We are an unlisted supplier. Why are customers asking for our ESG data?

Short answer

Large listed companies report under SEBI's BRSR and are encouraged to cover their value chain: suppliers and customers that make up 2% or more of their purchases or sales. Export buyers, especially in Europe, and banks assessing climate risk ask for similar data. The law does not require you to report, but answering well helps keep you on approved-vendor lists. Most of the data, such as electricity, fuel, water, waste and headcount, is already in your records.

Where the requests come from

Listed customers building their BRSR value-chain disclosures and Scope 3 emissions. Value-chain reporting is voluntary at present, but many large buyers already collect the data.
Export customers, particularly in the European Union, which has its own sustainability reporting and carbon border rules for some goods.
Banks and lenders assessing climate and environmental risk, and offering green or sustainability-linked loans.

What you are likely to be asked

Area	Typical questions	Where the data is
Energy and emissions	Electricity and fuel used; Scope 1 and 2 emissions	Electricity bills, fuel purchase registers
Water and waste	Water drawn and discharged; waste generated and disposed of	Water bills, pollution board returns, disposal challans
People	Employees and workers, gender mix, wages, safety incidents	Payroll, attendance, accident register
Governance	Ethics, anti-bribery and grievance policies	Board-approved policies

How to respond without a large budget

Name an owner for each data point: plant head for energy and waste, HR for people, accounts for spend.
Use records you already keep, for the same twelve-month period each time.
Calculate emissions consistently: the CEA's latest grid emission factor for electricity, and standard factors for fuels. See Scope 1, 2 and 3 emissions.
Keep an evidence file with the source document and calculation for each number.
Give every customer the same figures, and say where a number is an estimate.

Is it worth it?

A supplier who can answer quickly, with evidence, is easier to keep. The same data supports green-loan applications and any later assurance. Read our note: unlisted suppliers are being asked for BRSR-style data.

Legal basis

SEBI circular of 28 March 2025 (value-chain disclosures voluntary from FY 2025-26)
Regulation 34(2)(f), SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015

Official sources

Work it out for your own figures with our calculator: Emissions estimator.

By CA Ameesh Gupta, FCA, DISA (ICAI) | Last reviewed: 7 November 2026. General information, not advice on your facts: the law changes and outcomes depend on the details of each case.