ESG and BRSR: who reports, what, and how
Environmental, social and governance (ESG) reporting is now part of mainstream disclosure in India, especially for listed companies and the businesses that supply them. This guide explains the rules, the structure of the BRSR, and how to prepare.
- The top 1,000 listed entities by market capitalisation must file a Business Responsibility and Sustainability Report (BRSR) with their annual report.
- BRSR Core is a subset of key indicators that must be independently assessed or assured. The requirement reaches the top 1,000 in FY 2026-27.
- Value-chain disclosures are voluntary for the top 250.
- Unlisted companies are not required to file, but buyers, lenders and investors are asking for the same data.
1. Why ESG reporting matters to your business
- Regulation: SEBI's listing regulations require the BRSR from the largest listed entities.
- Capital: lenders and investors use ESG data in credit and investment decisions, and offer better terms for credible sustainability credentials.
- Customers: large buyers send sustainability questionnaires to their suppliers, including small and medium businesses.
- Exports: measures such as the EU's Carbon Border Adjustment Mechanism, whose definitive period began on 1 January 2026, require emissions data for covered products such as steel, aluminium, cement and fertilisers.
2. Who must report in India
| Requirement | Applies to |
|---|---|
| BRSR (full report) | Top 1,000 listed entities by market capitalisation |
| BRSR Core: assessment or assurance | Phased: top 150 in FY 2023-24, 250 in FY 2024-25, 500 in FY 2025-26, and 1,000 in FY 2026-27 |
| Value-chain disclosures | Top 250 listed entities, voluntary; assurance of these is also voluntary |
| Everyone else | No mandate, but may be asked by buyers, banks and investors |
Your cohort is decided by market capitalisation, so confirm it each year.
3. How a BRSR is structured
- Section A, General disclosures: the entity, operations, workforce, and stakeholders.
- Section B, Management and process disclosures: policies, governance and oversight for each principle.
- Section C, Principle-wise performance: Essential indicators (all must report) and Leadership indicators (voluntary) against the nine principles of the National Guidelines on Responsible Business Conduct.
The nine principles cover ethics and transparency, sustainable products, employee well-being, stakeholder engagement, human rights, the environment, responsible policy advocacy, inclusive growth, and consumer value.
4. BRSR Core: the nine attributes
| Attribute | Examples of what is measured |
|---|---|
| Greenhouse gas footprint | Scope 1 and 2 emissions and intensity |
| Water footprint | Consumption, withdrawal, discharge and intensity |
| Energy footprint | Total energy, share of renewables, intensity |
| Embracing circularity | Waste generated, recycled and disposed |
| Employee well-being and safety | Safety incidents, benefits, spending on well-being |
| Gender diversity | Gender mix, and wages paid to women |
| Inclusive development | Sourcing from small and local producers |
| Fairness with customers and suppliers | Data security, complaints, payment practices |
| Openness of business | Concentration of purchases, sales and related-party dealings |
Intensity indicators are reported relative to turnover, adjusted for purchasing power parity.
5. Building a reliable reporting process
- Set the boundary: which entities, plants and periods are covered.
- Name an owner for every data point, and a reviewer.
- Define each metric in writing, with units and the calculation method.
- Collect evidence: invoices, meter readings, payroll records, logs.
- Calculate and reconcile against financial and operational records.
- Review and sign off before publishing, and keep the trail for assurance.
Most gaps arise from missing owners, undefined boundaries and numbers that cannot be traced to evidence.
6. Carbon and climate basics
- Scope 1: direct emissions from sources you own or control.
- Scope 2: emissions from purchased electricity, steam, heating and cooling.
- Scope 3: other indirect emissions in your value chain. These are the hardest to measure.
- Carbon credits: India has been building a domestic Carbon Credit Trading Scheme. The accounting depends on whether credits are held for own use, for trading or for compliance, and is assessed under the existing standards on intangibles, inventory or financial instruments.
7. Assurance and independence
BRSR Core requires an independent assessment or assurance by a qualified provider. Preparing the data and giving assurance on it are different roles, and the same firm should not do both for the same data. SEBI's framework also places conditions on assurance providers, so check them before you appoint one. Good preparation, with clear controls and evidence, makes the assurance faster and cheaper.
8. Other frameworks and green finance
- GRI is widely used for impact-focused reporting.
- ISSB (IFRS S1 and S2) sets global baselines for sustainability and climate disclosures. Check the status of Indian standards aligned with them.
- CDP and lender questionnaires ask for climate and supply-chain data.
- Green and sustainability-linked finance: lenders may price loans against sustainability targets, which need credible baselines and reporting.
9. Common mistakes
- Treating the BRSR as a communications exercise rather than a data process.
- Using different boundaries for financial and sustainability numbers.
- No evidence behind figures, so they cannot be assured.
- Waiting until the assurance year to build controls.
- Ignoring supplier requests from large customers.
General information as of October 2026, not advice on your facts. SEBI and other regulators revise requirements; confirm the current position for your entity.