BRSR (Business Responsibility and Sustainability Reporting) is India’s mandatory ESG disclosure framework for listed companies. Introduced by SEBI in 2021, it replaced the older Business Responsibility Report and brought structured, principle-based sustainability reporting to the top 1,000 companies on Indian stock exchanges. A refined subset called BRSR Core, introduced in 2023, adds mandatory assurance for nine key ESG metrics.
The framework covers nine areas of responsible business conduct, from governance and human rights to environmental metrics and consumer protection. For sustainability teams preparing their next filing, understanding each component and its data requirements is the first step toward compliance.
Below is a complete breakdown of BRSR reporting: what it requires, who it applies to, how it compares to global frameworks, and how to prepare.
What Is BRSR?
BRSR stands for Business Responsibility and Sustainability Reporting. SEBI introduced it through a circular in May 2021, replacing the Business Responsibility Report (BRR) that had been in use since 2012.
The framework is built on the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), published by the Ministry of Corporate Affairs in 2019. Each principle maps to a set of Essential Indicators (mandatory) and Leadership Indicators (voluntary).
BRSR reports follow a three-section structure:
- Section A: General disclosures (entity details, products, operations, material ESG issues)
- Section B: Management and process disclosures (policies, governance, commitments per principle)
- Section C: Principle-wise performance (all nine principles with Essential and Leadership indicators)
Companies file BRSR as part of their annual report under SEBI’s Listing Obligations and Disclosure Requirements (LODR) Regulations, 2015.
Who Does BRSR Apply To?
BRSR reporting is mandatory for the top 1,000 listed entities by market capitalization on BSE and NSE. All other listed entities can file voluntarily. The relevant market cap ranking is determined as of March 31 of the preceding financial year, and the list is updated annually by the stock exchanges.
| Tier | Who | Requirement | Since |
|---|---|---|---|
| Top 1,000 by market cap | BSE/NSE listed entities | Mandatory | FY 2022-23 |
| Other listed entities | All remaining listed companies | Voluntary | FY 2021-22 |
| Unlisted companies | Private companies | Not applicable | N/A |
Newly listed entities must file from their first full financial year after listing, provided they fall within the top 1,000 threshold. Companies choose either a standalone or consolidated reporting boundary and must disclose which one they use.
The 9 Principles of BRSR
All BRSR disclosures are organized around nine principles derived from the National Guidelines on Responsible Business Conduct (NGRBC). Each principle has mandatory Essential Indicators and voluntary Leadership Indicators that signal advanced practice.
| # | Principle | Focus Area | Key Essential Indicators |
|---|---|---|---|
| 1 | Ethics, Transparency, Accountability | Governance | Anti-corruption policy, fines/penalties, conflict of interest |
| 2 | Sustainable Products/Services | Products | R&D for environmental improvement, EPR compliance, sustainable sourcing % |
| 3 | Employee Well-being | Workforce | Health insurance coverage, LTIFR, fatalities, training hours |
| 4 | Stakeholder Responsiveness | Engagement | Stakeholder identification, vulnerable group engagement |
| 5 | Human Rights | Rights | Minimum wages compliance, POSH complaints, child/forced labor |
| 6 | Environment | Climate/Env | GHG Scope 1+2, energy consumption, water withdrawal, waste by 8 categories |
| 7 | Responsible Policy Advocacy | Advocacy | Trade association memberships, anti-competitive conduct |
| 8 | Inclusive Growth | Social | CSR details, MSME procurement %, job creation in smaller towns |
| 9 | Consumer Responsibility | Consumers | Data privacy incidents, product recalls, complaint resolution |
Principles 1 through 9 span the full spectrum of ESG: governance (P1, P7, P9), social responsibility (P3, P4, P5, P8), and environment (P2, P6). Principle 6 carries the bulk of climate and environmental disclosures.
Principle 6: Environmental Disclosures
Principle 6 is where BRSR’s climate-related reporting requirements sit. Companies must report quantitative environmental data across five categories, each with both absolute values and intensity metrics.
GHG Emissions (Scope 1 and 2)
BRSR requires a gas-by-gas breakdown of direct (Scope 1) and indirect (Scope 2) emissions: CO2, CH4, N2O, HFCs, PFCs, SF6, and NF3. Carbon capture volumes must be reported separately. Emission intensity is required in two forms: revenue-based (adjusted for purchasing power parity) and output-based (using a sector-specific denominator like vehicles produced or room-nights).
The GHG Protocol is recommended as the measurement standard, though not strictly mandated. Scope 3 emissions remain voluntary under the Leadership Indicators.
Energy, Water, and Waste Metrics
| Category | What Must Be Reported | Unit |
|---|---|---|
| GHG Emissions | Scope 1+2 by gas, with intensity (revenue + output) | CO2e (MT) |
| Energy | Total by source, renewable %, intensity | Joules |
| Water | Withdrawal, consumption, discharge by treatment level | KL |
| Air Emissions | NOx, SOx, particulate matter | Various |
| Waste | 8 categories (plastic, e-waste, bio-medical, construction, battery, radioactive, hazardous, non-hazardous), disposal methods | MT |
| EIA Compliance | Environmental impact assessments, compliance status, legal actions | Y/N + details |
Voluntary Disclosures (Leadership Indicators)
Companies aiming beyond minimum compliance can report Scope 3 value chain emissions, GHG reduction targets and progress, zero liquid discharge status, water recycling percentages, biodiversity impact assessments, and carbon credit transactions. None of these are mandatory, but they signal maturity to investors and rating agencies.
What Is BRSR Core?
BRSR Core is a refined subset of the full BRSR framework, introduced by SEBI in July 2023. It extracts nine key ESG attributes with measurable KPIs and attaches a mandatory reasonable assurance requirement on a phased glide path.
BRSR vs BRSR Core: What Changes
Under full BRSR, companies self-report across all nine NGRBC principles with no external verification requirement. SEBI introduced BRSR Core to close this accountability gap. Three differences set BRSR Core apart from the full framework:
- Narrower scope: Full BRSR covers all 9 principles with over 100 indicators. BRSR Core distills these into 9 attributes with auditable KPIs drawn from across multiple principles.
- Mandatory assurance: Full BRSR requires no external assurance. BRSR Core mandates reasonable assurance from an independent provider, phased by company size.
- Value chain extension: Full BRSR covers only the reporting entity. BRSR Core extends ESG disclosures to value chain partners for the top 250 listed entities on a comply-or-explain basis.
The 9 BRSR Core Attributes and Their KPIs
Each BRSR Core attribute maps to a specific NGRBC principle and carries defined metrics that must be reported and independently assured. The table below shows what each attribute measures.
| # | Attribute | NGRBC Principle | KPIs Measured | Unit |
|---|---|---|---|---|
| 1 | GHG Footprint | P6 (Environment) | Scope 1 + Scope 2 emissions, GHG intensity per revenue (PPP-adjusted) and per output | tCO2e |
| 2 | Water Footprint | P6 (Environment) | Total consumption, intensity per revenue and output, discharge by destination and treatment level | KL |
| 3 | Energy Footprint | P6 (Environment) | Total energy consumed, intensity per revenue and output, renewable energy percentage | GJ |
| 4 | Embracing Circularity | P6 (Environment) | Waste across 8 categories (plastic, e-waste, bio-medical, construction, battery, radioactive, hazardous, non-hazardous), intensity, recovery rate, disposal methods | MT |
| 5 | Employee Well-being and Safety | P3 (Employees) | Safety spending as % of revenue, permanent disabilities, lost-time injury frequency rate (LTIFR), fatalities | Various |
| 6 | Gender Diversity | P5 (Human Rights) | Gross wages paid to females as % of total wages, POSH complaints filed and resolved | %, Count |
| 7 | Inclusive Development | P8 (Inclusive Growth) | Inputs sourced from MSMEs and small producers as % of total, job creation in smaller towns by RBI classification | % |
| 8 | Fairness in Engaging | P9 (Consumers) / P1 (Ethics) | Data breaches as % of total cyber security events, accounts payable days | %, Days |
| 9 | Open-ness of Business | P1 (Ethics) | Concentration of purchases and sales through trading houses, related party transaction share in purchases, sales, loans, and investments | % |
Attributes 1 through 4, all drawn from Principle 6, carry the heaviest data collection burden. They require metered environmental measurements across multiple facilities, often from different instrumentation and tracking systems. In December 2024, SEBI published industry-specific methodology standards for BRSR Core, providing detailed guidance on GHG calculation, water measurement protocols, and waste classification to address inconsistencies across filings.
SEBI’s July 2023 circular includes the official BRSR Core reporting format (Annexure I and II) with the exact disclosure template for each attribute.
| Financial Year | Applicable To | Assurance Requirement |
|---|---|---|
| FY 2023-24 | Top 150 listed entities | Mandatory reasonable assurance |
| FY 2024-25 | Top 250 listed entities | Mandatory reasonable assurance |
| FY 2025-26 | Top 500 listed entities | Mandatory reasonable assurance |
| FY 2026-27 | Top 1,000 listed entities | Mandatory reasonable assurance |
Value Chain ESG Disclosures
BRSR Core extends beyond the reporting entity itself. The top 250 listed entities must disclose BRSR Core metrics for their value chain on a comply-or-explain basis starting from FY 2024-25. Limited assurance on these value chain disclosures becomes applicable from FY 2025-26.
Value chain coverage applies to partners representing 75% of purchases and sales by value. In practice, this means collecting standardized environmental and social data from dozens or hundreds of suppliers and distributors across India, many of whom may not have their own ESG reporting infrastructure in place.
Assurance Standards and Conflict Rules
Three assurance standards are accepted for BRSR Core: ISAE 3000 (international), ICAI SSAE 3000 (Indian standard), and SAE 3410 (India-specific for GHG statements). Companies must disclose which standard their assurance provider follows.
The assurance provider must have sustainability expertise but does not need to be a chartered accountant. A company’s statutory auditor can serve as the BRSR Core assurance provider, but its internal auditor cannot. SEBI also bars providers from offering the assurance engagement alongside product sales, non-audit services, risk management consulting, investment advisory, accounting, or IT design services to the same entity or its group.
BRSR Lite, BRSR (Full), and BRSR Core serve different audiences and carry different compliance burdens:
| Feature | BRSR Lite | BRSR (Full) | BRSR Core |
|---|---|---|---|
| Target audience | Voluntary reporters | Top 1,000 listed entities | Top 150-1,000 (phased) |
| Disclosure scope | Subset of indicators | All 9 principles, Essential + Leadership | 9 KPIs across principles |
| Assurance | None | Not required | Mandatory reasonable |
| Value chain | No | No | Top 250 (comply-or-explain) |
How BRSR Compares to Global ESG Frameworks
BRSR is India-specific, but many companies subject to SEBI’s mandate also report under global frameworks like IFRS S2 or CSRD. The table below shows where BRSR aligns with and diverges from these standards.
| Feature | BRSR (India) | IFRS S2 | CSRD / ESRS | TCFD |
|---|---|---|---|---|
| Jurisdiction | India (SEBI) | Global (IFRS Foundation) | EU | Dissolved into ISSB |
| Scope 1+2 GHG | Mandatory | Mandatory | Mandatory | Recommended |
| Scope 3 GHG | Voluntary | Mandatory | Mandatory | Recommended |
| Scenario analysis | Not required | Required | Required | Core recommendation |
| Financial impact | Qualitative (Q24) | Quantitative required | Quantitative required | Quantitative recommended |
| Physical risk | Implicit (Q24) | Explicit category | Explicit category | Explicit category |
BRSR is broader than most global standards because its nine principles span governance, human rights, inclusive development, and consumer protection alongside climate. But it is shallower on climate specifics: no scenario analysis requirement, no explicit transition plan disclosure, and Scope 3 remains voluntary. BRSR’s PPP-adjusted intensity metrics are unique and designed for cross-country comparability.
For a detailed breakdown of global climate disclosure requirements, see our IFRS S2 explainer. Companies with EU operations may also need to meet CSRD climate risk disclosure requirements alongside BRSR. The TCFD framework, now dissolved into the ISSB standards, remains the conceptual foundation that most of these standards build upon.
How to Prepare a BRSR Report
Preparing a BRSR report requires coordination across multiple departments. Here is a step-by-step process:
- Determine applicability. Check whether your entity falls within the top 1,000 by market capitalization as of March 31 of the preceding financial year.
- Choose your reporting boundary. Decide between standalone (listed entity only) or consolidated (including subsidiaries, associates, joint ventures). Disclose which boundary you use.
- Map data sources to the 9 principles. Identify which department owns each metric. HR covers Principles 3 and 5. Environment, health, and safety teams handle Principle 6. Legal and compliance manage Principles 1 and 7.
- Collect Principle 6 environmental data. Gather GHG inventories, energy consumption logs, water meter readings, waste disposal records, and EIA documentation.
- Identify material ESG issues (Q24). Section A, Question 24 requires companies to identify environmental risks and opportunities, explain their rationale, describe adaptation or mitigation approaches, and disclose financial implications. While BRSR’s core metrics focus on operational environmental data, the framework’s Q24 disclosure on material ESG issues requires identifying climate-related risks and their financial implications, a requirement directly supported by physical climate risk assessment platforms.
- Compile Section A through C disclosures. Follow SEBI’s prescribed format across all three sections.
- Engage an assurance provider (if applicable). For BRSR Core, the assurance provider must have sustainability expertise, cannot be the internal auditor, and must follow a recognized standard such as ISAE 3000 or ICAI SSAE 3000.
Frequently Asked Questions
What is the purpose of BRSR reporting?
BRSR standardizes ESG disclosure for listed companies in India. It replaced the older BRR format with quantitative metrics across governance, social, and environmental dimensions, giving investors and regulators a consistent way to assess corporate sustainability performance.
Is BRSR mandatory?
Yes, for the top 1,000 listed entities by market capitalization on BSE and NSE, starting from FY 2022-23. Other listed entities can file voluntarily. BRSR Core, requiring reasonable assurance, is phasing in from the top 150 to the top 1,000 entities by FY 2026-27.
What is the difference between ESG and BRSR?
ESG is a broad framework for evaluating corporate responsibility. BRSR is India’s specific ESG disclosure format mandated by SEBI. Other countries use their own frameworks: the EU has CSRD/ESRS, and the IFRS Foundation publishes globally applicable S1 and S2 standards.
When was BRSR made mandatory?
SEBI issued the BRSR circular in May 2021. Voluntary adoption began in FY 2021-22. Mandatory reporting for the top 1,000 listed entities started in FY 2022-23. BRSR Core assurance requirements began phasing in from FY 2023-24.
What are the types of BRSR report?
Three tiers exist: BRSR Lite (simplified, voluntary), full BRSR (mandatory for top 1,000, all 9 principles), and BRSR Core (9 key KPIs with mandatory reasonable assurance, phased from top 150 to top 1,000 by FY 2026-27).
Who prepares the BRSR report?
The listed entity files its own BRSR. Sustainability teams typically coordinate data collection across environment, HR, legal, and finance departments. For BRSR Core, an independent assurance provider with sustainability expertise must verify the data. Internal auditors cannot serve as assurance providers.
What is BRSR Core?
BRSR Core pulls 9 ESG attributes with measurable KPIs from the larger BRSR framework. SEBI introduced it in July 2023 with mandatory reasonable assurance phased from the top 150 listed entities (FY 2023-24) to the top 1,000 (FY 2026-27). It also extends ESG disclosures to value chain partners for the top 250 entities on a comply-or-explain basis.
What is the difference between BRSR and BRSR Core?
Full BRSR covers all 9 NGRBC principles with over 100 indicators but requires no external assurance. BRSR Core extracts 9 key ESG attributes with defined, auditable KPIs and mandates reasonable assurance on a phased schedule. BRSR Core also introduces value chain ESG disclosures for the top 250 entities, which full BRSR does not require.
What are the 9 KPIs of BRSR Core?
The 9 BRSR Core KPIs are: GHG Footprint, Water Footprint, Energy Footprint, Embracing Circularity (waste), Employee Well-being and Safety, Gender Diversity, Inclusive Development, Fairness in Engaging with Customers and Suppliers, and Open-ness of Business. Each carries specific metrics that must be independently assured under a recognized standard such as ISAE 3000 or ICAI SSAE 3000.
Key Takeaways
BRSR covers the broadest ESG scope of any reporting framework in India, spanning anti-corruption governance, environmental emissions, human rights, and consumer data privacy across nine principles. For the top 1,000 listed companies, compliance is not optional, and the assurance bar is rising every year as BRSR Core expands.
The immediate priorities for most companies are Principle 6 data collection (GHG, energy, water, waste) and preparing for BRSR Core assurance as the threshold moves from the top 500 in FY 2025-26 to the top 1,000 in FY 2026-27. Climate-related risk identification under Q24 is heading toward alignment with ISSB scenario analysis requirements. Companies that start building physical risk assessment capabilities now will be better positioned when those changes arrive.
