GRI Releases New Climate and Energy Standards – Significant Reporting Changes Ahead

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The Global Reporting Initiative (GRI) published two new topic standards—GRI 102: Climate Change (2025) and GRI 103: Energy (2025). These standards will replace GRI 305: Emissions (2016), GRI 302: Energy (2016), and Disclosure 201-2 from GRI 201, and become effective for reporting periods starting January 1, 2027. Early adoption is permitted.

What This Means for Reporting Organizations

GRI provides a comprehensive sustainability reporting framework that has been voluntarily adopted by many large entities, although GRI emphasizes that any entity is eligible to use the framework.  Entities reporting under the GRI Standards 2021 should begin preparing for expanded and more rigorous climate- and energy-related disclosures. Key preparatory actions include:

  • Re-evaluating data systems and methodologies, ensuring they align with the GHG Protocol and meet more detailed disclosure requirements under GRI 102 and 103.
  • Examining opportunities to leverage interoperability between the new GRI Standards and regulatory disclosure frameworks—particularly the EU CSRD, California’s SB 253 (Climate Corporate Data Accountability Act), and SB 261 (Climate-Related Financial Risk Disclosure).

GRI 102: Climate Change (2025) – Key Updates

  1. Climate Transition Plans – Organizations must disclose their climate transition plans, including targets and alignment with a 1.5°C pathway or science-based climate goals.
    (Significantly expanded in 2025 – GRI 305-5 required targets and reductions but lacked alignment with 1.5°C pathways and science-based methodologies)
  2. Adaptation to Physical Risks – Requires disclosures on physical climate risks and adaptation strategies across operations, value chains, and business models.
    (New in 2025 – Physical climate risk and adaptation strategies were not explicitly required under GRI 305 or 201-2)
  3. Expanded GHG Emissions Reporting – Expands Scope 1, 2, and 3 emissions reporting in line with the GHG Protocol, including calculation methods, base years, reduction targets, and progress updates.
    (Enhanced in 2025 – More granular and rigorous than GRI 305 (2016))
  4. Carbon Credits and GHG Removals – Mandatory disclosures of carbon credits and GHG removals, including type, source, accounting approach, and role in achieving targets.
    (New in 2025 – Prior GRI guidance allowed limited voluntary disclosure on offsets but lacked requirements on credit typology, accounting method, and permanence)
  5. Just Transition – Introduces disclosure on the social impacts of climate transition efforts, specifically regarding workers, communities, and Indigenous Peoples.
    (New in 2025 – Social impacts not addressed in GRI 305 (2016))

GRI 103: Energy (2025) – Key Updates

  1. Energy Consumption – Requires disclosure of total energy consumption, broken down by renewable vs. non-renewable sources and internal vs. external use.
    (Enhanced in 2025 – GRI 302 (2016) lacked detailed source and usage breakdowns)
  2. Energy Efficiency – Introduces outcome-based reporting on energy efficiency initiatives, including performance indicators, targets, and results achieved.
    (Expanded in 2025 – GRI 302 (2016) included efficiency, but lacked focus on outcomes)
  3. Upstream and Downstream Impacts – New disclosures on the environmental and social impacts of energy sourcing and use across the value chain. 
    (New in 2025 – No equivalent in GRI 302 (2016))

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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