2026 Fund Standard Updates

Introduction

Updates to the GRESB Infrastructure Standards maintain the direction of travel established by the GRESB Foundation. The 2026 Infrastructure Fund updates focus on significantly reducing the reporting burden for participants while retaining and adding value to the assessment and reports over the long term and still rewarding best practices. The first step taken for the 2026 Infrastructure Fund Standard is to make the assessment more static, requiring less annual input from managers, particularly if no material change or actions have occurred. Ultimately, the GRESB Infrastructure Fund Assessment will aim to be a hygiene check and an aggregation tool, allowing a shift in both reporting and scoring efforts towards performance at the asset level.

Summary of Updates

Click on each indicator code for detailed information about the summarized updates below.

Topic	Indicator	Description	Reporting Impact	Validation Impact	Scoring Impact
Static Fund Assessment	All	Elimination of the need to annually update the fund assessment by pre-filling it completely.	Funds may seamlessly submit a pre-filled response, so long as they have not materially changed their management practices. Each update in this table helps enable the fund assessment to become static.
Evidence Requirements	RM1.1-2, RM3.1-3.6	Removal of the reporting-year-applicability requirement for evidence.	Participants may choose against uploading new evidence when policies and management practices remain materially consistent.
Incident Reporting	RP2.2	Indicator removed.	Reduced reporting burden
Stakeholder Engagement	SE2	Removal of dynamic data points for the percentage of employees who receive training.	Participants are no longer required to report time-sensitive metrics.
Stakeholder Engagement	SE3	Removal of dynamic data points for survey coverage and response rate.	Participants are no longer required to report time-sensitive metrics.
Stakeholder Engagement	SE4	Removal of dynamic data points for gender ratio and age group discrimination.	Participants are no longer required to report time-sensitive metrics.
Portfolio Coverage	RC6	Recognition of two new reasons to validly exclude assets from contributing to the Fund Score: Non-infrastructure asset Disclosure of data prohibited due to national security restrictions	None
Sustainability Reporting	RP1	Indicator simplified so that only one disclosure type is required. List of third-party standards expanded to include SFDR.	Participants are only required to identify elements of a single sustainability report.
Climate Resilience	RM2	Updated climate scenarios to reflect most recent NGFS data and discontinuation of the 2°C scenario from CRREM.	Participants may select the most recent climate scenarios.

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Static Fund Assessment

All indicators

Background & Purpose

Analysis of our reporting data shows that almost all funds reporting management practices in the GRESB Fund Assessment do not regress in terms of scoring, instead maintaining or improving practices over time. Discussions with the GRESB Foundation confirmed that sustainability practices are unlikely to change significantly after a fund has been launched.

Description

GRESB is moving toward creating a more static Fund Assessment that reduces reporting burden by ensuring that funds only need to report on relevant and material updates, rather than expecting all fund participants to provide annual evidence even when no changes have taken place.

To reduce reporting burden further, a shift to a more static assessment will include removing any annual data from the fund level and focusing on the collection of this same information at the asset level, where performance can be measured.

As a result, from 2026, all fund participating in the Fund Assessment will have the opportunity to pre-fill all indicators. If a participant has not made any material changes from one submission year to the next, they will be able to confirm this and submit their Fund Assessment with pre-filled data from the previous year, with no change in outcome. If participants have any material changes to their management practices (i.e., changes in practice, which impact their GRESB submission), they must update their responses to reflect this, and these changes will be assessed by GRESB.

These shifts position the Fund Assessment as a check on critical management sustainability objectives, continuing to assess new participants, but not enforcing continual retesting of more mature funds whose practices remain unchanged.

This approach will minimize reporting burden for mature funds on content that does not change, while still enabling the provision of future updates based on the latest sustainability practices.

To support this transition toward a more static Fund Assessment, GRESB will implement the following set of changes:

• Updates to validation requirements: Introduction of pre-validation for all indicators in the Fund Assessment.

• Indicator and data removals: Removal of all dynamic data from the Fund Assessment to allow for full prefill and easy submission.

• Prefill enhancements: Prefill of all fund assessment indicators with the previous year’s data, allowing for a quick submission for the funds that had no material changes to their management practices and have no updates that they wish to report.

Changes to Validation Requirements to Avoid Repetitive Annual Evidence Uploads

RM1.1-2, RM3.1-3.6

Background & Purpose

Manual validation takes place after assessment submission and consists of document and text review to ensure that sufficient evidence supports the answers provided in the assessment when required. As a rule, all evidence must refer to the reporting year identified in indicator EC4 Reporting Year, unless stated otherwise. Since funds rarely change their management practices, an annual review of the same policies and processes does not add value to the GRESB assessment, yet it significantly increases reporting burden for participants via annual evidence upload, work behind the scenes to update internal policies and documentation, and increasing the risk of human error during reupload or manual review.

Description

In 2026, validation rules will be changed for the following eight indicators to allow pre-validation based on the previous year's validation outcomes:

• Sustainability Due Diligence for New Acquisitions (RM1.1)

• Sustainability Risks and Opportunities in Investment Monitoring Processes/Asset Management (RM1.2) - No evidence required; only the open text boxes are subject to validation.

• 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)

Note: for the Sustainability Reporting (RP1) indicator, this change will be implemented in 2027.

Reporting Impact

1. Lower reporting burden for mature GRESB funds.

For example, if the fund reissues the same policy signed with a new year on an annual basis, this is not considered a material change, and they are not required to re-upload this evidence annually. If the fund changes the content of the policy, this is considered a material change— The entity should re-upload new evidence, and GRESB will manually validate it.

This means that 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.

1. No reporting impact for new participants.

Scoring Impact

None.

Future Development

For the Sustainability Reporting (RP1) indicator, this change will be implemented in 2027.

Removal of ESG Incident Occurrences Indicator

RP2.2

Background & Purpose

The purpose of the ESG Incident Occurrences Indicator (RP2.2) is to ensure the communication of any ESG-related misconduct, penalties, incidents, accidents, or breaches against the codes of conduct/ethics to the reporting entity’s investor.

Since GRESB’s intent is to remove dynamic data points from the Fund Assessment and to replace them with the assessment of management practices, this indicator will be completely removed from the Fund Standard for the following reasons:

• There is a separate, scored, indicator to assess fund management practices Sustainability-Related Incident Monitoring (RP2.1).

• The indicator includes dynamic data that requires annual reporting (total number of cases occurred, total value of penalties, pending investigations).

• Sustainability incidents are more prominent at the asset level where there is ongoing management of real assets, and a review of evidence suggests that no incidents have been reported that related to actions taken at the fund level.

• Fund participants tend to report aggregation of asset-level incidents in the Fund Assessment. This results in double reporting, since GRESB aggregates asset-level data automatically.

• The same indicator exists on an asset level. The incident data reported on an asset level is aggregated on a Fund Assessment level in the fund performance.

• The indicator is not scored.

Description

The indicator RP2.2 ESG Incident Occurrences will be removed from the Fund Assessment.

Reporting Impact

Lower reporting burden due to the removal of the indicator.

Scoring Impact

None.

Reporting on the Management Practices Instead of Annual Performance Data in Employee Training Indicator

SE2

Background & Purpose

This indicator examines the types and content of training received by employees responsible. With the transfer to a static Fund Assessment, this indicator has been reviewed to focus on the fund’s management practices and not on annual training data, hence all dynamic data points will be replaced with static checkboxes. Note that this dynamic information is still collected and aggregated at the underlying asset level.

Description

The following metrics will be removed from the Fund Assessment indicator SE2:

• Percentage of employees who received professional training in the reporting year

• Percentage of employees who received sustainability-related training in the reporting year

The indicator will be prefilled with the previous year’s data and pre-validated with no need to provide annual updates unless there are changes to the fund’s practices in relation to this indicator.

Reporting Impact

Reporting annual data on the percentages of employees who received professional or sustainability training will not be required; participants will have to report on the types of training conducted instead.

The indicator will be fully prefilled, with no changes to the reported data required in the following years. This will simplify assessment completion and allow for a more static Fund Assessment.

Scoring Impact

Points will be awarded based on answering “Yes” to “Does the entity provide training and development for employees?” and choosing applicable types of training from the list.

Focusing on the Management Practices and Removing Dynamic Data from Employee Satisfaction Monitoring Indicator

SE3

Background & Purpose

This indicator examines whether and to what extent the entity engages with employees regarding their satisfaction. With the transition to a more static Fund Assessment, this indicator has been reviewed to focus on the fund’s management practices and not on annual survey data, hence all dynamic data points will be removed from this indicator. Note that this dynamic information is still collected and aggregated at the underlying asset level.

Description

The following metrics will be removed from the Fund Assessment indicator SE3:

• Percentage of employees covered by the internal employee satisfaction survey

• Survey response rate to internal survey

• Percentage of employees covered by the third-party employee satisfaction survey

• Survey response rate to a third-party survey

The indicator will be prefilled with the previous year’s data, with no need to provide annual updates unless there are changes to the fund’s practices in relation to this indicator.

Reporting Impact

Points will be awarded based on reporting of the survey type and noting the types of metrics included. Since the information has been removed, reporting of percentages of employees covered by the surveys and survey response rates will not be required to receive points for this indicator.

Scoring Impact

The indicator will be fully prefilled, with no changes to the reported data required on an annual basis. This will simplify assessment completion and allow for a more static Fund Assessment.

Removing Dynamic Data from Human Capital Indicator

SE4

Background & Purpose

This indicator examines whether and to what extent the entity engages with employees regarding their satisfaction. With the transition to a more static Fund Assessment, this indicator has been reviewed to focus on the fund’s management practices and not on annual survey data, hence all dynamic data points will be removed from this indicator. Note that this dynamic information is still collected and aggregated at the underlying asset level.

Description

The following metrics will be removed from the Fund Assessment indicator SE4:

• Entity’s governance bodies: Percentage of employees that identify as women or men

• Organization's employees: Percentage of employees that identify as women or men

• Organization's employees: Percentage of employees that are:

  • Under 30 years old

  • Between 30 and 50 years old

  • Over 50 years old

Reporting Impact

Reduced reporting burden due to the removal of seven data fields. The indicator will be fully prefilled, with no changes to the reported data required on an annual basis. This will simplify assessment completion and allow for a more static Fund Assessment.

Scoring Impact

None.

New Exclusion Reasons

RC6

Background & Purpose

To achieve a maximum Fund Score, funds must report 100% of assets within their portfolio to GRESB. Reporting less than full coverage results in a score reduction equal to the percentage weight of the unreported asset(s). Participants have the option to exclude specific assets from contributing to the Performance Component Score and from the portfolio coverage if they have a reason permitted by the GRESB Standards. GRESB has received feedback from members regarding some types of assets that can’t be reported to the GRESB Assessment for different reasons and may result in score penalties or in funds not reporting to GRESB as they have no formal exclusion reason. In response to this feedback, GRESB is introducing an update allowing GRESB Fund Participants to exclude certain assets.

Description

Starting in 2026, two new exclusion reasons will be introduced:

• Non-infrastructure asset—for assets that are not infrastructure investments and are therefore not suitable for the GRESB Infrastructure Assessment.

  • Feedback received from multiple members indicates that their infrastructure portfolios consist not only of real assets covered by GRESB sector classifications, but also other investments that are not infrastructure or "real” assets. This exclusion reason is introduced to exclude other investments from the portfolio coverage. Example of use: a tech/software company or service provider that is a part of the same portfolio as infrastructure assets.

• Disclosure of data prohibited due to national security restrictions—where disclosure is prohibited by national security regulations or restrictions imposed by a national authority.

  • This exclusion reason is introduced in response to the feedback on regulatory restrictions in disclosing data on certain assets due to national security reasons. Example of use: an asset serving military facilities where asset-level data is a matter of national security and is restricted.

The use of both exclusion reasons is subject to a check by GRESB to ensure their valid implementation. If an asset is unable to provide evidence detailing why they have used the exclusion reason following outreach from GRESB, they will be informed that this is not a valid reason for future submissions.

Reporting Impact

If choosing one of the new exclusion reasons, the participants must provide supporting evidence if requested by GRESB.

Scoring Impact

Portfolio coverage will not be impacted if the Fund is not reporting these two types of assets. Scoring is reweighted across the rest of the portfolio.

Simplification of Sustainability Reporting Indicator

RP1

Background & Purpose

The intent of the Sustainability Reporting (RP1) indicator is to assess the level of sustainability disclosure undertaken by the entity, including disclosure of sustainability actions and performance. Given the complex and comprehensive nature of the content within the indicator, and recognizing that its scoring system does not always award best practice, the indicator will be streamlined and updated to reduce reporting burden and reward only best practice.

The changes will shift the focus from awarding entities based on the number of channels through which they report sustainability data to recognizing the quality and reach of their disclosures.

Description

GRESB will ask participating funds to report only on one sustainability report that will be assessed on aspects that are deemed to be best practice, including the level of reporting (group or entity), whether reporting to the public or only to investors, alignment to recognized third-party guidelines, and third-party review.

In addition, the list of accepted third-party standards/frameworks will be updated to include the Sustainable Finance Disclosure Regulation (SFDR).

Reporting Impact

In 2026, the prefill feature will not be available for this indicator due to the change of the indicator structure. From 2027 onwards, this indicator will be subject to prefill and pre-validation. As a result, reporting burden decreases for funds with over 60 data fields removed from the survey. Participants will report on only one sustainability disclosure applicable specifically for the reporting entity and only in the first year, unless their reporting practices change over the years.

Scoring Impact

Only one report will be scored as follows, instead of rewarding a number of different disclosures:

• The level of reporting: Entity-level reporting will be scored higher than group level. Group-level reports shall be accepted and can be reported as entity level if containing specific and detailed actions/performance of the entity.

• Stakeholder outreach: Public reporting will be scored higher than reporting only to investors. GRESB considers the report to be public if the information is publicly accessible on the internet.

• Alignment to a recognized third-party guideline: A full score will be rewarded where the entity aligns to a guideline from the drop-down list in the portal.

• Third-party review: A full score will be awarded for third-party verification and assurance; fractional scores will be awarded if the disclosure is checked by a third party.

• Evidence: The evidence will be subject to manual validation. The validation status of the evidence will affect the final score for the indicator through a multiplier. From 2027 onwards, GRESB will reuse previous year validation outcomes, unless participants report changes to their reporting practices.

The expected impact on average Fund Assessment Scores is approximately -0.47 points on average:

Scenario	Max Score Change (p)	Average Score Change (p)
The report is group level	-0.27	-0.14
The report is only for investors	-0.27	-0.04
The report is not aligned to a recognized guideline	-1.30	-0.10
The report is not reviewed by a third party	-0.54	-0.19

Future Development

The addition of the “Other guideline” option to the third-party standard/framework section will help inform future development of the Standard. GRESB will track commonly used frameworks reported in this field to inform the list of scored frameworks.

Update to Climate Scenarios

RM2

Background & Purpose

Indicator RM2 (Resilience of strategy to climate-related risks and opportunities) lists climate scenarios available for participants to use in their assessment of transition and physical climate risks and opportunities

Description

The list of climate scenarios available in RM2 has been updated in the 2026 Standard, including:

• NGFS: The latest release now incorporates the most recent climate and economic data for both short-term and long-term climate scenarios.

• CRREM: The CRREM Foundation has discontinued the provision of the 2°C scenario, citing an inability to guarantee full scientific quality. CRREM may reinstate or add new scenarios over time.

Reporting Impact

Participants are now able to select the latest climate scenarios available as part of their reporting.

Scoring Impact

None.