Business Responsibility and Sustainability Reporting

BRSR (Business Responsibility and Sustainability Reporting) is SEBI’s mandatory ESG disclosure framework for listed companies in India. It replaced the earlier Business Responsibility Report (BRR) from FY 2022–23 onward and is built on the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC). It requires the top 1,000 listed companies by market capitalization to submit structured ESG disclosures - covering 150+ indicators across environmental, social, and governance parameters - as part of their annual report, in both PDF and XBRL formats filed with BSE/NSE. Once a company becomes subject to BRSR, it must continue reporting until it has remained below the top-1,000 threshold for three consecutive years. SEBI also encourages all listed companies outside the top 1,000 to report voluntarily.

BRSR Core is a focused subset of 49 Key Performance Indicators (KPIs) drawn from the broader BRSR framework. Introduced by SEBI in July 2023, it’s designed to make ESG data more comparable, quantifiable, and assurance-ready. The key differences: BRSR Core metrics are specifically selected for measurability (GHG emissions, energy intensity, water use, gender diversity, etc.), and they require third-party assessment or assurance - which the full BRSR does not mandate across the board. BRSR Core is also the basis for value chain ESG disclosures, where listed entities must report on their top upstream and downstream partners covering 75% of purchases/sales by value. Think of BRSR as the full disclosure framework and BRSR Core as the audit-grade performance layer sitting on top of it.

SEBI is rolling out BRSR Core assurance progressively by company size. The top 150 listed entities (by market capitalization) were required to obtain reasonable assurance from FY 2023–24 onward. The top 250 follow, and the requirement is expected to extend to all top 1,000 listed entities by FY 2026–27. SEBI has been considering whether to shift from "reasonable assurance" to a lighter "assessment" for companies beyond the top 150 - a proposal that’s drawn debate about whether it would dilute ESG data credibility. Regardless of the final form, the direction is clear: external verification of BRSR Core KPIs is becoming mandatory across the board. Companies further down the top-1,000 list should be building assurance-ready data trails now, not waiting for their specific deadline.

Starting FY 2024–25, the top 250 listed entities must report BRSR Core parameters for their key value chain partners - defined as the upstream and downstream partners that cumulatively account for 75% of the entity’s purchases and sales by value (or those individually comprising 2% or more). This applies on a comply-or-explain basis initially, with limited assurance expected from FY 2025–26 onward. The practical challenge is significant: many value chain partners are smaller firms - including MSMEs - that may lack ESG awareness, data systems, or reporting capacity. Listed companies effectively need to train, support, and collect structured ESG data from their supply chains, making supplier engagement workflows and standardized data collection templates critical to meeting these requirements without creating operational bottlenecks.

BRSR was designed with global interoperability in mind. Its nine NGRBC principles align closely with the UN Guiding Principles on Business and Human Rights and the UNGC’s Ten Principles. Many BRSR indicators - particularly on GHG emissions, energy, water, waste, diversity, and governance - map directly to GRI Standards and SASB metrics. However, the mapping isn’t one-to-one: BRSR has India-specific indicators (e.g., CSR spend per Section 135 of the Companies Act, EPF/ESIC contributions, caste/community diversity data) that don’t have direct equivalents in GRI or SASB. If you’re already reporting under GRI or SASB, a crosswalk exercise will identify which datapoints you can reuse, which need reformatting, and which are unique to BRSR. Building that crosswalk upfront avoids duplicate data collection and keeps your global and India-specific disclosures consistent.

Non-compliance with BRSR is treated as a violation of SEBI’s Listing Obligations and Disclosure Requirements (LODR) Regulations. Consequences can include monetary penalties from SEBI, adverse observations in annual report filings, reputational damage in the investor and ESG rating community, exclusion from ESG indices (which increasingly drive institutional capital allocation), and difficulty accessing ESG-linked financing. Beyond the direct regulatory risk, companies with weak or missing BRSR disclosures face practical consequences: ESG rating agencies downgrade companies with poor disclosure quality, institutional investors increasingly screen for BRSR compliance in their India portfolio decisions, and large customers conducting supply chain due diligence may flag gaps. The cost of non-compliance extends well beyond the fine itself.