EFRAG has published its final Comment Letter on the Global Reporting Initiative’s (GRI) Exposure Drafts for its new Air Pollution, Soil Pollution, and Critical Incidents Standards. The response officially welcomes GRI’s efforts to strengthen international pollution reporting whilst emphasizing the technical adjustments required to ensure seamless interoperability with the European Sustainability Reporting Standards (ESRS).
The submission marks a critical technical step in the ongoing alignment between EU statutory reporting mandates and global voluntary frameworks, designed to reduce the administrative burden on corporate preparers.
While EFRAG endorsed the relevance of the updated GRI frameworks in driving corporate transparency, the advisory body identified several structural areas requiring refinement prior to final publication:
- Entity-specific disclosure pathways: EFRAG noted that because multiple granular requirements within the GRI drafts are not explicitly mandated under ESRS E2 (the EU’s dedicated pollution standard), European companies can systematically adopt these specific GRI metrics to satisfy their “entity-specific” disclosure obligations under EU law.
- Granularity and material disaggregation: The letter highlighted technical inconsistencies regarding the required granularity of data between the Air Pollution and Soil Pollution drafts, specifically urging GRI to standardise how companies report and disaggregate chemical spill data.
- Feasibility and regulatory permitting: EFRAG raised practical implementation concerns regarding the application of strict permitting limits, noting that such regulatory structures are standard for air emissions but are not generally applicable or feasible for soil pollution contexts.
The technical review was prepared with a primary focus on ensuring that entities reporting under the legally binding ESRS framework can simultaneously claim to report “with reference to” the voluntary GRI Standards without duplicating data collection workflows. EFRAG called for further alignment on core nomenclature, definitions, and the structural allocation of pollution requirements across separate thematic standards to prevent cross-framework friction.
The feedback will now be processed as part of the GRI’s formal due process as it moves to finalise the global standards.
