CSDDD alignment), labour rights compliance (ILO core convention topics), anti-corruption compliance, and tax compliance — noting that MSS is an ongoing assessment that must be reviewed annually.

This unit covers the calculation of the three Taxonomy financial KPIs and the preparation of the Article 8 disclosure table. The revenue KPI is the proportion of net turnover derived from Taxonomy-eligible and aligned activities, expressed as a percentage of total group net turnover. The CapEx KPI covers capital expenditure related to Taxonomy-eligible and aligned activities as a proportion of total CapEx. The OpEx KPI covers operational expenditure associated with aligned activities using the narrow OpEx definition in the Delegated Regulation (maintenance, repair, short-term lease, and related costs for assets used in Taxonomy activities). The disclosure table preparation covers the mandatory format specified in the Article 8 Delegated Regulation annexes — a matrix with rows for each Taxonomy objective and columns for each financial KPI — including the treatment of activities that are eligible but not aligned, and the CapEx plan disclosure for activities expected to become aligned within five years. The capstone deliverable is a complete EU Taxonomy disclosure table for the case company, with supporting assessment documentation for the three case activities.