BRSR in India: What Companies Need to Prepare for Next
The Growing Importance of BRSR in India: Building Systems for Accurate, Transparent, and Assurable Disclosures
Environmental, Social and Governance (ESG) performance is becoming an increasingly important part of how businesses operate, manage risks and communicate with stakeholders.
In India, the Securities and Exchange Board of India (SEBI) has strengthened sustainability reporting requirements through the Business Responsibility and Sustainability Report (BRSR).
BRSR enables companies to disclose information about their environmental impact, workforce practices, business conduct, governance systems and broader sustainability performance. It encourages businesses to move beyond general statements and demonstrate progress through measurable data.
As ESG reporting evolves, companies must establish reliable data collection systems, clarify internal responsibilities, improve documentation, and prepare for the assessment or assurance of relevant disclosures.
The Strategic Imperative
For Indian businesses, the next stage of BRSR readiness involves building reporting systems that are accurate, consistent, transparent, and fully aligned with SEBI provisions.
What Is BRSR?
Business Responsibility and Sustainability Reporting (BRSR) is a sustainability disclosure framework introduced by SEBI for specified listed entities in India. It builds on the National Guidelines on Responsible Business Conduct (NGRBCs) and covers nine core principles relating to responsible business practices.
Applicability: Mandatory for the top 1,000 listed entities by market capitalisation from FY 2022–23. The BRSR format distinguishes between Essential Indicators (mandatory) and Leadership Indicators (voluntary).
What Is BRSR Core and How Is It Different from BRSR?
BRSR Core is a defined subset of BRSR focusing on selected key performance indicators across nine ESG attributes to improve the consistency and credibility of sustainability information through measurable, verifiable disclosures.
| Aspect | BRSR | BRSR Core |
|---|---|---|
| Primary Purpose | Broad sustainability and responsible business disclosures | Focused reporting of specified key ESG metrics |
| Coverage Scope | Wider set of environmental, social, and governance disclosures | Selected KPIs across nine defined ESG attributes |
| Reporting Approach | Essential and Leadership Indicators | Defined metrics with prescribed measurement methodologies |
| Verification / Audit | Requirements depend on applicable disclosure framework | Assessment or assurance requirements apply per SEBI framework |
| Business Value | Provides a wider holistic view of sustainability performance | Strengthens reliability, comparability, and trust in key ESG data |
Why BRSR Readiness Matters for Indian Companies
BRSR readiness should be treated as an ongoing business process rather than a last-minute compliance exercise. Establishing structured reporting systems unlocks five key strategic advantages:
Improved Regulatory Preparedness
Plans activities ahead, allocates clear team ownership, and eliminates incomplete disclosures.
Better ESG Data Quality
Standardises definitions and calculation formulas across facilities, branches, and subsidiaries.
Stronger Risk Management
Reveals operational inefficiencies in energy, emissions, waste, safety, and supply-chain vulnerabilities early.
Greater Stakeholder Confidence
Builds trust with investors, lenders, ESG rating agencies, and global customers through auditable data.
Effective Sustainability Planning
Monitors quantifiable targets over time, aligning ESG priorities with long-term commercial strategy.
ESG Data Collection: Building a Reliable System
One of the biggest challenges in BRSR reporting is consolidating data from fragmented departments. Here is the recommended workflow to transform operational records into verifiable disclosures:
Map Required Metrics
Identify quantitative metrics, supporting document needs, and data gaps against BRSR/BRSR Core.
Assign Metric Owners
Designate single points of accountability across Facilities, HR, Legal, and Procurement teams.
Standardise Methods
Establish uniform calculation methods, units of measure, and assumptions across facilities.
Build Evidence Trail
Archive utility bills, meter logs, payroll summaries, and manifests for auditor verification.
Value-Chain Disclosures: Extending ESG Reporting Beyond Company Operations
A company’s sustainability impact extends beyond its direct facilities. Suppliers, contractors, and distributors contribute significantly to environmental and social footprints.
Under SEBI’s evolving framework (March 2025 update), value-chain disclosures for the top 250 listed entities are voluntary from FY 2025–26, with associated assurance also voluntary from FY 2026–27. Companies can choose to limit reporting to partners representing up to 75% of purchases/sales by value.
What Companies Should Prepare for Value-Chain ESG:
- Map the Value Chain: Identify key upstream suppliers and downstream distributors.
- Prioritise Significant Partners: Use purchase/sales volume data to select partners within scope.
- Define Required Metrics: Request targeted data on Scope 3 emissions, energy, waste, and safety.
- Engage Early: Provide standardized reporting templates and capacity-building support.
- Document Boundaries: Record partner inclusion ratios, assumptions, and data limitations.
Practical 10-Step Roadmap to Improve BRSR Reporting
Review Requirements
Confirm applicability, deadlines, and recent SEBI circulars.
Gap Assessment
Benchmark current data against BRSR & BRSR Core requirements.
Data Inventory
Create a central register of metrics, units, and evidence sources.
Define Roles
Form a cross-functional team (ESG, HR, Finance, Legal, Ops).
Standardise Collection
Roll out uniform data templates and calculation formulas.
Internal Controls
Establish validation checks, review workflows, and approval logs.
Assurance Prep
Test data trails and resolve gaps prior to external auditor engagement.
Value-Chain Plan
Engage key vendors and establish pragmatic data submission workflows.
Year-Round Monitoring
Track metrics quarterly rather than rushing at year-end.
Drive Improvement
Use reporting insights to improve efficiency, governance, and strategy.
Common BRSR Reporting Challenges & Solutions
| Common Challenge | Practical Action / Solution |
|---|---|
| Fragmented Data across siloed teams | Establish a central data inventory, standard templates, and clear ownership. |
| Inconsistent Calculations between branches | Document calculation methodologies, measurement units, and review procedures. |
| Limited Supporting Evidence for audit | Maintain a structured evidence repository with mandatory sign-off controls. |
| Low Supplier Participation in value-chain | Provide practical guidance, simplified questionnaires, and vendor capacity building. |
| Last-Minute Reporting Pressure | Implement periodic quarterly reviews and conduct early gap assessments. |