# Validation: Qualitative

## Manual Evidence Validation

### Validation Scope

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<summary>What is manually validated?</summary>

GRESB and subject matter experts from [Sustainability Assurance Services (SAS)](https://www.sustainabilityassured.com/) manually verify the following content:

1. **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.
   1. Note that R1 and (Standing Investments Portfolio) DR1 (Development Portfolio) are subject to a distinct manual review process, called 'Reporting Boundaries Review. See [here](#reporting-boundaries-review) for more information.
2. **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.
3. **Information related to third parties**, such as assurance, audit, and certification standards.

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### Validation Criteria

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<summary>Evidence Format</summary>

**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](https://gresb-prd-public-eu.s3.eu-central-1.amazonaws.com/2025/Evidence_Cover_page_2025.pdf)) or open text box to specify where evidence for each selection can be found.
* Participants may upload evidence as a document or an 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 pertaining to public availability, participants must upload a hyperlink.

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<summary>Reporting Year Applicability</summary>

Regardless of whether the indicator is manually validated, **all assessment answers must refer to the reporting year identified in indicator&#x20;*****EC4: Reporting year*****.**

However, **certain** indicators have **different** reporting year requirements. They 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: Social risk assessments
* RM3.2: Governance risk assessments
* RM6.1-4: Climate-related Risk Management indicators
* SE2.1: Employee satisfaction survey
* SE4: Employee safety indicators
* RA1: Risk assessments performed on standing investments portfolio
* RA2: Technical building assessments
* RA3: Energy efficiency measures
* RA4: Water efficiency measures
* RA5: Waste efficiency measures
* TC2.1: Tenant satisfaction survey

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.&#x20;

* For example, if a policy was implemented one month before the end of the reporting year, this is acceptable; it does not need to 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.**

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<details>

<summary>Reporting Entity Applicability</summary>

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.

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<details>

<summary>Indicator Applicability</summary>

GRESB does not consider evidence submitted under other indicators or evidence from previous years, **even if it is available in the Document Library.**&#x20;

Participants must upload evidence directly under the relevant indicator for the validation team to consider it.

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<details>

<summary>Language </summary>

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.

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<details>

<summary>Summary of Indicator-Specific Requirements</summary>

The table below highlights the manually validated indicators in the Real Estate Assessment, providing a high-level summary of the validation requirements for each.

For detailed guidance on the evidence required for each indicator, refer to the ‘Validation’ section on the specific page for 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.

#### Management Component

<table><thead><tr><th width="107.64453125">Indicator</th><th width="127.234375">Indicator Title</th><th>Requirement Summary</th></tr></thead><tbody><tr><td>LE6</td><td>Personnel Sustainability performance targets</td><td><ul><li>Sustainability targets must be explicitly tied to the selected personnel groups.</li><li>Applicability must cover all members within the selected group. If targets apply to a single person within a group, report under 'Other'.</li><li>Specify and link financial consequences to sustainability targets.</li></ul></td></tr><tr><td>PO1, PO2, PO3</td><td>Environmental, social and governance policies</td><td><ul><li>Formal policy documents must address each selected issue.</li><li>General goals/commitments are not considered formal policies.</li></ul></td></tr><tr><td>RP1</td><td>Sustainability reporting</td><td><ul><li>Disclose sustainability performance; a list of objectives alone is not sufficient.</li><li>Reference the selected reporting level (group or entity), alignment, and third-party review type (checked, assured, verified).</li><li>Meet disclosure-type specific requirements: integrated reports, annual reports, standalone sustainability reports, and dedicated sections on corporate websites.</li></ul></td></tr><tr><td>RM1</td><td>Environmental Management System (EMS)</td><td><ul><li>Demonstrate how the EMS aligns with or is certified to a recognized standard.</li><li>Aligned: name the standard and describe the aligned elements.</li><li>Certified: provide certification proof, standard name, third-party contact, and certification date (must have been valid during reporting year).</li></ul></td></tr><tr><td>RM6.1</td><td>Transition risk identification</td><td><ul><li>Demonstrate a systematic transition risk identification process.</li><li>List assessment outcomes, including identified transition risks, or lack thereof.</li><li>Outcomes must be entity specific.</li><li>Must be applicable to reporting year, or two years prior</li></ul></td></tr><tr><td>RM6.2</td><td>Transition risk impact assessment</td><td><ul><li>Demonstrate a systematic transition risk impact identification process.</li><li>List assessment outcomes, including the identified financial impacts, or lack thereof.</li><li>Outcomes must be entity specific.</li><li>Must be applicable to reporting year, or two years prior</li></ul></td></tr><tr><td>RM6.3</td><td>Physical risk identification</td><td><ul><li>Demonstrate a systematic physical risk identification process.</li><li>List assessment outcomes, including the identified physical risks, or lack thereof.</li><li>Outcomes must be entity specific.</li></ul></td></tr><tr><td>RM6.4</td><td>Physical risk impact assessment</td><td><ul><li>Demonstrate a systematic physical risk impact identification process.</li><li>List assessment outcomes, including the identified financial impacts, or lack thereof.</li><li>Outcomes must be entity specific.</li><li>Must be applicable to reporting year, or two years prior</li></ul></td></tr><tr><td>SE2.1</td><td>Employee satisfaction survey</td><td><ul><li>Demonstrate the existence of a satisfaction survey, indicating if it was conducted internally or by a third party, with quantitative metrics from 2023, 2024, or 2025.</li><li>Surveys must have been distributed by the end of the reporting year and results aggregated before the GRESB submission deadline.</li></ul></td></tr><tr><td>SE5</td><td>Human capital</td><td><ul><li>Demonstrate human capital monitoring process for the selected parties.</li><li>Present metrics through data visuals, sustainability reports, internal tracking, etc.</li><li>Describe the process via corporate letterhead narrative.</li></ul></td></tr></tbody></table>

#### Performance Component

<table><thead><tr><th width="106.046875">Indicator</th><th width="123.61328125">Indicator Title</th><th>Requirement Summary</th></tr></thead><tbody><tr><td>R1</td><td>Reporting characteristics</td><td><ul><li>Corroborate portfolio composition via 10K filings, audited financial statements, a signed CEO/Senior Management statement, etc.</li></ul></td></tr><tr><td>T1.2</td><td>Net Zero Targets</td><td><ul><li>Demonstrate existence of Net Zero target.</li><li><em>*Exempt from manual validation</em></li></ul></td></tr><tr><td>TC2.1</td><td>Tenant satisfaction survey</td><td><ul><li>Demonstrate the existence of a satisfaction survey, indicating if it was conducted internally or by a third party, with quantitative metrics from 2023, 2024, or 2025.</li><li>Surveys must have been distributed by the end of the reporting year and results aggregated before the GRESB submission deadline.</li></ul></td></tr><tr><td>MR1, MR2, MR3, MR4</td><td>External review of energy, GHG, water and waste data</td><td><ul><li>Provide proof of third-party data review and confirmation that it covers the reporting entity's assets. Using a sample of the portfolio is permitted as long as it is representative.</li><li>Checked: independent third-party review of reported data and collection methods. Assured/Verified: The entity holds a certificate against one of the GRESB approved and listed schemes. If a scheme is not listed the entity can apply for approval with the GRESB team.</li></ul></td></tr></tbody></table>

#### Development Component

<table><thead><tr><th width="106.90234375">Indicator</th><th width="124.2109375">Indicator Title</th><th>Requirement Summary</th></tr></thead><tbody><tr><td>DR1</td><td>Reporting Characteristics</td><td><ul><li>Corroborate portfolio composition via 10K filings, audited financial statements, a signed CEO/Senior Management statement, etc.</li></ul></td></tr><tr><td>DRE1</td><td>Sustainability strategy during development</td><td><ul><li>Demonstrate the existence of sustainability-focused strategies for development projects.</li><li>Confirm whether the sustainability strategy is publicly available or not.</li></ul></td></tr><tr><td>DMA1</td><td>Materials selection requirements</td><td><ul><li>Demonstrate the implementation of a formal policy addressing environmental and health attributes of building materials for development projects.</li><li>Evidence must support actual policy implementation, not just intent or operational asset requirements.</li></ul></td></tr><tr><td>DMA2</td><td>Embodied carbon measurement &#x26; disclosure</td><td><ul><li>Evidence must adequately support the disclosure of absolute embodied carbon emissions for the entity's development portfolio.</li></ul></td></tr><tr><td>DSE5.2</td><td>Community impact monitoring</td><td><ul><li>Evidence must demonstrate the existence of the monitoring process.</li></ul></td></tr></tbody></table>

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### Validation Outcomes

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<summary>What are the impacts of each validation decision?</summary>

Validators will make one of the three decisions below depending on the degree to which evidence meets GRESB’s requirements.&#x20;

Each validation outcome corresponds with a scoring weight that impacts the indicator’s final score. See the [Scoring Basics](https://app.gitbook.com/o/Bveezar1nazy8275RL7l/s/31ovOsfsdlwYDiJclXFF/outcomes/scoring-basics) page for more information.

#### 'Other' Answers

<table><thead><tr><th width="134.0390625">Validation status</th><th>Explanation</th><th>Scoring impact</th></tr></thead><tbody><tr><td>Accepted</td><td>'Other' answer falls outside the provided options and fulfills indicator requirements.</td><td>Full points</td></tr><tr><td>Duplicate</td><td>'Other' answer fulfills indicator requirements but duplicates an already selected answer.</td><td>No points will be awarded for this answer</td></tr><tr><td>Not Accepted</td><td>No points will be awarded for this answer'Other' answers do not fulfill indicator requirements.</td><td>No points will be awarded for this answer</td></tr></tbody></table>

#### Evidence and Open Text Boxes

| Validation Status  | Explanation                                                                                                                           | Scoring Impact                                                                                   |
| ------------------ | ------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------ |
| 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                                  |

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## Reporting Boundaries Review

<details>

<summary>What is the Reporting Boundaries Review?</summary>

Annually, GRESB conducts a targeted Reporting Boundaries Review to ensure the accuracy and completeness of the portfolio of assets that participants report to the Real Estate Assessment.&#x20;

Portfolio composition determines an entity’s peer group allocation and plays a key role in scoring indicators subject to property sub-type and country benchmarking. Relevant assessment results and comparisons, therefore, depend on the completeness and accuracy of an entity’s portfolio boundaries.

This process involves verifying portfolio composition through manual checks. GRESB reserves the right to use alternative sources of information to corroborate the composition of the portfolio, such as publicly available reports and uploaded documentation in other sections of the GRESB Assessment. Additionally, participants showing discrepancies will be asked for additional clarifications and/or to make corrections to their reporting scope.

The selection is based on parameters set by GRESB, such as listed versus non-listed entities, increases or decreases in GAV, asset count, and/or floor area year over year. A subset of participants who did not provide sufficient documentation in the previous year may be selected for a second review.

Non-compliance with the GRESB reporting requirements will result in the rejection of the Performance Component submission and will prevent the provision of a GRESB Score and GRESB Rating.

Process and timeline:

* In **June**, the selected participants are notified by GRESB that they have been selected for a reporting boundaries review, which will occur at the beginning of July. There is no action needed from the participant at this point in time.
* In **July**, the Reporting Boundaries process starts, and participants will be contacted via email to provide clarifications and/or to make corrections to their reporting scope. They have five working days to respond and resolve the request.
* At the beginning of **August**, the Reporting Boundaries process is concluded. GRESB may request participating entities to conduct some corrections to their data during the Review Period, which ends in mid-**September**.

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***

**Download GRESB's Evidence Cover Page Template**

{% embed url="<https://gresb-prd-public-eu.s3.eu-central-1.amazonaws.com/2025/Evidence_Cover_page_2025.pdf>" %}


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