ESRS vs GRI: Key Differences Explained

Quick Comparison

	ESRS	GRI
Scope	Full ESG under double materiality	Full ESG under impact materiality
Applicability	Companies subject to the EU CSRD	Any organization, any sector, any size
Required/Voluntary	Mandatory EU regulation	Voluntary (widely adopted)
Geography	European Union (with extraterritorial reach)	Global
Key Focus	Double materiality — impact and financial	Impact materiality — effects on people and planet
Assurance	Limited assurance required, moving to reasonable	Encouraged, not required

What is the ESRS?

The European Sustainability Reporting Standards are the disclosure standards underpinning the EU's Corporate Sustainability Reporting Directive. Developed by the European Financial Reporting Advisory Group (EFRAG), the first set of twelve ESRS was adopted by the European Commission in July 2023 as a delegated act. These standards specify exactly what CSRD-subject companies must report.

The twelve standards comprise two cross-cutting standards (ESRS 1 General Requirements and ESRS 2 General Disclosures), five environmental standards (E1 through E5 covering climate, pollution, water, biodiversity, and circular economy), four social standards (S1 through S4 covering own workforce, value chain workers, affected communities, and consumers), and one governance standard (G1 Business Conduct).

ESRS uses a double materiality approach: companies must report on sustainability topics that are material from either an impact perspective (the company's effects on people and planet) or a financial perspective (sustainability issues that affect the company's financial position). ESRS 2 General Disclosures is mandatory for all in-scope companies; the topical standards (E1-E5, S1-S4, G1) apply based on each company's materiality assessment, with the exception of certain climate disclosures that require explicit justification if omitted.

What is GRI?

The Global Reporting Initiative has been the world's most widely used sustainability reporting framework since its founding in 1997. GRI Standards use impact materiality — organizations report on topics where they have the most significant positive or negative effects on the economy, environment, and people. The modular framework includes Universal Standards applicable to all organizations and Topic Standards covering specific sustainability subjects.

GRI and EFRAG collaborated extensively during the ESRS development process, resulting in a high degree of structural alignment between the two systems. Many ESRS disclosure requirements trace directly to GRI equivalents, though the ESRS adds financial materiality, more prescriptive data points, and mandatory digital tagging requirements.

GRI's 2021 revision, effective January 2023, updated the Universal Standards and strengthened due diligence and human rights reporting requirements — changes that also influenced the ESRS development.

Key Differences

1. Materiality: Double vs Impact

The most significant conceptual difference. GRI uses impact materiality exclusively — what matters is an organization's effects on people and the environment. ESRS requires double materiality: both impact materiality (aligned with GRI) and financial materiality (how sustainability issues affect the company's financial position). A topic that creates financial risk but has limited outward impact could be material under ESRS but not under GRI, and vice versa.

2. Mandatory vs Voluntary

ESRS compliance is a legal obligation for companies subject to the CSRD. Non-compliance carries legal consequences under member state enforcement mechanisms. GRI reporting is voluntary — organizations choose to report and self-declare their level of conformance. This distinction affects everything from board-level accountability to audit committee involvement.

3. Prescriptiveness and Data Points

ESRS standards contain approximately 1,100 individual data points across the twelve standards. While materiality assessment determines which topical standards apply, those that do apply must be reported with specific quantitative and qualitative disclosures at defined granularity. GRI provides disclosure requirements but allows more flexibility in how organizations present information and the level of quantitative detail.

4. Assurance Requirements

ESRS-based reports must be assured from the outset — initially at a limited assurance level, with a planned transition to reasonable assurance. GRI encourages but does not require external assurance. The mandatory assurance requirement under ESRS elevates data quality demands, internal controls, and documentation standards beyond what most GRI reporters have maintained.

5. Digital Taxonomy and Format

ESRS reports must be prepared in XHTML format with digital tagging using the ESRS XBRL taxonomy, enabling machine-readable data extraction. GRI has no digital format requirement — reports can be PDFs, web pages, or any other format. The ESRS digital taxonomy imposes technical requirements on reporting systems that GRI reporters have not faced.

6. Transition Relief and Phasing

ESRS includes specific transition provisions — for example, companies with fewer than 750 employees can omit Scope 3 emissions and certain workforce data in the first year. Companies in their first year of ESRS reporting can omit comparative data. GRI has no equivalent phasing provisions since reporting is voluntary and organizations determine their own scope.

7. Value Chain Scope

Both frameworks require value chain reporting, but ESRS is more explicit about expectations and provides a three-year transition period for value chain data collection. ESRS requires companies to explain their efforts to obtain value chain data and the limitations encountered. GRI requires value chain disclosure where material but provides less prescriptive guidance on data collection expectations.

Which One Do You Need?

ESRS is required for companies subject to the CSRD — large EU companies, listed EU companies, and qualifying non-EU companies. There is no choice involved; compliance is mandatory.

GRI is the right choice for organizations outside CSRD scope that want to report on their sustainability impacts, or for organizations that want a globally recognized framework while they prepare for potential regulatory requirements.

Both in practice, for many organizations. GRI reporting can continue alongside ESRS compliance, and the high interoperability means much of the content overlaps. Organizations with global stakeholders may use GRI for non-EU operations and ESRS for EU-regulated disclosures.

Can You Use Both?

Absolutely, and the alignment between the two frameworks was intentionally designed to make this feasible. EFRAG and GRI published an interoperability index mapping GRI disclosures to ESRS data points, demonstrating substantial overlap. An organization that complies with ESRS will largely satisfy GRI requirements for the same topics, with some additions needed for GRI-specific disclosures.

The practical approach for organizations subject to CSRD is to use ESRS as the primary reporting framework and then prepare a GRI Content Index that maps to the ESRS disclosures, supplementing with any GRI-specific requirements not covered by ESRS. This is particularly useful for organizations with global operations where GRI is the recognized standard outside Europe.

Council Fire's Perspective

The GRI-ESRS relationship is closer than any other framework pairing in sustainability reporting. For organizations already reporting under GRI, the transition to ESRS is more of an expansion than a transformation — adding financial materiality, greater prescriptiveness, and assurance requirements on top of a familiar conceptual foundation.

Where we see clients underestimating the effort is in the data infrastructure required for ESRS. The approximately 1,100 data points, mandatory assurance, and digital tagging requirements demand a level of systematization that most GRI reporters haven't built. We advise clients to start their ESRS gap analysis from their existing GRI disclosures, identify the additional data points and qualitative requirements, and invest in systems that can serve both frameworks from a single data collection process.

Frequently Asked Questions

Can I use my GRI report to comply with ESRS?

Not directly. While there is significant content overlap, ESRS has specific formatting requirements (XHTML with digital tagging), mandatory assurance, and additional data points beyond GRI — particularly around financial materiality, transition plans, and certain quantitative metrics. A GRI report is an excellent starting point for ESRS compliance but will need supplementation and reformatting.

Does ESRS replace GRI for EU companies?

For regulatory compliance, yes — EU companies subject to CSRD must report under ESRS. However, many organizations continue to reference GRI alongside ESRS, particularly for global reporting consistency and for stakeholders accustomed to the GRI format. GRI itself has stated that the two frameworks are complementary.

How do the materiality assessments differ?

A GRI materiality assessment identifies topics based on the significance of an organization's outward impacts on economy, environment, and people. An ESRS materiality assessment evaluates topics from two perspectives: impact materiality (similar to GRI) and financial materiality (whether the topic creates risks or opportunities that could affect the company's financial position). The double materiality assessment typically starts with impact materiality and adds the financial lens, or conducts both in parallel.