Three things this year’s GRESB Infrastructure Assessment revealed 

Having worked through another GRESB Infrastructure cycle, a few themes stood out to me – particularly around the growing gap between how sustainability is managed in practice and what can realistically be evidenced through the Assessment. Risks may well be managed, but the lack of structured evidence can often harm GRESB scores.

This matters because strong sustainability management does not automatically translate into a strong GRESB submission.

Increasingly, participants need to think not only about whether the right processes are in place, but whether those processes can be clearly evidenced, documented and disclosed in a way that meets GRESB’s expectations.

Three areas stood out this year.

1. The bar for fund-level disclosure was exceptionally high

One of the biggest challenges this year was the change to fund-level requirements, which limited participants to one reporting disclosure for their responses to the Sustainability Reporting question.

On paper, this sounds relatively straightforward. In practice, the requirements that a single disclosure needed to meet to achieve full points were demanding.

The disclosure needed to:

• Refer specifically to the fund
• Be publicly available
• Align with a recognised third-party framework
• Include the relevant data, or have that data independently verified

Meeting all four requirements through a single publicly available disclosure can be difficult.

This created a particular challenge when the scale and granularity of reporting are considered. Many infrastructure managers report sustainability performance at a group or business unit level rather than producing a separate disclosure that identifies every individual fund and asset.

This does not necessarily mean that the underlying sustainability practices are weak. In fact, we worked with several sophisticated infrastructure funds with mature sustainability practices that simply did not produce this specific type of fund-level disclosure.

For those participants, full points could therefore remain out of reach despite strong underlying ESG practices.

It raises a broader question for disclosure-based assessments: how do we maintain a high bar for transparency and comparability without inadvertently penalising strong participants because of the format and level at which information is disclosed?

For participants, the practical lesson is that disclosure strategy increasingly needs to be considered alongside sustainability strategy. Waiting until the GRESB submission window to determine whether existing disclosures meet the requirements may be too late. In simple terms, organisations need to ask, “How important is it for the fund to achieve the maximum possible GRESB points?” If the answer is “very”, then disclosure needs to be aligned with GRESB requirements in advance.

2. Risk management is about demonstrating the process and the outcome

Risk management remains one of the areas where interpretation matters most.

The challenge is not necessarily that organisations lack risk management processes. Often, those processes already exist.

The difficulty is demonstrating the full journey in a way that is clear from the evidence:

identification → analysis → evaluation → treatment

This is becoming increasingly important as GRESB moves towards raising expectations around sustainability-related risk assessment, including the requirement to demonstrate a complete assessment process for material environmental, social and governance issues, as well as transition and physical climate risk management.

Simply showing that a risk has been identified is therefore unlikely to be enough. This is something we agree strongly with. Risk management is not the same as risk identification!

Participants need to consider whether their evidence demonstrates what happened next. How significant was the risk? How was it prioritised? What decisions were made? What mitigation or treatment followed?

This year’s submissions highlighted another challenge: the evidence can sometimes be spread across multiple outputs.

A risk might appear in a risk register, with the analysis documented elsewhere, the response captured in an asset management plan and the resulting decision recorded in committee minutes. That may reflect how the organisation genuinely manages risk — but it can make the overall process difficult to follow.

GRESB’s preference for a clear, coherent risk assessment matrix is therefore understandable. If evidence is highly fragmented, it can be difficult to distinguish a genuinely embedded process from a collection of activities that have developed independently.

The challenge for participants is not necessarily to force every aspect of risk management into one document. It is to make the logic of the process visible.

That distinction between having a process and being able to evidence the process and its outcomes is becoming increasingly important.

3. Climate opportunities need to be embedded in the business

This was perhaps the most interesting issue for me.

Consider a renewable energy company. Climate change and the transition to a low-carbon economy are fundamental drivers of its business model. In many respects, the climate “opportunity” is already embedded in the company’s core strategy.

So, what does assessing climate opportunities actually mean in this context?

Undertaking a standalone exercise simply to demonstrate that renewable energy represents a climate opportunity adds limited value.

The bigger opportunity is to understand how climate considerations are actually influencing business and operational planning.

• Are emerging technologies being considered?
• Are changing energy markets influencing investment decisions?
• Is customer demand changing? Are new infrastructure requirements creating opportunities?
• Are policy and regulation influencing the organisation’s growth strategy?

These are all questions that can turn climate opportunity from an ESG exercise into a genuine business consideration.

This is particularly relevant for infrastructure because climate change and the transition to a low-carbon economy are often closely connected to the underlying business models.

Yet we still see climate risks and opportunities being considered separately from core operations or business planning.

That can be a missed opportunity.

For a renewable energy business, the question is unlikely to be whether climate change creates an opportunity. It clearly does. The more valuable question is how the business is identifying, prioritising and acting on the opportunities that arise as the transition evolves.

This is where materiality and business context become critical.

GRESB, as a standardised framework, plays an important role in creating comparability across infrastructure. But a climate-related opportunity will manifest very differently for different sectors – consider, for example, renewable energy companies versus transport operators, water utility companies and even digital infrastructure businesses – all of which have different climate-related impacts and opportunities.

The strongest assessments are therefore likely to be those that apply the framework intelligently to the realities of the business, rather than treating each requirement as an isolated compliance exercise.

So, what are the key takeaways?

For me, this year’s GRESB Infrastructure cycle reinforced three things:

1. High-quality ESG practices do not always translate neatly into disclosure-based assessments.
2. Risk management needs to demonstrate what happened as a result of the assessment, not simply that risks were identified (sounds obvious, but it is important to flag).
3. Climate considerations create the most value when they are connected to core business and operational planning, rather than treated as a standalone ESG exercise.

As GRESB continues to evolve, the direction of travel is positive. But this year’s Assessment also highlighted the importance of considering how requirements work in practice for infrastructure investors and operators, rather than only how they appear on paper.

The broader lesson goes beyond GRESB. As sustainability reporting and disclosure requirements mature, organisations are increasingly being asked to demonstrate not just policies and commitments, but the governance, evidence and decision-making processes sitting behind them.

The real opportunity for participants is therefore not simply to ask:

“How do we answer this GRESB question?”

but:

“What is GRESB trying to understand about our organisation — and can we demonstrate that the underlying process is genuinely embedded?”

That is ultimately where the strongest submissions come from and, more importantly, where GRESB can become a tool for strengthening sustainability management rather than simply an annual reporting exercise.

How EVORA can help

A strong GRESB submission starts well before the reporting window opens.

EVORA works with infrastructure investors, fund managers and operators to understand what GRESB requirements are really testing, identify gaps in existing processes and evidence, and strengthen the underlying sustainability practices behind the submission.

Our support can include:

→ Reviewing previous GRESB performance and identifying priority improvement areas

→ Assessing evidence and disclosure gaps before the reporting cycle begins

→ Strengthening ESG risk management and materiality processes

→ Supporting climate risk and opportunity assessments that reflect the context of the asset or business

→ Developing policies, processes and disclosures that can stand up to increasing scrutiny

→ Managing and supporting the GRESB submission process itself

The objective is not simply to maximise points. It is to make sure that what is reported through GRESB is supported by robust, meaningful processes that create value beyond the Assessment.

If you are reviewing your 2026 GRESB Infrastructure results or starting to think about your strategy for the next assessment cycle, speak to EVORA. We can help you understand where the biggest opportunities for improvement lie and build a practical roadmap for the year ahead.