More reporting changes are coming…

Just when companies are getting used to ISSB, there are more reporting updates to keep track of. This time, they come from GRI.

The good news is that GRI is not redesigning its entire framework. Instead, it is progressively updating individual Topic Standards. Three are particularly relevant right now: GRI 101: Biodiversity, GRI 102: Climate Change, and GRI 103: Energy.

So, what is changing? And what should companies be doing about it?

First: Biodiversity is already here

• GRI 101: Biodiversity 2024 became effective January 1, 2026, replacing GRI 304.
• A key clarification: this does not mean every GRI reporter suddenly has to report on biodiversity. GRI 101 applies when biodiversity has been identified as a material topic.
• For companies where it is material, however, reporting gets much more granular. Among other things, companies may need to disclose:  

               -Sites associated with significant biodiversity impacts.

               -Their location, size, and proximity to ecologically sensitive areas.

               -Products and services in the supply chain associated with significant impacts.

               -Biodiversity-related policies, commitments, goals, and targets.

              -GRI does not require companies to create a policy or target just to comply. If one does not exist,                   they can say so.

• The bigger challenge will likely be finding the data. Companies that have never mapped biodiversity impacts by location or throughout their supply chain may have some work ahead.
• Our take: if biodiversity is potentially material, 2026 is not the year to postpone the assessment. Confirm materiality, map the relevant sites and value-chain impacts, and identify the information gaps now.

Next up: Climate and Energy

• GRI 102: Climate Change 2025 and GRI 103: Energy 2025 become effective January 1, 2027, although early adoption is encouraged.
• These are more than simple updates. GRI 102 significantly expands climate disclosures, including:

                o Transition and adaptation plans.

               o Alignment with a 1.5°C pathway.

              o GHG reduction targets.

              o Scope 1, 2, and 3 emissions.

             o Carbon removals and carbon credits.

            o Just transition impacts on workers and communities.

• GRI 103 also asks for greater detail on energy use and sourcing, including renewable versus non-renewable energy, RECs and other certificates, PPAs, and market-based versus location-based information.
• For many companies, Scope 3 and energy sourcing will probably be the biggest gaps.

Already reporting under ISSB? There is some good news

Companies should not build separate reporting systems for every standard. GRI and the IFRS Foundation confirmed in 2025 that equivalent IFRS S2 Scope 1, Scope 2, and Scope 3 disclosures can satisfy the corresponding requirements under GRI 102, subject to the applicable conditions and cross-referencing. In other words: one robust emissions dataset can serve multiple reporting frameworks. This is particularly relevant in Mexico since issuers subject to the CNBV’s ISSB-based requirements.

Should you early-adopt GRI 102 and 103?

Before deciding, we would ask:

• Is Scope 3 reliable enough to disclose?
• Can energy consumption be broken down by source?
• Are climate targets and transition plans sufficiently developed?
• Can RECs, PPAs, removals, and carbon credits be properly substantiated?
• Are the data and controls ready for assurance?

If the answer to several of these is “not yet,” using 2026 as a preparation year may make more sense.

So, what should companies do in 2026?

We would focus on four things:

1. Confirm materiality. GRI 101, 102, and 103 apply when the corresponding topic is material.

2. Address GRI 101 now. If biodiversity is material, the new Standard is already effective.

3. Gap-assess GRI 102 and 103. Identify missing data before the 2027 reporting process starts.

4. Connect GRI and ISSB. Wherever possible, build one set of methodologies, data, and controls that can support both.

The main takeaway? These changes are manageable, but some of the underlying work takes time. 2026 is the year to close the gaps, not just update the content index.

I hope you found this interesting. As usual, if there is anything we can help you with, or if there is an ESG topic you would like to know more about, please let us know.

Best,

Marimar

CEO, Miranda ESG