Your FY2026 Sustainability Report Is the First Under GRI’s New Climate Standard

Reporting season has started. Thai listed companies with a December year-end are closing FY2026 data now, and will publish their sustainability reports and file their 56-1 One Reports by 31 March 2027. Most teams will start from last year’s GRI content index and update the numbers.

That shortcut will not work this year. GRI’s two new topic standards, GRI 102: Climate Change 2025 and GRI 103: Energy 2025, apply to “reports or other materials published on or after 1 January 2027.” Any report published in 2027 that claims to be prepared in accordance with the GRI Standards, and treats climate or energy as material, has to use them. In practice that means every FY2026 report.

The date that decides which standard applies

GRI dates its standards by when a report is published, not by the year it covers. GRI 1: Foundation is explicit: “Information published after the effective date of a Standard must make use of that Standard.” That produces a timeline many teams have not lined up:

Effective dates: the GRI 101, 102 and 103 standard PDFs. Replacements: GRI 101 and GRI 102 FAQs; GRI 103 FAQ on the renumbering from GRI 302. Earlier adoption of all three is encouraged.

One caveat applies to everything in this post. These obligations bind only a company that says it reports in accordance with GRI, and only for topics it has found material. A company reporting with reference to GRI is not held to each topic standard in full. No Thai regulator requires GRI. The SEC’s One Report form points companies to GRI’s reporting guidance only as an optional source for further disclosure, and its ESG FAQ calls GRI the international standard companies use most widely.

What GRI 102 asks that GRI 305 never did

GRI 305 was mainly an emissions inventory. GRI 102 also asks about strategy. The standard has ten disclosures, and the first ones are about plans rather than inventory figures:

For a company that has found climate change material, GRI 102 requires the topic-management disclosures that are relevant to its climate impacts, alongside Disclosure 3-3 in GRI 3. It also requires whichever of 102-3 to 102-10 are relevant. Only four reasons for omitting a required item are allowed: not applicable, legal prohibition, confidentiality, and information unavailable or incomplete. GRI 1 says “the organization is not allowed to use other reasons for omission.” A company that cannot meet the requirements loses the “in accordance with” claim and can only report “with reference to” GRI.

Carbon credits leave the target

This is where Thai reports will change most visibly. Many Thai net-zero and carbon-neutral claims rely on T-VER and other credits. GRI 102 keeps credits out of the reduction story:

Credits are reported separately under 102-10. The company must give the total credits cancelled in tonnes of CO2 equivalent, split between removal and reduction projects. For each project it must give the name and ID, project type, cancellation serial number and date, vintage, host country and issuing registry. It must also explain how each project meets seven quality criteria, including additionality, permanence, leakage avoidance and independent verification. A sentence such as “offset through carbon credits” will not be enough. Our note on Thai carbon-credit prices explains why the quality criteria matter in this market.

What Thai reports look like today

We read the GRI content indexes in four FY2025 sustainability reports from SET50 companies, published this year. They show companies at very different points:

• SCG claims “in accordance with” and already cites GRI 101: Biodiversity 2024 disclosures in its index.
• Thai Union reports “in accordance with” and still cites GRI 304: Biodiversity 2016, although GRI 101 applied to reports published from January 2026.
• Banpu has already mapped GRI 102 and GRI 103 into its index. Several GRI 102 rows, including the transition plan, just transition and removals, are marked as information unavailable and in development, for disclosure in a later report.
• AIS states “in accordance with” GRI, while its assurance provider’s conclusion refers to “with reference to” GRI. Readers notice when the company and its assurer use different terms.

Four reports are a small sample and prove nothing about the market as a whole. They do show that GRI updates are not applied consistently, and that the gap is visible to anyone who reads a content index.

One emissions set for GRI and IFRS S2

For SET50 companies, GRI 102 arrives one year before the SEC’s IFRS S1 and S2 requirement starts in FY2027. The two standards are meant to work together. On 26 June 2025 the GRI granted equivalence to IFRS S2 for greenhouse-gas emissions. Scope 1, 2 and 3 figures prepared under IFRS S2 can satisfy GRI 102, provided they are measured under the GHG Protocol Corporate Standard and the content index shows where each disclosure sits.

That makes FY2026 a useful rehearsal. Build the GRI 102 emissions disclosures on the GHG Protocol now, ideally from a TGO-certified organisational footprint, and the same data can support IFRS S2 next year. See our SET50 climate-disclosure guide and how a TGO carbon footprint becomes disclosure.

The same index, read in two languages

A GRI content index is a page-by-page map of the report. In Thailand there are usually two reports to map: the Thai One Report and sustainability report, and the English editions that foreign investors and rating analysts read. If the English index points to the wrong page, cites GRI 305 where the Thai version cites GRI 102, or translates a transition-plan target loosely, the two editions no longer match.

The English edition is the one most global readers use. FTSE Russell scores from public disclosure only, with no questionnaire, and Thai is not among the research languages named in its FAQ (v1.5 §1.8). SET recommends English disclosure for that reason. CDP will not score a Thai-language response. None of this means a Thai report is marked down. It means the version a foreign analyst checks against GRI 102 is usually the English one, so the company should make sure it is accurate. Our clause-mapped bilingual One Report keeps the index, page references and terms the same in both languages, and our note on ESG translation risk covers what goes wrong when they drift.

Where the evidence runs out

A reporting-season checklist

The FY2026 report is the first under GRI 102 and 103, and the last before SET50 moves to IFRS S2. Do the GRI 102 work this season and most of the data will be ready for IFRS S2 next year. Start with a TGO-certified organisational footprint, read our guide to bilingual IFRS S1 and S2 disclosure, and follow the deadlines on our regulatory tracker →

Sources, read 7 October 2026: GRI, GRI 102: Climate Change 2025, GRI 103: Energy 2025 and GRI 101: Biodiversity 2024 (effective-date sections, Disclosures 102-1, 102-4 guidance and 102-10) and their FAQs; GRI 1: Foundation 2021 (effective dates, reasons for omission, in-accordance requirements); IFRS Foundation, “GRI 102 and IFRS S2: reporting and equivalence” (26 June 2025); FY2025 sustainability reports and GRI content indexes of SCG (Thai edition), Thai Union, Banpu and AIS; FTSE Russell, “ESG scores and beyond” (April 2021); FTSE Russell ESG Scores FAQ v1.5 §1.8; SEC notification ทจ. 48/2568 on Form 56-1 One Report.