CSRD vs GRI What can be reused under ESRS

Companies subject to CSRD use the European Sustainability Reporting Standards. The Commission says the adopted ESRS apply to all companies subject to CSRD.

GRI is not the CSRD reporting standard. EU materials describe GRI as a global standard-setting reference used to improve interoperability and reduce unnecessary double reporting.

For a CSRD report, start with ESRS applicability, disclosure requirements, and sustainability-statement structure. Use GRI only where ESRS or EFRAG guidance supports reuse or additional disclosure.

ESRS uses double materiality. A CSRD preparer must address impact materiality and add the financial materiality dimension required by ESRS.

EFRAG says a GRI Universal Standards assessment is focused on impact materiality and can be a good basis for the ESRS impact assessment, but it does not cover ESRS financial materiality by itself.

A prior GRI materiality exercise is useful input, not the finished ESRS materiality assessment. Add ESRS financial materiality, ESRS matter mapping, and documentation of material impacts, risks, and opportunities.

ESRS requires all applicable ESRS disclosures to be reported in the sustainability statement, with general, environmental, social, and governance parts.

GRI can be a source of additional disclosure content, but ESRS 1 says those disclosures must be clearly identified and still satisfy ESRS qualitative characteristics.

Do not mix GRI content into the ESRS statement without labelling it. Keep an ESRS disclosure index and mark any GRI-derived additional disclosure with the related framework reference.

ESRS material impacts, risks, and opportunities can arise in the undertaking's own operations and its upstream and downstream value chain.

EFRAG's value-chain guidance states that value-chain definitions under ISSB and GRI frameworks are aligned with ESRS.

Use GRI value-chain work to accelerate scoping only after confirming it matches the ESRS reporting group, upstream and downstream boundary, and required ESRS disclosure topic.

Where material matters are not fully covered by topical ESRS, ESRS requires entity-specific disclosures and includes transitional measures for the first three annual sustainability statements.

ESRS 1 expressly names GRI Sector Standards as one available framework that may help cover material sector matters during the transitional period.

GRI Sector Standards can help fill entity-specific gaps, but the resulting disclosure still has to satisfy ESRS qualitative characteristics and sit inside the ESRS reporting structure.

ESRS is designed with interoperability in mind, including digital reporting considerations and alignment work with other sustainability reporting frameworks.

ESMA describes an EFRAG project on ESRS-GRI interoperability and says existing GRI reporters can leverage current reporting efforts when preparing an ESRS sustainability statement.

Reuse GRI work through a crosswalk: material topic, ESRS disclosure requirement, GRI source, owner, data source, assurance status, and any remaining ESRS gap.

ESRS is the binding reporting baseline for CSRD-covered undertakings, and the sustainability statement has to follow the ESRS structure and disclosure rules.

GRI can still be used as a benchmark or source set, but it only becomes part of the CSRD report if ESRS allows the disclosure or if the disclosure is clearly identified as additional information.

A preparer should not ask 'ESRS or GRI?' for the legal report. The real question is whether a GRI item is usable as supporting evidence, an additional disclosure, or a sector input inside an ESRS-compliant file.

GRI can help fill evidence gaps earlier in the reporting process, especially where a company already maintains a GRI-based reporting pack or a GRI-aligned data model.

EU materials describe GRI as a framework that can reduce unnecessary duplication, but the ESRS statement still needs its own mapping, labelling, and boundary checks.

Reuse the work, not the label: import GRI data into an ESRS mapping table, then verify which figures or narratives survive unchanged and which need ESRS-specific recasting.

Use ESRS as the mandatory reporting baseline and ask whether a disclosure is required by ESRS, required as an EU datapoint, or needed as entity-specific information.

Use GRI as a source set when it helps produce ESRS-compliant evidence, topic coverage, or additional disclosures that are clearly identified and still meet ESRS qualitative characteristics.

If an item is only in GRI, keep it out of the ESRS report unless you can point to the ESRS rule that allows it or requires extra disclosure. If an item exists in both, keep the ESRS version in the filing and document the GRI source as support.