Strengthening global standards on pollution reporting: EFRAG’s Comment Letter to GRI now available

EFRAG’s Comment Letter on GRI’s Pollution Standards is now available, supporting clearer, more aligned and interoperable reporting.

EFRAG publishes its final Comment Letter on the GRI Exposure Drafts for the Air Pollution (GRI AP), Soil Pollution (GRI SP), and Critical Incidents (GRI CI) Standards of the GRI Topic Standard Project for Pollution, welcoming GRI’s efforts to strengthen pollution reporting.

Key highlights:

  • The relevance of GRI’s pollution standards to enhance corporate transparency on the topic globally. EFRAG welcomes GRI’s revision and enhancement of pollution-related disclosures, including through the reflection of internationally agreed best practice and intergovernmental instruments.

  • The role of the GRI Pollution Standards in providing helpful examples of entity-specific disclosures. Many of the requirements across the GRI AP, GRI SP and GRI CI Topic Standards are not explicitly covered in ESRS E2 and preparers may choose to incorporate them into their sustainability statements as entity-specific information.

  • The strong interoperability with ESRS, with a need for further refinement. Additional alignment is needed on key concepts and terminology, as well as on the addressing of pollution requirements across separate standards.

  • The need to address inconsistencies related to the granularity of disclosure requirements, particularly in relation to differences between the GRI AP and the GRI SP Standards, and to the disaggregation of spill information.

  • Feasibility challenges connected with permitting limits, which are not generally applicable to soil pollution.

Read more in EFRAG Comment Letter

This Comment Letter contributes to GRI’s due process and was prepared with consideration for enhanced interoperability with other relevant standards and frameworks, in support of preparers. This interoperability allows ESRS reporters to effectively report ‘with reference’ to the GRI Standards through their sustainability statement, whilst acknowledging that the GRI topical standards can serve as a source of entity-specific information.

Stakeholder feedback that informed the comment letter

EFRAG's analysis was informed by the results of its public consultation and two stakeholder workshops. The reports summarising these results can be found here:

  • Public Consultation Survey on EFRAG’s Comment Letter on GRI Pollution Summary Report
  • Stakeholder Workshops on EFRAG’s Comment Letter on GRI Pollution Summary Report

What’s next ?

Stakeholder feedback provided to the GRI will help shape the next stage of the development of GRI AP, GRI SP and GRI CI. According to the GRI’s Pollution project page, the approval of these standards by the Global Sustainability Standards Board (GSSB) is expected in 2027. 

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