ESG Reporting with GRI & ISSB for SMEs: Which Standard, What to Disclose (2026)
How Vietnamese SMEs can build a credible ESG report: GRI (impact materiality) vs ISSB/IFRS S1-S2 (financial materiality), which framework serves whom, Vietnam's Circular 96/2020/TT-BTC, and how to disclose without greenwashing under Vietnamese law.
July 13, 2026 · 13 phút

Photo: RDNE Stock project / Pexels (free license)
Quick summary
An ESG report discloses a company's Environmental (E), Social (S) and Governance (G) performance. The two dominant international standard families serve different purposes: GRI uses impact materiality (how the company affects the economy, environment and people) and serves all stakeholders; ISSB/IFRS S1 & S2 (issued 26 June 2023, effective for annual periods from 1 January 2024, with first-year relief) use financial materiality and serve investors. In Vietnam, public/listed companies already disclose ESG in annual reports under Circular 96/2020/TT-BTC; non-listed SMEs are not yet required, but EU partners and supply chains increasingly demand standardised reports. This article gives no specific ESG figures for any company — those depend on each firm's real data.
What ESG reporting is, and why the standard you pick matters
An ESG (or sustainability) report is how a company discloses its Environmental, Social and Governance impacts and performance in a structured way. A common SME mistake is writing a "nice-looking" report with no standard — the result is not comparable, not verifiable, and easily labelled greenwashing.
Two families of international standards dominate, and the key point is that they do not replace each other — they serve two different audiences:
- GRI (Global Reporting Initiative) answers: how does the company affect the outside world? It is the most widely used sustainability reporting standard, with over 10,000 reporters across more than 100 countries (Global Reporting Initiative).
- ISSB (IFRS S1 & S2) answers: how do sustainability matters affect enterprise value and cash flows? — i.e. it serves investors (IFRS Foundation).
SMEs don't need to "do both standards" at once. Decide who reads your report — customers and community → start with GRI; investors and banks → head toward ISSB. The good news: the two standards are being made interoperable.

How GRI and ISSB differ
Audience: GRI serves all stakeholders; ISSB (IFRS S1/S2) serves investors and capital markets. Materiality: GRI uses impact materiality (the company's impact on the economy, environment, people); ISSB uses financial materiality (effect on enterprise value) (GRI). The EU (CSRD/ESRS) combines both as double materiality (Deloitte, 27 Jun 2024).
Scope & timing: GRI is structured as Universal (GRI 1, 2, 3 — 2021), Sector, and Topic Standards. IFRS S1 & S2 were issued 26 June 2023, effective for annual periods beginning on/after 1 January 2024, subject to each jurisdiction's adoption, with first-year transition relief (climate-only / Scope 3) (IFRS Foundation).
| Criterion | GRI Standards | ISSB — IFRS S1 & S2 |
|---|---|---|
| Primary audience | All stakeholders (customers, community, employees, investors…) | Investors & capital markets |
| Materiality principle | Impact materiality — the company's impact on the economy, environment and people | Financial materiality — effect on enterprise value |
| Disclosure scope | Broad: E, S, G across the Topic Standards | S1: sustainability in general; S2: climate specifically (incl. Scope 1, 2, 3) |
| Timing / effective date | Universal 2021 edition (GRI 1, 2, 3); continuously updated via Topic/Sector | Issued 26 Jun 2023; applies to reporting periods from 1 Jan 2024 (subject to national adoption) |
| Nature | Voluntary (in many places), oriented toward impact transparency | Moving toward a legal mandate country by country; integrated with financial reporting |
Comparison sources: audience & materiality principle per Global Reporting Initiative and IFRS Foundation; issue & effective dates per IFRS Foundation.
The GRI standards structure: read the map before you go
| Family | Applies to | Main content |
|---|---|---|
| Universal Standards (GRI 1, 2, 3 — 2021) | All organisations | GRI 1 Foundation (principles & how to report); GRI 2 General Disclosures (organisational profile, governance); GRI 3 Material Topics (identifying & reporting material topics) |
| Sector Standards | By specific sector | Sustainability topics specific to a sector (e.g. oil & gas, agriculture, coal…) |
| Topic Standards | By the material topics selected | Disclosures for each topic (e.g. GRI 305 Emissions, plus water, labour, anti-corruption topics…) |
Source: the three-family structure per Global Reporting Initiative — Universal Standards. Standard process: start with GRI 1 & 2, use GRI 3 to select material topics, then report against the relevant Topic/Sector Standards — an SME need not disclose every topic, only those material to it.

Interoperability — good news for SMEs
GRI and the IFRS Foundation signed an MoU in 2022 and, on 24 May 2024, announced a deeper collaboration to deliver full interoperability (IFRS Foundation). For emissions specifically, a January 2024 resource shows GRI 305 and IFRS S2 are highly aligned, both drawing on the GHG Protocol (IFRS Foundation). So a company that has inventoried Scope 1-2-3 under the GHG Protocol does not start over when switching frameworks.
Vietnam's ESG reporting rules
Vietnam has not adopted ISSB into law, but mandatory ESG disclosure for the listed sector already exists. Circular 96/2020/TT-BTC (issued 16 Nov 2020, replacing Circular 155/2015) requires public/listed companies to disclose ESG content — including GHG emissions, energy, water, waste, labour and community — in their annual reports (Keslio). The State Securities Commission has issued GRI-based sustainability reporting guidance since 2015 (GREEN IN Vietnam). Non-listed SMEs are not yet required to file, but any "green" claim already falls under the Law on Protection of Consumer Rights 2023 (No. 19/2023/QH15, effective 1 July 2024), which prohibits false, incomplete or inaccurate information (LuatVietnam).
| Instrument / guidance | Role | Key points |
|---|---|---|
| Circular 96/2020/TT-BTC | Disclosure on the securities market | Issued 16 Nov 2020, replacing Circular 155/2015; public/listed companies disclose ESG (GHG emissions, energy, water, waste, labour, community) in their annual reports — Keslio |
| SSC's GRI guidance | Orientation for sustainability reporting | The State Securities Commission has provided GRI-based sustainability reporting guidance for listed companies since 2015 — GREEN IN Vietnam |
| Law on Protection of Consumer Rights 2023 (No. 19/2023/QH15) | Curbs false / misleading information | Issued 20 Jun 2023, effective 1 Jul 2024; prohibits deception or misleading through false, incomplete or inaccurate information about goods/services — LuatVietnam |
| Advertising Law & Environmental Protection Law 2020 | Basis against misleading environmental advertising | Prohibit advertising that misleads on characteristics or effects — applies to every "green" claim |
A 5-step ESG reporting roadmap for SMEs
| Step | What to do | Output |
|---|---|---|
| 1. Choose the standard & audience | Identify who reads it (customers / investors / EU partners) → choose GRI, ISSB, or both (leveraging interoperability) | A decision on the reporting framework |
| 2. Assess materiality | Use GRI 3 (impact) and/or the ISSB financial lens; consult stakeholders | A list of material topics |
| 3. Collect & measure data | E data (emissions per the GHG Protocol, energy, water, waste), S (labour, safety), G (governance, anti-corruption) | A dataset with sources & methodology |
| 4. Draft the report to standard | Present per GRI Topic Standards / IFRS S1-S2; state scope, period and methodology clearly | A draft ESG report |
| 5. Assure & publish | Review against greenwashing; consider independent assurance; publish (standalone or within the annual report) | A published ESG report |
Anti-greenwashing
Every published figure or "green" claim must be measurable, sourced and scope-transparent. Under Vietnamese law (Advertising Law, Consumer Rights Protection Law 2023, Environmental Protection Law 2020), misleading environmental claims are prohibited, and marketing claims must match the numbers in the report. This article therefore gives no specific ESG figures for any sample company — those depend on real activity data and must be measured, computed and sourced by each business.
Frequently asked questions
GRI or ISSB — which should an SME pick first?
It depends on who reads your report. Customers/community focused on impact → start with GRI. Investors/banks → head toward ISSB (IFRS S1-S2). Because the two standards are being made interoperable (announced 24 May 2024), the data you collect is reusable for both.
How do "impact materiality" and "financial materiality" differ?
Impact materiality (GRI) looks at how the company affects the economy/environment/people, even when there is no financial effect yet. Financial materiality (ISSB) looks at how sustainability matters affect enterprise value. The EU combines both as "double materiality".
Are non-listed SMEs in Vietnam required to produce an ESG report?
Not yet. Circular 96/2020/TT-BTC applies to public/listed companies (ESG disclosure in annual reports). Non-listed SMEs are not yet required, but they fall into scope when they list or issue public bonds, and any "green" claim already falls under the Law on Protection of Consumer Rights 2023.
When did IFRS S1 & S2 take effect?
The ISSB issued IFRS S1 & S2 on 26 June 2023, for annual reporting periods beginning on or after 1 January 2024 — but actual application depends on each jurisdiction's adoption, with first-year relief (climate-only/Scope 3).
If I already report under GRI, do I start over for ISSB?
Not really. For emissions, GRI 305 and IFRS S2 are highly aligned, both based on the GHG Protocol — Scope 1-2-3 data is reusable. That is the goal of "full interoperability" between GRI and the IFRS Foundation.
References
- Global Reporting Initiative — Standards
- GRI — Universal Standards
- GRI — Understanding materiality
- IFRS Foundation — IFRS S1 supporting materials
- IFRS Foundation — IFRS S2 supporting materials
- IFRS Foundation — GRI/IFRS full interoperability
- IFRS Foundation — Emissions reporting GRI & ISSB
- Deloitte — Double materiality (CSRD/ESRS)
- Keslio — Sustainability Reporting in Vietnam
- GREEN IN Vietnam — ESG reporting regulations
- LuatVietnam — Law 19/2023/QH15 (Consumer Rights)