In June 2025 the Global Reporting Initiative published two new topic standards: GRI 102: Climate Change 2025 and GRI 103: Energy 2025. Both take effect on 1 January 2027. For organizations reporting on emissions and energy with reference to the GRI Standards, they change which disclosures apply — and they illustrate why a requirement checklist cannot be hard-coded.
What GRI 102 replaces
GRI 102 withdraws disclosures 305-1 to 305-5 of GRI 305: Emissions 2016 — direct, energy indirect and other indirect emissions, emissions intensity and emissions reductions — together with disclosure 201-2 of GRI 201 on climate-related financial implications. Disclosures 305-6 (ozone-depleting substances) and 305-7 (nitrogen oxides, sulphur oxides and other significant air emissions) remain in GRI 305.
GRI 102 contains ten disclosures:
| Disclosure | Title |
|---|---|
| 102-1 | Transition plan for climate change mitigation |
| 102-2 | Climate change adaptation plan |
| 102-3 | Just transition |
| 102-4 | GHG emissions reduction targets and progress |
| 102-5 | Scope 1 GHG emissions |
| 102-6 | Scope 2 GHG emissions |
| 102-7 | Scope 3 GHG emissions |
| 102-8 | GHG emissions intensity |
| 102-9 | GHG removals in the value chain |
| 102-10 | Carbon credits |
The headline additions are transition and adaptation plans, just transition, and carbon credits, alongside a stronger focus on targets and on value-chain (Scope 3) emissions.
What GRI 103 replaces
GRI 103: Energy 2025 replaces GRI 302: Energy 2016 in full. It has five disclosures, 103-1 to 103-5, covering energy policies and commitments, energy consumption and generation within the organization, energy consumption in the value chain, energy intensity, and reductions in energy consumption. According to GRI's FAQ, it extends the requirements on purchased and self-generated electricity — including a breakdown by energy source and whether it is renewable — requires the numerator of the energy intensity ratio to be reported, and folds the former disclosure on reductions in the energy requirements of products and services into the reduction disclosure.
When it applies
GRI's FAQ for GRI 103 states that its use is required for all reporting on energy published on or after 1 January 2027, and that earlier adoption is encouraged; GRI 102 takes effect on the same date. Some commentators describe the trigger as reporting periods beginning on or after that date instead. The difference matters for a report covering 2026 but published in 2027, so confirm the trigger against the official text for each report.
The European picture
Separately, on 3 July 2026 the European Commission adopted revised European Sustainability Reporting Standards, amending the first set adopted in 2023, together with a voluntary standard for undertakings outside the scope of the CSRD. The revised standards are subject to a scrutiny period by the European Parliament and Council and, as reported by several advisers, apply to financial years beginning on or after 1 January 2027. The Commission describes a substantial reduction in mandatory datapoints. Treat the exact entry-into-force date as provisional until publication in the Official Journal.
Why effective dates belong in the data model
A gap analysis is only as current as its requirement list. Veridion stores requirement catalogues as versioned files with effective dates: its GRI 302 and 305 (2016) set is marked for reports published before 1 January 2027, and a GRI 102 and 103 (2025) set is available as a draft for early adopters. Every assessment records which catalogue version it used, so a finding made today can still be explained after the standards change.
Sources
- GRI — GRI 102: Climate Change 2025
- GRI — GRI 103: Energy 2025, frequently asked questions (June 2025)
- Jones Day — GRI releases new climate and energy standards
- Cooley — European Commission adopts revised EU CSRD reporting standards (July 2026)
- EY — European Commission adopts revised ESRS for sustainability reporting