Quick Comparison
| CSRD | GRI | |
|---|---|---|
| Scope | EU directive mandating sustainability reporting under ESRS | Global voluntary framework for sustainability impact reporting |
| Applicability | ~50,000 companies meeting EU size/listing thresholds | Any organization worldwide |
| Required/Voluntary | Mandatory EU law | Voluntary |
| Geography | European Union (with extraterritorial reach) | Global |
| Key Focus | Double materiality with legally binding disclosure requirements | Impact materiality with flexible disclosure approach |
| Assurance | Mandatory limited assurance (moving to reasonable) | Encouraged but not required |
What is the CSRD?
The Corporate Sustainability Reporting Directive is the EU's legislative framework mandating comprehensive sustainability disclosure. Adopted in November 2022 and entering force in January 2023, the CSRD replaces the 2014 Non-Financial Reporting Directive and dramatically expands the universe of companies required to report, the topics they must cover, and the rigor expected.
The CSRD itself is the directive — the law that establishes the obligation to report. The content of what companies report is defined by the European Sustainability Reporting Standards (ESRS), developed by EFRAG. The CSRD also establishes the assurance requirement, the digital format mandate, and the phased implementation timeline.
Companies report in waves: large public-interest entities (already under NFRD) started for fiscal year 2024, other large companies for fiscal year 2025, listed SMEs for fiscal year 2026 (with opt-out until 2028), and qualifying non-EU companies for fiscal year 2028. The extraterritorial scope means non-EU companies with significant EU revenue must also comply.
What is GRI?
The Global Reporting Initiative provides the most widely adopted voluntary sustainability reporting standards globally. Since 1997, GRI has offered a structured approach for organizations of any size and sector to report on their impacts on the economy, environment, and people. The framework uses impact materiality — organizations determine which topics to report on based on the significance of their outward effects.
GRI's modular system includes Universal Standards (GRI 1, 2, 3) and Topic Standards covering economic, environmental, and social subjects. Organizations conduct a materiality assessment, select applicable Topic Standards, and disclose against the specified requirements. The framework is flexible: organizations can report "in accordance" with GRI (meeting all Universal Standard requirements and all applicable Topic Standards) or "with reference to" GRI (using selected standards).
GRI collaborated extensively with EFRAG on ESRS development, and the resulting interoperability between GRI and ESRS is by design. Many ESRS disclosure requirements have direct GRI counterparts.
Key Differences
1. Legal Nature
The CSRD is EU legislation — a directive transposed into national law by each member state. Non-compliance has legal consequences including penalties set by member states. GRI is a voluntary framework with no legal enforcement mechanism. An organization choosing not to report under GRI faces no regulatory consequence; a CSRD-subject entity that fails to report faces fines and potential liability.
2. Directive vs Standards
The CSRD and GRI are different things. The CSRD is a directive (the legal requirement to report); ESRS are the standards (what to report). GRI is only standards (what to report). The more precise comparison is ESRS vs GRI, which addresses the content and methodology differences. The CSRD adds the legal enforcement layer, assurance mandate, digital format requirements, and scope definitions that sit above the reporting content.
3. Company Scope
GRI is available to any organization that chooses to use it. The CSRD applies to specific categories of companies based on defined thresholds — large EU companies (250+ employees, €50M+ revenue, or €25M+ total assets), EU-listed companies (except listed micro-enterprises), and qualifying non-EU companies. This mandatory scope captures approximately 50,000 companies, compared to approximately 11,700 under the predecessor NFRD.
4. Double Materiality
The CSRD mandates double materiality through the ESRS — companies must assess and report from both impact and financial materiality perspectives. GRI uses impact materiality only. The addition of financial materiality under CSRD means companies must evaluate how sustainability issues affect their financial position, not just how their operations affect people and the environment.
5. Assurance and Data Quality
The CSRD requires third-party assurance of sustainability reporting from the first reporting year — initially limited assurance, with a transition to reasonable assurance. This elevates the standard for data collection, internal controls, and documentation. GRI encourages assurance but leaves it to the reporting organization's discretion. The mandatory assurance requirement is one of the CSRD's most operationally demanding provisions.
6. Digital Reporting
CSRD reports must be prepared in XHTML format with ESRS XBRL taxonomy tagging, enabling automated data extraction and analysis by regulators, investors, and the European Single Access Point (ESAP). GRI has no digital format requirements — organizations publish in whatever format they choose.
7. Management Report Integration
The CSRD requires sustainability information to be included in the company's management report, placing it alongside financial information in a single audited document. GRI reports can be standalone documents, sections of annual reports, or web-based disclosures — the framework is agnostic about placement.
Which One Do You Need?
The CSRD applies based on objective criteria: your company's size, listing status, and EU nexus. If you meet the thresholds, you must comply — there is no opt-in or opt-out (except the temporary SME deferral).
GRI is appropriate for organizations outside CSRD scope that want to report on sustainability impacts, or for CSRD-subject companies that also want a globally recognized framework for non-EU stakeholders. GRI also serves as excellent preparation for future CSRD obligations.
CSRD-subject companies should treat ESRS (the CSRD's reporting standards) as their primary framework and use GRI's interoperability mapping to maintain continuity with previous GRI reporting.
Can You Use Both?
Yes, and organizations already reporting under GRI have a meaningful head start on CSRD compliance. The EFRAG-GRI interoperability mapping shows that approximately 80% of GRI disclosures have an ESRS counterpart. The gaps are primarily in financial materiality disclosures, specific quantitative data points, transition plan requirements, and certain governance disclosures that ESRS demands beyond GRI.
For organizations with global operations, maintaining GRI reporting alongside CSRD compliance serves stakeholders outside Europe who are familiar with GRI. The unified data collection process serves both, with ESRS-specific requirements (digital tagging, assurance, financial materiality analysis) applied as an additional layer for EU compliance.
Council Fire's Perspective
Organizations with GRI experience are better positioned for CSRD than they often realize. The materiality assessment process, stakeholder engagement methodology, and impact-oriented thinking that GRI cultivates transfer directly to the ESRS framework. The incremental work is real — financial materiality analysis, more prescriptive data points, assurance readiness, and digital format compliance — but it's incremental, not foundational.
The organizations we see struggling most with CSRD are those that have never reported under any framework. They're building governance structures, data collection systems, and stakeholder engagement processes from scratch while simultaneously meeting a legal deadline. We strongly recommend that companies approaching CSRD scope thresholds — particularly subsidiaries of non-EU parents — begin voluntary GRI reporting now to build the muscles they'll need when CSRD obligations arrive.
Frequently Asked Questions
Does GRI reporting satisfy CSRD requirements?
No, but it provides a strong foundation. CSRD compliance requires reporting under ESRS, which includes requirements beyond GRI — financial materiality, digital XBRL tagging, mandatory assurance, and specific data points. However, organizations with mature GRI reporting programs will find that significant portions of their existing disclosures map to ESRS requirements.
Should I stop GRI reporting when CSRD starts?
Not necessarily. Many organizations continue GRI reporting alongside CSRD compliance, particularly those with global stakeholders. GRI provides a universally recognized framework that serves audiences outside the EU regulatory context. The practical approach is to produce CSRD-compliant ESRS disclosures as your primary report and publish a GRI Content Index that cross-references the ESRS disclosures.
Can GRI help me prepare for CSRD before my compliance date?
Absolutely. We recommend this approach for companies expecting to fall within CSRD scope. GRI reporting builds the organizational capabilities — materiality assessment, data collection, governance, stakeholder engagement — that CSRD requires. Starting with GRI allows you to learn and improve before compliance becomes mandatory and the stakes are higher.
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