The framework problem: too many acronyms, not enough clarity

Walk into any ESG discussion in East Africa and you will encounter a wall of acronyms: GRI, SASB, TCFD, ISSB, IFRS S1, IFRS S2, ESRS, KGFT. For a sustainability lead trying to build their organisation's first ESG programme, or a CFO trying to understand what their institutional investor actually wants to see, the landscape feels more confusing than clarifying.

The confusion is understandable but mostly unnecessary. Once you understand what each major framework was designed to do and who it was designed for, the choice of what to report against becomes considerably clearer. And the most important insight is this: these frameworks are not designed to replace each other. They are designed to answer different questions about the same organisation.

This article provides a plain-language breakdown of the frameworks that matter most for East African businesses right now, explains who typically uses each one, and sets out how they interact in practice and in the Kenyan regulatory context — including where the Kenya Green Finance Taxonomy fits in.

GRI: Global Reporting Initiative Standards

What it does: The GRI Standards enable organisations to disclose their impacts on the economy, environment, and society, for the benefit of a wide range of stakeholders including communities, employees, regulators, and civil society.

Who it is for: Multiple stakeholders — investors, communities, regulators, NGOs, employees, customers. GRI is the broadest-audience framework of the three.

How it works: Three universal standards apply to all organisations, plus 33 topic-specific standards applied based on a materiality assessment. GRI 2021 is the current version.

Key concept: Materiality. Organisations report on the ESG topics that are most significant for their specific business and stakeholder context, determined through a structured stakeholder engagement process.

In Kenya: The NSE ESG Disclosures Guidance Manual (2021) recommends GRI as the primary reporting framework for listed companies. GRI is the most widely adopted ESG reporting standard globally, used by over 10,000 organisations in more than 100 countries.

SASB: Sustainability Accounting Standards Board

What it does: SASB Standards enable organisations to disclose sustainability information that is financially material to investors in a specific industry, supporting sector-by-sector comparability.

Who it is for: Primarily investors and financial analysts seeking to compare ESG performance across companies in the same sector.

How it works: 77 industry-specific standards, each defining a set of financially material sustainability topics and associated accounting metrics. Now maintained by the IFRS Foundation.

Key concept: Financial materiality. SASB focuses on ESG factors likely to affect a company's financial condition or operating performance — making it the most investor-facing of the three frameworks.

In Kenya: SASB is referenced in the NSE ESG Guidance Manual and in Ardena's ESG strategy work as a complementary investor-facing framework. IFRS S1, which underpins the forthcoming CMA ESG Code, draws substantially on SASB's industry-specific metrics.

TCFD: Task Force on Climate-related Financial Disclosures

What it does: TCFD recommendations help organisations disclose how they identify, assess, and manage climate-related risks and opportunities, structured for integration into mainstream financial reporting.

Who it is for: Investors, lenders, insurers, and financial regulators assessing climate-related financial risk in their portfolios and balance sheets.

How it works: Four thematic areas — governance, strategy, risk management, and metrics and targets. Requires scenario analysis to assess business resilience under different climate pathways.

Key concept: Physical and transition risk. TCFD requires organisations to distinguish between risks from the physical impacts of climate change (drought, floods, heat stress) and risks from the transition to a low-carbon economy (carbon pricing, policy change, stranded assets).

In Kenya: The CBK Guidance on Climate-Related Risk Management (2021) is explicitly aligned with TCFD. Mandatory climate risk reporting for CBK-licensed banks commenced September 2022. IFRS S2, incorporated into the forthcoming CMA ESG Code, builds directly on TCFD's four-pillar structure.

The Kenya Green Finance Taxonomy: a classification tool, not a reporting framework

The Kenya Green Finance Taxonomy (KGFT), issued by the CBK on 4 April 2025, is a distinct but closely related instrument that East African businesses — particularly banks, project developers, and companies seeking green finance — need to understand alongside the three reporting frameworks above.

Unlike GRI, SASB, and TCFD, the KGFT is not a reporting standard. It is a classification system that defines which economic activities qualify as environmentally sustainable, using three principles: Significant Contribution to an environmental objective, Do No Significant Harm to other objectives, and compliance with Minimum Social Safeguards. An activity must satisfy all three to be considered taxonomy-aligned.

Currently covering ten categories of economic activities and focused on climate mitigation and adaptation, the KGFT is voluntary for an initial 18-month period from April 2025, after which it becomes mandatory for commercial banks and mortgage finance companies.

Can you use more than one? Yes, and most sophisticated organisations do

The most common practical approach for East African companies with significant investor or DFI relationships is to use GRI as the primary reporting framework for comprehensive stakeholder disclosure, SASB metrics for the investor-facing sections, and TCFD to structure the climate risk section. This is not duplication — it is building a complete picture from complementary lenses.

The global trend is explicitly toward integration. The IFRS Foundation, which now oversees both SASB and the International Sustainability Standards Board (ISSB), has designed IFRS S1 and IFRS S2 to incorporate SASB's industry-specific metrics and TCFD's four-pillar structure respectively.

For listed Kenyan companies preparing for the forthcoming CMA ESG Code, building familiarity with IFRS S1 and S2 now is the most efficient preparation strategy. Organisations already reporting against GRI and TCFD will have the strongest head start.

What investors and DFIs in East Africa actually expect

International DFIs and institutional investors typically expect GRI-aligned reporting as a baseline, supplemented by TCFD-aligned climate risk disclosure for any project or company with significant climate exposure. DFI lenders including the IFC additionally require ESG performance reporting against the IFC Performance Standards.

Banks and companies seeking green financing in Kenya will increasingly need to demonstrate alignment with the KGFT as it transitions from voluntary to mandatory.

3 critical questions to determine your framework priorities

1. Who are your primary ESG audiences: regulators, DFI lenders, institutional investors, local communities, or all of the above? The answer determines whether GRI, SASB, TCFD, or a combination should take priority.

2. Is your organisation in a sector with significant climate exposure — agriculture, energy, real estate, infrastructure? If yes, TCFD-aligned climate risk disclosure is a near-term requirement regardless of whether currently mandated.

3. Are you a bank, corporate bond issuer, or project developer seeking green finance? If yes, KGFT alignment is becoming a commercial and regulatory expectation that will be mandatory within the next 18 months.

*Ardena's ESG Strategy and Implementation service helps East African organisations identify the right framework combination, build their materiality assessment, and develop reporting systems that meet both current requirements and the regulatory trajectory ahead. Contact us to get started.*

GRI vs SASB vs TCFD: Which ESG Framework is Right for Your Business?