Validation: Qualitative
Manual evidence validation and Reporting Boundaries Review
Manual Evidence Validation
Validation Scope
What is manually validated?
GRESB and subject matter experts from Sustainability Assurance Services (SAS) manually verify the following content:
Evidence uploaded to the indicators that require it. In most cases, GRESB and its third-party validation provider validate this evidence against GRESB’s requirements. Refer to the' Criteria' section below for a summary of indicators subject to manual validation and their specific requirements.
All scored ‘Other’ answers. Most indicators allow participants to report an additional option if it is not already included in the indicator’s assessment choices. These ‘Other’ answers are also subject to manual validation. ‘Other’ answers should not be duplicates or subsets of existing options. Multiple ‘Other’ answers can be reported, but only one will count toward the final score, as long as it meets the acceptance criteria.
Information related to third parties, such as assurance, audit, and certification standards.
Validation Criteria
Evidence Format
Document: Participants may upload multiple documents of any file type. GRESB encourages participants to follow the following documentation best practices to ensure that validators can identify relevant information as efficiently and clearly as possible:
Use an evidence cover page (see GRESB’s template here) or open text box to specify where evidence for each selection can be found.
Participants may upload evidence as a document or active hyperlink.
When using multiple documents, consolidate them into one file (but avoid using zip files).
Make sure section headings and page numbers are clear.
Hyperlink: The evidence must be accessible within two clicks. Note that to support selections about public availability, participants must upload a hyperlink.
Reporting Year Applicability
Regardless of whether the indicator is manually validated, all* assessment answers must refer to the reporting year identified in indicator EC4: Reporting year.
*Several indicators, however, have different reporting year requirements and may refer to the past three calendar years or fiscal years, including the current one, depending on the entity's reporting period selection: RM3.1-3.6: Climate-related Risk Management; SE3: Employee satisfaction monitoring.
A response to an indicator must be true at the close of the reporting year; however, the response does not need to have been true for the entire reporting year. For example, if a policy was put in place one month prior to the end of the reporting year, this is acceptable, it need not have been in place for the entire reporting year.
For manually validated indicators, it is mandatory to clearly specify the year to which the evidence corresponds within the evidence or open text box.
Static Fund Assessment
GRESB has created a more static Fund Assessment that reduces reporting burden by ensuring funds only need to report relevant and material updates. This means that all indicators subject to manual validation are pre-validated based on the validation outcomes from the previous year.
This applies to the following indicators:
Responsible Investment Strategy (LE2)
Personnel Sustainability Performance Targets (LE4)
Policies on Environmental Issues (PO1)\
Sustainability Due Diligence for New Acquisitions (RM1.1)
Sustainability-Related Risks and Opportunities in Investment Monitoring Processes/Asset Management (RM1.2)
Transition Risk Identification (RM3.1)
Transition Risk Impact Assessment (RM3.2)
Physical Risk Identification (RM3.3)
Physical Risk Impact Assessment (RM3.4)
Climate-Related Opportunities Identification (RM3.5)
Climate-Related Opportunities Impact Assessment (RM3.6)
Entities that either (1) achieved full points in the previous submission or (2) achieved partial points but do not wish to modify their responses or supporting evidence can pre-fill these indicators and leave them unchanged in the current assessment cycle.
So long as the indicator response and documentation remain consistent (i.e., the entity does not modify its selections or evidence), GRESB will automatically reapply the previous year's validation decision.
Scenario (1) - Entities that previously earned full points: changing any selections or evidence will not affect the validation decision. In practice, this means that an entity could:
Leave the same links to policy documents, even if some links are no longer active,
Replace last year’s links with inactive ones, or
Replace last year’s documents with blank files — and still receive full acceptance for 2025.
However, an entity cannot:
Remove the previously provided links and supply no evidence this year. Once an entity selects 'Yes’ for PO1–3, the portal will continue requiring supporting documentation.
Scenario (2) - Entities that previously earned partial points: changing the indicator response and/or documentation will prompt GRESB to re-validate the indicator.
Please note that GRESB encourages participants to update their evidence if there have been any material changes to the policy that the entity wishes to present to investors.
Note: for Sustainability Reporting (RP1) indicator this change will be implemented in 2027.
Read more in the 2026 Fund Standard Updates.
Reporting Entity Applicability
Answers must directly apply to the entity identified in EC1, i.e., the investable entity for which participants submit an Assessment response, regardless of whether the indicator is manually validated.
When a participating entity belongs to a larger investment management organization or group of companies (the 'organization'), it must clearly explain the relationship between the entity and the organization. This ensures that group-level answers or evidence are appropriately linked to the reporting entity. This clarification can be provided within the evidence itself or in an open text box.
Note for indicators in the ‘Climate-related Risk Management’ section of the Risk Management Aspect (i.e., transition and physical risk identification and impact assessment): GRESB requires evidence to be specific to the reporting entity identified in EC1. References to the overarching organization cannot be used as substitutes for entity-level risk assessment outcomes.
Language
As of 2025, GRESB accepts evidence in any language. However, the systems must be able to read the text contained in the file. Information or text contained in pictures will only be accepted if accompanied by a translation.
Note that information provided in open text boxes that appear in the Benchmark Report will be displayed exactly as submitted, in the original language.
Summary of Indicator-Specific Requirements
The table below highlights the indicators manually validated in each infrastructure and offers a high-level summary of the validation requirements for each.
For detailed guidance on the evidence needed for each indicator, refer to the ‘Validation’ section specific to that indicator.
In addition to the summarized requirements listed below, it is mandatory that all submitted evidence clearly and directly supports each option selected by participants within every indicator.
Fund Assessment
LE2
Responsible Investment Strategy
Formally adopted approach to sustainable investment for each selected strategy.
LE4
Personnel Sustainability Performance Targets
Sustainability targets must be explicitly tied to the selected personnel groups.
Applicability must cover all members within the selected group. If targets apply to a single individual within a group, report under "Other".
Financial consequences must be linked to sustainability targets and specified.
PO1
Environmental Policies
Formal policy documents addressing Net Zero.
General goals/commitments are not considered formal policies.
RP1
Sustainability Reporting
Documentation must disclose sustainability performance and/or actions; a list of objectives is not appropriate.
References the selected reporting level, alignment, and third-party review type.
RM1.1
Sustainability Due Diligence for New Acquisitions
Meets the disclosure-type-specific requirements, such as: Integrated reports, Annual reports, Standalone sustainability reports, and Dedicated sections on corporate websites.
Describes a formal due diligence process that highlights selected sustainability issues.
Sustainability risks and opportunities are identified, analyzed, evaluated, and treated.
RM3.1
Transition Risk Identification
Demonstrate a systematic transition risk identification process.
List the outcomes of the assessment, including the identified transition risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM3.2
Transition Risk Impact Assessment
Demonstrate a systematic transition risk impact process.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM3.3
Physical Risk Identification
Demonstrate a systematic physical risk identification process.
List the outcomes of the assessment, including the identified physical risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM3.4
Physical Risk Impact Assessment
Demonstrate a systematic process for assessing the financial impacts of physical risks.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM3.5
Climate-Related Opportunities Identification
Demonstrate a systematic climate-related opportunity identification process.
List the outcomes of the assessment, including the identified climate-related opportunities risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM3.6
Climate-Related Opportunities Impact Assessment
Demonstrate a systematic process for assessing the financial impacts of climate-related opportunities.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
Asset Assessment
Indicator
Indicator Title
Requirement Summary
LE2
Sustainability Objectives
Actionable sustainability objectives must relate to specific issues within the selected topics.
Objectives must have been formally adopted and/or implemented.
LE4
Personnel Sustainability Performance Targets
Sustainability targets must be explicitly tied to the selected personnel groups.
Applicability must cover all members within the selected group. If targets apply to a single individual within a group, report under "Other".
Financial consequences must be linked to sustainability targets and specified.
PO1,
PO2,
PO3
Environmental, Social and Governance Policies
Formal policy documents must address each selected issue.
General goals/commitments are not considered formal policies.
RP1
Sustainability Reporting
Documentation must disclose sustainability performance and/or actions; a list of objectives is not appropriate.
References the selected reporting level, alignment, and third-party review type.
Meets the disclosure-type-specific requirements, such as: Integrated reports, Annual reports, Standalone sustainability reports, and Dedicated sections on corporate websites.
RM1
Environmental Management System (EMS)
Demonstrates proof of formal alignment or accreditation to the selected standards.
Alignment: includes the name of the standard.
Accreditation: includes signed proof of certification including the name of standard, independent third-party, and date within the reporting period.
RM2.1
Environmental Risk Assessments
Confirm an environmental risk assessment was conducted within the last three years.
Clarifies elements of the risk assessment process and environmental issues that it covered.
Presents outcomes of the risk assessment.
RM2.2
Social Risk Assessments
Confirm a social risk assessment was conducted within the last three years.
Clarifies elements of the risk assessment process and social issues that it covered.
Presents outcomes of the risk assessment.
RM2.3
Governance Risk Assessments
Confirm a governance risk assessment was conducted within the last three years.
Clarifies elements of the risk assessment process and governance issues that it covered.
Presents outcomes of the risk assessment.
RM4.1
Transition Risk Identification
Demonstrate a systematic transition risk identification process.
List the outcomes of the assessment, including the identified transition risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.2
Transition Risk Impact Assessment
Demonstrate a systematic transition risk impact process.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.3
Physical Risk Identification
Demonstrate a systematic physical risk identification process.
List the outcomes of the assessment, including the identified physical risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.4
Physical Risk Impact Assessment
Demonstrate a systematic process for assessing the financial impacts of physical risks.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.5
Climate-Related Opportunities Identification
Demonstrate a systematic climate-related opportunity identification process.
List the outcomes of the assessment, including the identified climate-related opportunities risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.6
Climate-Related Opportunities Impact Assessment
Demonstrate a systematic process for assessing the financial impacts of climate-related opportunities.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
GH1
Greenhouse Gas Emissions
For relatively large assets only (based on RC7 materiality assessment):
Provide proof of third-party Scope 1 and 2 data review, review type (assured, verified, checked), and confirmation it covers the reporting entity.
Checked: independent third-party review of reported data and collection methods.
Assured/verified: accredited professional review against a standard.
Development Asset Assessment
LE2
Sustainability Objectives
Applicable sustainability objectives must relate to specific issues within the selected options.
Objectives must have been formally adopted and/or implemented.
LE4
Personnel Sustainability Performance Targets
Sustainability targets must be explicitly tied to the selected personnel groups.
Applicability must cover all members within the associated group. If targets apply to a single individual within a group, report under "Other".
Financial consequences must be linked to sustainability targets and specified.
RP1
Sustainability Reporting
Documentation must disclose sustainability performance and/or actions; a list of objectives is not appropriate.
References the selected reporting level, alignment, and third-party review type.
Meets disclosure-type-specific requirements, such as: Integrated reports, Annual reports, Standalone sustainability reports, Dedicated sections on corporate websites.
RM1
Environmental Management System (EMS)
Demonstrates proof of formal alignment or integration into the framework of the EMS.
Accreditation includes uploaded certification, referencing name of standard, independent third-party, and date within the reporting period.
RM2.1
Environmental Risk Assessments
Details elements of the risk assessment process and environmental issues that it considers.
Confirm a standalone risk assessment was conducted within the last three years.
RM2.2
Social Risk Assessments
Details elements of the risk assessment process and social issues that it considers.
Confirm a standalone risk assessment was conducted within the last three years.
RM2.3
Governance Risk Assessments
Details elements of the risk assessment process and governance issues that it considers.
Confirm a standalone risk assessment was conducted within the last three years.
RM4.1
Transition Risk Identification
Demonstrate a systematic transition risk identification process.
List the outcomes of the assessment, including the identified transition risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.2
Transition Risk Impact Assessment
Demonstrate a systematic transition risk impact process.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.3
Physical Risk Identification
Demonstrate a systematic physical risk identification process.
List the outcomes of the assessment, including the identified physical risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.4
Physical Risk Impact Assessment
Demonstrate a systematic process for assessing the financial impacts of physical risks.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.5
Climate-Related Opportunities Identification
Demonstrate a systematic climate-related opportunity identification process.
List the outcomes of the assessment, including the identified climate-related opportunities risks, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
RM4.6
Climate-Related Opportunities Impact Assessment
Demonstrate a systematic process for assessing the financial impacts of climate-related opportunities.
List the outcomes of the assessment, including the identified financial impacts, or lack thereof.
Outcomes must be entity specific.
Must be applicable to reporting year, or two years prior.
GH1
Greenhouse Gas Emissions
Must include a regulatory scope (based on an internationally recognized standard).
Must include all operational Scope 1, 2, and relevant Scope 3 emissions (e.g., business travel, freight, etc.).
GHG emissions must cover a whole reporting period, expressed in CO2e values.
Aligned with defined industry standards.
Approved for third-party verification/professional review against a standard.
Validation Outcomes
What are the impacts of each validation decision?
Validators will make one of the three decisions below depending on the degree to which evidence meets GRESB’s requirements.
Each validation outcome corresponds with a scoring weight that impacts the indicator’s final score. See the Scoring Basics page for more information.
'Other' Answers
Accepted
'Other' answer falls outside the provided options and fulfills indicator requirements.
Full points
Duplicate
'Other' answer fulfills indicator requirements but duplicates an already selected answer.
No points will be awarded for this answer
Not Accepted
No points will be awarded for this answer'Other' answers do not fulfill indicator requirements.
No points will be awarded for this answer
Evidence and Open Text Boxes
Accepted
Evidence fully meets the validation requirements.
Full points, resulting in the application of the full multiplier (100%) to the indicator's score
Partially Accepted
Evidence fully meets general requirements but fails to meet some indicator-specific requirements and/or support all selected options.
Partial points, resulting in a reduced multiplier (50%) to the indicator's score
Not Accepted
Evidence does not meet general requirements and/or does not support the selected options.
No points, resulting in a 0 multiplier to the indicator's score
Download GRESB's Evidence Cover Page Template below:
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