GRI sustainability report preparation and assurance preparation guidance｜Startrust

Starting from major impact and cross-departmental data, complete a credible, readable, and continuously updated sustainability report

A sustainability report should not just be a collection of annual activity results, nor just a collection of information provided by various departments. A truly useful report needs to explain what significant positive and negative impacts the company has on the economy, environment and people, how it is managed, prevented, mitigated and improved, and whether relevant goals and performance have consistent data and evidence.

Starting from 2025, all listed companies in Taiwan are required to prepare and submit sustainability reports in accordance with the operating procedures. In addition to completing content in accordance with GRI’s general, industry and major theme standards, companies also need to deal with board governance, industry indicators, reporting schedules and applicable assurance requirements.

Startrust assists companies starting from the reporting scope, major themes and stakeholders, establishing cross-department information forms, responsibilities, audits and version management, completing report structure, writing, GRI content indexing, design proofreading and third-party assurance preparation, and connecting IFRS S1/S2 with sustainable performance management.

Use the GRI method to identify the most significant actual and potential impacts on the company
Establish stakeholder communication, information collection and cross-department review processes
Complete the report content, GRI index and Taiwan reporting requirements
Improve data definition, boundaries, evidence and confidence readiness
Transform the annual preparation process into a sustainable management mechanism

Reservation consultation

Why do companies need to prepare sustainability reports?

Comply with Taiwan regulations and reporting requirements

According to the current operating procedures of the Taiwan Stock Exchange, listed companies should prepare and file a Chinese sustainability report for the previous year every year, and disclose major impacts and management methods in accordance with GRI general standards, applicable industry standards and major theme standards. Listed companies, specific industries and other organizations should confirm their requirements in accordance with their respective applicable regulations.

Respond to the information needs of investors, customers and supply chain

Stakeholders want to know how companies manage carbon emissions, energy, water, employees, human rights, occupational safety, suppliers, products and governance. A complete report can provide a common source of information, reducing repeated responses to questionnaires and the use of inconsistent numbers among departments.

Let major sustainability issues enter management decision-making

The major theme process can help companies identify actual and potential impacts in the value chain, and bring stakeholder perspectives, regulations, industry and operational data into goal, resource and performance management.

Establish transparent and traceable performance benchmarks

The promises and data in the report will become the basis for external comparison. Companies need to clearly define the reporting scope, statistical period, calculation method, reason for restatement and data restrictions in order to maintain annual comparability and trust.

Establish a data basis for IFRS sustainable disclosure and third-party assurance

GRI and IFRS S1/S2 have different material focus, but underlying data such as governance, carbon emissions, employees, supply chain and targets can be shared. Establishing accountability, substantiation and review first will help with future financial disclosure and assurance.

What is a sustainability report?

A sustainability report is a formal document for an organization to explain its sustainability impact, governance approach, policies, actions, goals and performance to stakeholders. According to GRI guidelines, major themes are those that represent the organization’s most significant impact on the economy, environment and people, including human rights.

Reports are not equivalent to corporate promotional publications

In addition to results, the report content also needs to present major negative impacts, management gaps, incidents, improvements, and unfinished goals. Only positive cases are presented, but data boundaries and management methods are lacking, which is difficult to meet the purpose of credible and sustainable reporting.

ESG reports and sustainability reports usually refer to similar documents

Names such as ESG report, corporate sustainability report or sustainable development report are often used in the market. When formally preparing it, it should be based on the requirements of applicable laws and regulations, rather than just looking at the file name.

Sustainability reports and annual reports have their own functions

Sustainability reports are aimed at a wide range of stakeholders and focus on major corporate impacts and management; annual reports and IFRS sustainability-related financial information focus more on investors and corporate prospects. Content may refer to each other, but duplication, contradiction, or the use of different numbers should be avoided.

What are the establishment requirements for Taiwan listed companies?

Applicable objects and declaration

All Taiwan listed companies will be required to prepare and submit sustainability reports starting from 2025. Enterprises should confirm the application deadline, file format, website disclosure and board of directors procedures in accordance with the latest listing or OTC operating procedures.

GRI Guidelines

The current working methods require preparation in accordance with GRI general standards, industry standards and major theme standards, and provide a GRI content index in the report. If industry standards apply, companies need to review the possible material topics one by one.

Strengthen disclosure by industry

Specific industries may need to disclose additional sustainability indicators, climate information or measurement items required by competent authorities. Enterprises need to identify their own industry classifications and applicable schedules, and cannot just compile based on general GRI content.

Third party belief or guarantee

The working methods require enterprises to indicate whether the disclosure project has obtained third-party confirmation or guarantee. Some industries or indicators have other confirmation requirements. The actual scope, criteria and institutional qualifications should be confirmed according to the latest regulations.

Board of Directors and Governance

The content of the report should be consistent with the company’s sustainable governance, risks, goals and performance. Enterprises should arrange for the board of directors or appropriate governance levels to review and keep records of decisions and approvals.

How should GRI guidelines be used?

GRI 1: Basics

GRI 1 explains the GRI reporting purpose, key concepts, reporting principles and compliance requirements. Companies need to understand concepts such as impact, material themes, due diligence and stakeholders, and cannot just select a few indicators to use.

GRI 2: General Disclosure

General disclosure covers organizational profile, activities, employees, governance, strategies, policies, due diligence, grievances and stakeholder discussions, etc., forming the background for readers to understand the boundaries of the enterprise and the report.

GRI 3: Key themes

GRI 3 requires companies to explain how to identify actual and potential, positive and negative impacts, how to rank them in order of significance, and which stakeholders and experts are involved in the judgment. Companies also need to disclose a list of material topics and how each topic is managed.

GRI Industry Code

If GRI has issued applicable industry standards, companies need to use them to help identify common major impacts in the industry. Industry standards do not replace companies’ own assessment of major topics, but rather avoid missing key industry issues.

GRI Material Theme Guidelines

Companies adopt corresponding standards based on major themes, such as climate, energy, biodiversity, water, waste, occupational safety, human rights or anti-corruption, and disclose applicable management methods and indicators.

GRI Content Index

The content index needs to clearly correspond to the disclosure items, page numbers, URLs, reasons for omission and industry standards requirements. The index is not a last-minute appendix but should be used as a completeness check during the material planning phase.

How should major themes be identified?

1. Understand the organizational situation

Take stock of organizational activities, products, services, locations, value chains, business relationships, industries and regulations to establish the scope within which an impact is likely to occur.

2. Identify actual and potential impacts

Collect operational data, complaints, audits, incidents, suppliers, media, research, regulations and stakeholder information to identify positive and negative impacts, including human rights impacts.

3. Assess the significance of the impact

The severity of actual negative impacts will be considered, while the severity and likelihood of occurrence of potential negative impacts will be considered. Positive impacts should also be assessed in terms of scale, scope and likelihood.

4. Sort and identify major themes

The company sorts the impact according to the degree of significance and determines the reporting threshold, and verifies it with internal and external experts and stakeholders. Key thematic results should be understood and approved by the board of directors or senior management.

Questionnaire is only one source of information

Stakeholder questionnaires can provide an understanding of the level of concern, but they cannot replace a company’s due diligence on actual and potential impacts. Simply making a matrix based on the average questionnaire scores may overlook serious but unfamiliar or unpopular issues.

What information needs to be collected for a sustainability report?

Governance and Economics

Organizational structure, board oversight, ethics and integrity, risk, operational performance, taxation, anti-corruption and regulatory compliance.

Environment

Greenhouse gases, energy, water, biodiversity, raw materials, waste, pollution, product life cycle and supply chain environmental data.

Crowds and Human Rights

Employee structure, remuneration, diversity and equality, training, occupational safety, industrial relations, grievances, human rights due diligence, community and supply chain labor conditions.

Products and Customers

Quality, safety, privacy, information security, customer satisfaction, responsible marketing, product recalls and innovation.

Each data should define the reporting boundary, statistical period, unit, calculation method, responsible department, reviewer and supporting evidence. If annual data are restated or estimated, the reasons and methods need to be retained.

What GRI updates from 2026 to 2027 need attention?

GRI 101 Biodiversity

The new version of GRI 101 will be effective from January 2026, strengthening location, value chain, biodiversity impacts, drivers and management information. Companies involved in land, water, raw materials, agriculture, forestry, fisheries, mining, construction or supply chains need to prepare location and natural data in advance.

GRI 102 Climate Change and GRI 103 Energy

GRI will release a new version of its climate and energy theme guidelines in 2025, which will be applicable to reporting starting in January 2027. Companies should assess whether existing carbon emissions, transition plans, climate impact, energy and just transition data are sufficient to support the new requirements.

Establish guideline version management

Before starting the report every year, the version and effective date of GRI general, industry and subject standards should be confirmed, and the adopted version and conversion judgment should be recorded to avoid gaps caused by the use of old forms.

How to integrate GRI and IFRS S1/S2?

GRI focuses on the significant impact of enterprises on the economy, environment and people; IFRS S1/S2 focuses on sustainable risk opportunities that can reasonably be expected to affect the prospects of enterprises. The two views may overlap, but are not directly substitutes for each other.

Integration practices can include:

Share organization, location, value chain and reporting period data
Shared governance, policies, goals, emissions and performance indicators
Preserve both impact and financial assessment results in the materiality process
Establish disclosure comparisons between GRI, IFRS, SASB and Taiwan indicators
Use the same data dictionary, supporting evidence and review process
Write content based on user needs and check consistency

Frequently asked questions about corporate sustainability reports

The report content is like a collection of department achievements

Each department provides photos and results of activities, but does not link major impacts, policies, goals and data, making it difficult for the report to present the company’s true sustainable management.

Major topics are ranked only according to the questionnaire

Questionnaire attention is not equal to the significance of the impact. Businesses need to be reinforced with evidence of impact, industry, value chain, appeals and expert judgment.

Data boundaries and definitions change every year

Different departments may use different calibers such as number of persons, number of people, amount or proportion. Without a data dictionary and change records, annual comparisons and assurances are prone to problems.

Reports, annual reports and official website statements are inconsistent

Using different periods or numbers in different documents for carbon emissions, workforce, targets or governance information will reduce credibility. Cross-file consistency checks should be performed before publishing.

Don’t start looking for evidence until you are convinced

Organizing invoices, system reports, meeting minutes and calculation files is only done at the end of the year, which is prone to delays. Support requirements and review processes should be established during the data collection phase.

How does Startrust assist enterprises in importing?

1. Project initiation and confirmation of applicable requirements

Confirm the reporting period, organizational boundaries, Taiwan working methods, GRI version, industry standards, industry indicators, IFRS connection and assurance needs.

2. Organizational situation and value chain inventory

Understand the company’s activities, products, locations, suppliers, customers and business relationships, and establish the scope of possible impacts and data sources.

3. Stakeholders and major themes

Plan negotiation methods, collect internal and external evidence, identify and evaluate actual and potential impacts, and complete the ranking, verification and confirmation of governance of major topics.

4. Report structure and data form

Establish chapters, GRI disclosure matrix, industry requirements, data dictionary, department responsibilities, reporting schedule, supporting evidence and review process.

5. Department interviews and data collection

Help departments understand the purpose of disclosure and compile policies, management methods, indicators, cases and data through briefing sessions, interviews and workshops.

6. Content writing and data checking

Transform information into clear, consistent and evidence-based content, checking data boundaries, formulas, units, year-to-year comparisons and cross-section consistency.

7. Design, proofreading and GRI indexing

Complete content arrangement, graphics, text and number proofreading, and create GRI content index and necessary comparison tables to avoid data misplacement during the design process.

8. Confirmation, governance approval and reporting support

Assist in sorting out sampled information, respond to improvement matters, complete management or board of directors procedures, and prepare declaration files in accordance with regulations.

Coaching content and deliverables

Main counseling work

Confirmation of Taiwan’s working practices, GRI and industry requirements
Report scope, period and stakeholder inventory
Major impact identification, assessment and theme identification
Information forms, data dictionaries and supporting requirements
Department interviews, education training and progress management
Report writing, data and cross-document review
Comparison of GRI content index and industry indicators
Third-party assurance, governance approval and filing preparation

Expected deliverables

Project plan, timeline and responsibility matrix
List of applicable standards and disclosure requirements
Stakeholders and negotiation planning
Impact list, assessment results and key themes
Report chapters and GRI disclosure matrix
Cross-department information forms and data dictionaries
Complete transcript of the sustainability report
GRI content index and other comparison tables
Data, text and cross-document check lists
Confirm and prepare documents for formal declaration

The delivery content is confirmed based on the enterprise size, industry, applicable specifications, design division of labor and scope of assurance; third-party assurance opinions are issued by institutions that meet the requirements and remain independent.

What changes can be brought about after importing?

From chasing information at the end of the year to a fixed annual reporting process

Departments clearly understand data definitions, responsibilities, deadlines and supporting evidence, and managers can keep track of progress and gaps.

From listing results to managing major impacts

The report content links the company’s value chain, major themes, policies, goals, actions and results, allowing readers to understand how companies manage their impacts responsibly.

Change from using different numbers in different files to shared trusted information

Sustainability reports, annual reports, IFRS disclosures and customer questionnaires can use the same underlying data and then output according to different standards.

From supplementing documents before being convinced to accumulating daily evidence

Each important data can be traced back to the source, calculation, review and approval, shortening the preparation time for assurance.

From one report per year to continuous performance management

Major themes and indicators can be entered into management meetings and digital systems to continuously track goals, improvements and risks.

Why choose Startrust?

Startrust also has sustainability consulting, carbon management, energy, supply chain and information system capabilities, which can help companies transform GRI requirements into actual data processes, instead of just being responsible for text editing or visual layout.

When multiple people are required to fill in reports, content review and version management are required, the Sustainability Report Co-editing Module can be used; when major themes, indicators and goals need to be continuously tracked, the Sustainability Performance Management Module can be used.

FAQ

Which Taiwanese companies need to prepare sustainability reports?

All listed companies are required to prepare and report from 2025; listed companies and other specific organizations should confirm according to their applicable standards. Companies still need to review industry indicators, assurances and reporting requirements.

Does the sustainability report have to use GRI?

The operating procedures for listed companies in Taiwan are required to be prepared in accordance with GRI general, industry and major subject standards. Non-applicable objects can voluntarily adopt it, but if they declare to follow GRI, they still need to comply with GRI-related requirements.

Can major topics be decided using only questionnaires?

Not recommended. GRI requirements are based on the actual and potential impacts of the enterprise and their significance. The stakeholder questionnaire is only one source of information.

Can GRI and IFRS S1/S2 be included in the same report?

They can be integrated or cross-referenced according to the disclosure location allowed by the competent authority, but they must meet the user, materiality and content requirements of the two sets of standards, and the index must be clearly marked.

Does the sustainability report require third-party confirmation?

Depends on legislation, industry and disclosure items. Enterprises should confirm the latest applicable requirements; even if it is not mandatory, they can also voluntarily confirm specific indicators based on the needs of stakeholders.

Which departments need to be involved in the first preparation?

It usually includes sustainability, finance, human resources, environmental safety and health, factory affairs, procurement, supply chain, legal affairs, information security, marketing and internal audit, and management and resources are provided by the management.

How long does it take to prepare a sustainability report?

Depends on the size of the enterprise, material themes, data maturity, departmental responses, design and scope of assurance. The first preparation usually requires a lot of inventory and process establishment. You should first evaluate the readiness and then arrange the schedule.

If you are preparing to prepare or update a report for the first time, you can first provide the most recent annual report, sustainability information, organizational structure, stakeholders, major themes, confirmed needs and expected reporting time, and a consultant will assist in a readiness assessment.

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