Companies are no longer expected to report only revenue, profit, assets and other financial numbers. Investors and regulators also want to understand how a business uses energy and water, manages waste, treats employees, handles environmental risks and maintains ethical governance.

This is where BRSR Reporting in India becomes important.

BRSR stands for Business Responsibility and Sustainability Report. It is a sustainability reporting framework introduced by the Securities and Exchange Board of India, or SEBI, for listed entities.

The framework brings Environmental, Social and Governance information into a more structured reporting format. Instead of simply making broad claims about sustainability, companies are expected to disclose measurable information about their actual performance.

BRSR has been mandatory for the top 1,000 listed entities by market capitalisation from FY 2022-23 onwards.

For companies directly covered by BRSR, accurate reporting is a regulatory requirement. For manufacturers, suppliers and private companies outside the mandatory threshold, understanding BRSR is also becoming important because large listed customers increasingly seek ESG information from their value chains.

What is BRSR Reporting?

BRSR is a structured framework used by listed companies to disclose their environmental, social and governance performance.

It replaced the earlier Business Responsibility Report, commonly called BRR, for companies falling within the applicable threshold.

BRSR is based on the nine principles of the National Guidelines on Responsible Business Conduct, or NGRBC.

SEBI designed the framework to provide more quantitative and standardised ESG disclosures, making it easier to compare sustainability performance across companies and over time.

In simple terms, BRSR helps answer questions such as:

How much electricity does the company consume?

How much water does it use?

What are its Scope 1 and Scope 2 greenhouse gas emissions?

How much waste does the company generate and recycle?

How many employees and workers does it have?

What are its occupational health and safety records?

Does it have policies covering ethics, human rights and responsible business practices?

How does the company manage environmental and social risks?

The objective is to provide investors and other stakeholders with a clearer picture of the company's non-financial performance.

Who Needs to File BRSR in India?

The main applicability requirement is straightforward.

BRSR reporting is mandatory for the top 1,000 listed entities based on market capitalisation. Other listed entities can make BRSR disclosures voluntarily.

However, businesses should not assume that BRSR matters only to listed companies.

Its influence is gradually extending into supply chains.

A listed manufacturer may purchase raw materials and components from hundreds of private businesses. To understand its overall sustainability footprint, the company may ask important suppliers for information relating to energy, emissions, water, waste, employee safety and other ESG parameters.

This means BRSR readiness can also be useful for:

• Private manufacturers supplying large listed companies
• Export-oriented businesses
• Automotive component suppliers
• Chemical and pharmaceutical manufacturers
• Recycling companies
• Engineering businesses
• Renewable energy companies
• Companies seeking institutional investment
• Suppliers working with multinational corporations

A business may not legally need to file a BRSR today, but maintaining structured ESG data can make customer and investor reporting much easier.

What is the Format of BRSR?

The BRSR format is broadly divided into three main sections.

Section A - General Disclosures

Section A contains basic information about the organisation.

This can include company identity, year of incorporation, registered office, reporting period, stock exchanges where securities are listed and the reporting boundary.

It also asks for information relating to business activities and major products or services.

For example, the prescribed format seeks information about business activities accounting for approximately 90% of turnover, along with products and services contributing to the company's turnover.

This section establishes the basic profile of the reporting entity before ESG performance is discussed.

Section B - Management and Process Disclosures

Section B focuses on how sustainability is managed inside the organisation.

It looks at whether the company has policies, commitments, targets and governance mechanisms linked to responsible business conduct.

Companies may need to explain their ESG goals, performance against those goals and the responsibilities assigned to senior management.

SEBI's guidance also provides for a statement from the director responsible for the report explaining the relevance of sustainability to the organisation and its broader strategy.

This section is important because ESG reporting should not simply be a data collection exercise. Companies should demonstrate that sustainability risks and responsibilities are incorporated into management processes.

Section C - Principle-wise Performance Disclosure

Section C is generally the most detailed part of BRSR.

It requires companies to report performance against the nine principles of responsible business conduct.

The disclosures are divided into:

Essential Indicators - mandatory for entities required to file BRSR.

Leadership Indicators - voluntary indicators designed for companies that want to demonstrate more advanced sustainability practices.

The information can cover environmental performance, employee welfare, human rights, consumer responsibility, ethical governance and other areas.

Important BRSR Disclosures

Preparing BRSR requires information from several departments within a company.

Environmental disclosures can include energy use, renewable energy, water consumption, wastewater, greenhouse gas emissions, air emissions and waste generation.

For example, BRSR includes disclosure of:

• Total electricity consumption
• Total fuel consumption
• Energy from other sources
• Total energy consumption
• Energy intensity
• Scope 1 greenhouse gas emissions
• Scope 2 greenhouse gas emissions
• Water withdrawal and consumption
• Waste generated and recovered

The updated BRSR framework provides structured formats for energy consumption and intensity reporting.

Social disclosures can cover employees, workers, gender diversity, wages, training, occupational health and safety, human rights and employee welfare.

Governance-related disclosures can include ethics, anti-corruption measures, regulatory proceedings, complaints, policies and responsibilities of senior management.

This means BRSR preparation normally requires coordination between multiple departments rather than being completed only by the company's sustainability team.

What is BRSR Core?

BRSR Core is a focused subset of important ESG Key Performance Indicators taken from the broader BRSR framework.

SEBI introduced BRSR Core to improve the credibility and comparability of selected sustainability information.

The applicability was introduced through a phased approach.

The original glide path covers:

FY 2023-24 - Top 150 listed entities

FY 2024-25 - Top 250 listed entities

FY 2025-26 - Top 500 listed entities

FY 2026-27 - Top 1,000 listed entities

SEBI has also updated the framework to permit assessment or assurance of BRSR Core information under the applicable requirements. Its April 2025 FAQs further clarify requirements relating to independence and the standards that may be used for assurance engagements.

For covered companies, this makes supporting documentation particularly important.

Numbers reported in BRSR Core should be capable of being traced back to reliable source records.

What Documents Are Required for BRSR Reporting?

There is no single document checklist that works for every organisation because requirements depend on industry and operations.

However, companies typically need information such as:

• Electricity bills and meter records
• Diesel, petrol, LPG and natural gas consumption
• Renewable electricity information
• Scope 1 and Scope 2 emission calculations
• Water bills and groundwater records
• Waste generation and disposal records
• Hazardous waste manifests
• Pollution Control Board approvals
• Environmental monitoring reports
• Employee and worker data
• Gender diversity records
• Training records
• Occupational health and safety records
• Accident and incident data
• CSR information
• Customer complaints
• Ethics and anti-bribery policies
• Supplier and procurement data
• Board-approved sustainability policies

Maintaining these records monthly is much easier than attempting to reconstruct an entire year's ESG performance at the time of annual reporting.

BRSR Reporting Process in India

A well-managed BRSR reporting exercise normally starts with a gap assessment.

Step 1 - Determine Applicability

First, establish whether the company falls within the mandatory BRSR reporting threshold and whether BRSR Core assessment or assurance requirements also apply.

Step 2 - Define Reporting Boundary

The company must determine the organisational boundary covered by its disclosures.

The prescribed BRSR format specifically asks whether disclosures are prepared on a standalone or consolidated basis.

This should be clearly established before collecting ESG data.

Step 3 - Conduct ESG Gap Assessment

Existing policies, records and systems should be compared against the BRSR requirements.

The company may discover that some data is already available but spread across HR, finance, EHS, procurement and production teams.

Missing information should be identified early.

Step 4 - Collect and Validate Data

The company should collect environmental, social and governance data from relevant departments and operating locations.

Numbers should be reconciled with source records wherever possible.

For example, reported electricity consumption should reconcile with electricity bills and meter data.

Waste quantities should match disposal manifests and authorised recycler records.

Step 5 - Calculate ESG Indicators

Several indicators require calculations rather than simple data entry.

These can include:

energy intensity, greenhouse gas emissions, water intensity, waste intensity and other performance indicators.

A documented calculation methodology should be maintained so that numbers can be reviewed later.

Step 6 - Prepare the BRSR

Once the data has been validated, it can be entered into the prescribed BRSR structure.

The reporting team should also review qualitative disclosures carefully.

Descriptions of company policies or sustainability performance should match actual practices rather than simply using generic ESG language.

Step 7 - Assessment or Assurance Where Applicable

Companies falling within the applicable BRSR Core requirements need to follow the relevant assessment or assurance framework.

Supporting data, calculation sheets and source documents should therefore be organised before the review begins.

Step 8 - Include BRSR in Annual Reporting

For companies required to report, BRSR forms part of their annual reporting obligations.

Companies should therefore align their sustainability reporting calendar with financial reporting, Board review and annual report preparation.

BRSR Value Chain Reporting

Another important development relates to the ESG performance of suppliers and customers.

SEBI subsequently eased the earlier BRSR Core value-chain framework. Value-chain disclosures for the relevant top listed entities were made voluntary from FY 2025-26.

The revised scope focuses on upstream and downstream partners that individually represent 2% or more of purchases or sales by value, while allowing reporting to be limited to partners collectively covering up to 75% of purchases and sales respectively.

This is particularly important for Indian MSMEs.

A smaller manufacturer may not be directly subject to mandatory BRSR reporting but could still receive ESG questionnaires from a major listed customer.

Preparing basic environmental and social data in advance can make such supplier assessments much easier.

Common Challenges in BRSR Reporting

One of the biggest problems companies face is fragmented data.

Energy numbers may be maintained by plant teams, employee information by HR, waste records by EHS and supplier information by procurement.

If these departments follow different systems and reporting periods, preparing a consolidated BRSR can become difficult.

Another problem is lack of supporting evidence.

A company may report that 70% of its waste was recycled but later struggle to produce recycler invoices, manifests or weight records supporting that percentage.

Companies can also face difficulties with greenhouse gas calculations, reporting boundaries, energy intensity calculations and ESG policies.

Starting the process early is therefore important.

BRSR should ideally become part of the company's regular data management system rather than an annual exercise carried out just before filing.

Benefits of Proper BRSR Reporting

Good BRSR reporting can provide benefits beyond regulatory compliance.

It helps management understand where resources are being consumed and where improvement opportunities exist.

For example, analysing electricity consumption may identify energy-efficiency opportunities.

Waste data can reveal materials that could be recovered instead of disposed of.

Employee safety information can highlight recurring operational risks.

BRSR reporting can also improve transparency with investors, customers and other stakeholders.

For suppliers and manufacturers, stronger ESG documentation may improve readiness for corporate procurement assessments and international customer requirements.

Most importantly, structured reporting helps companies move from sustainability claims to measurable performance.

How a BRSR Consultant Can Help

Preparing BRSR can become complex when the organisation operates several factories, warehouses or business divisions.

An experienced BRSR consultant in India can help establish a structured reporting process.

Consulting support may include:

BRSR applicability assessment, ESG gap analysis, data collection templates, Scope 1 and Scope 2 emission calculations, environmental performance analysis, BRSR Core readiness, policy development, value-chain ESG support and preparation for assessment or assurance.

A consultant can also coordinate information between departments and identify gaps before the annual reporting deadline.

For manufacturers, ESG reporting can be linked with existing environmental compliance such as Consent to Establish, Consent to Operate, hazardous waste management, EPR, energy use and pollution monitoring.

This creates a more practical compliance system rather than maintaining ESG reporting separately from everyday operations.

Conclusion

BRSR has become an important part of India's corporate sustainability framework.

It requires covered listed companies to report measurable environmental, social and governance information rather than relying only on general sustainability statements.

For the top 1,000 listed entities, BRSR reporting is mandatory. At the same time, BRSR Core, assessment or assurance requirements and growing value-chain expectations are making high-quality ESG data increasingly important.

Businesses should therefore create systems for collecting energy, emissions, water, waste, employee, governance and supplier information throughout the year.

Strong ESG reporting begins with reliable data and clear documentation.

Green Permits supports Indian businesses with BRSR preparation, ESG reporting, BRSR Core readiness, carbon accounting, Scope 1 and Scope 2 calculations, sustainability assessments and environmental compliance.

Need Support with BRSR Reporting or ESG Compliance?

Website: https://www.greenpermits.in

Phone: +91 78350 06182

Email: wecare@greenpermits.in