Environmental, Social and Governance reporting has become an important part of corporate compliance in India, particularly for listed companies.

Two terms that businesses frequently come across are BRSR and BRSR Core. They sound similar, but they are not the same.

BRSR, or Business Responsibility and Sustainability Reporting, is the broader ESG disclosure framework prescribed by the Securities and Exchange Board of India. BRSR Core is a focused subset of BRSR containing selected Key Performance Indicators that receive additional verification through assessment or assurance.

Understanding the difference is important because companies need to know what information must be reported, which entities are covered, what supporting documents should be maintained and whether independent assessment or assurance is required.

For Indian manufacturers, listed businesses, corporate groups and suppliers working with large listed entities, understanding these requirements can also improve ESG data management and future compliance readiness.

What Is BRSR?

BRSR stands for Business Responsibility and Sustainability Report.

SEBI introduced BRSR to create a structured framework through which listed companies disclose information relating to their environmental, social and governance performance.

BRSR became mandatory from FY 2022-23 for the top 1,000 listed entities by market capitalization. Other listed entities may make BRSR disclosures voluntarily.

The framework is designed around the principles of responsible business conduct and includes both quantitative and qualitative disclosures.

Instead of simply stating that a company follows sustainable practices, BRSR requires businesses to provide structured information about areas such as energy, emissions, water, waste, workforce, safety and responsible business practices.

This helps investors and other stakeholders evaluate a company's ESG performance in a more standardized manner.

What Is BRSR Core?

BRSR Core is not a completely separate sustainability report.

It is a subset of the larger BRSR framework containing selected ESG Key Performance Indicators or KPIs that are considered particularly important for comparability and verification.

SEBI introduced the BRSR Core framework in July 2023. It covers KPIs under nine ESG attributes and was designed to make selected sustainability information more reliable and comparable.

For applicable listed entities, these Core indicators are subject to third-party assessment or assurance according to the applicable SEBI framework.

This is one of the biggest differences between BRSR and BRSR Core.

BRSR provides the larger sustainability disclosure structure, while BRSR Core focuses on a smaller group of important metrics where stronger verification is expected.

BRSR vs BRSR Core: Main Difference

The easiest way to understand the difference is to look at their purpose.

ParticularBRSRBRSR CoreFull FormBusiness Responsibility and Sustainability ReportBusiness Responsibility and Sustainability Report CoreNatureComprehensive ESG reporting frameworkSelected subset of BRSRCoverageBroad environmental, social and governance disclosuresSelected ESG KPIsApplicabilityTop 1,000 listed entities by market capitalizationPhased applicability for assessment/assuranceMain PurposeESG transparency and sustainability reportingGreater reliability of key ESG metricsVerificationEntire BRSR is not automatically subject to Core verificationApplicable Core KPIs undergo assessment or assuranceReporting LocationAnnual ReportForms part of the BRSR frameworkIn simple terms:

BRSR tells stakeholders about the company's wider ESG performance.

BRSR Core focuses on selected numbers that require stronger verification.

Who Needs to File BRSR in India?

BRSR is mandatory for the top 1,000 listed entities by market capitalization.

SEBI made it mandatory beginning with FY 2022-23, replacing the earlier Business Responsibility Report framework for these entities.

Other listed entities may also choose to disclose BRSR voluntarily.

Companies that are not directly covered can still benefit from preparing similar ESG information.

This is especially relevant for:

• Large private companies
• Manufacturers supplying listed companies
• Exporters
• Companies seeking institutional investment
• Businesses supplying multinational corporations
• Companies planning future listings
• Businesses receiving ESG questionnaires from customers

Therefore, even when BRSR is not directly mandatory, the underlying ESG data may still become commercially important.

BRSR Core Applicability

BRSR Core assessment or assurance has been introduced gradually rather than applying to all 1,000 entities at once.

SEBI originally prescribed the following glide path:

• 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

This phased structure allows companies to progressively strengthen their ESG data collection and verification systems.

SEBI subsequently provided flexibility by allowing assessment or assurance for BRSR Core instead of framing the requirement only around assurance.

For businesses, this makes proper ESG documentation even more important because selected information needs to be capable of independent verification.

What Does BRSR Cover?

BRSR is broader than carbon reporting.

A company cannot complete BRSR simply by calculating greenhouse gas emissions.

The framework looks at the overall responsible business performance of the company.

Important areas can include:

Environmental Performance

Companies may need to maintain information relating to:

• Energy consumption
• Renewable energy
• Water withdrawal and consumption
• Greenhouse gas emissions
• Air emissions
• Waste generation
• Waste recovery and disposal
• Environmental compliance

For manufacturers, these figures often come from electricity bills, fuel records, water meters, waste manifests and environmental monitoring reports.

Employee and Workforce Information

BRSR also examines social indicators relating to employees and workers.

These can include workforce composition, employee benefits, health and safety, training and other labour-related information.

Governance and Responsible Business

Companies are expected to disclose information regarding business responsibility, policies, complaints and governance mechanisms.

The objective is to understand whether sustainability principles are embedded into actual business operations.

What Does BRSR Core Cover?

BRSR Core takes selected information from the wider BRSR and places greater emphasis on measurable KPIs.

SEBI describes BRSR Core as a subset containing KPIs and metrics across nine ESG attributes.

The Core framework includes metrics related to areas such as resource use, emissions and social indicators.

It was designed partly to improve comparability between companies and increase confidence in ESG data.

This means companies need stronger internal controls around Core metrics.

For example, a reported electricity consumption figure should be traceable back to supporting electricity bills or meter data.

Similarly, waste information should reconcile with waste registers, manifests and disposal records.

BRSR Core Assessment or Assurance

One major area of confusion is whether companies require assurance for every BRSR disclosure.

They do not.

The specific assessment or assurance requirement relates to BRSR Core for entities covered by the applicable phased framework.

SEBI's updated approach allows applicable listed entities to undertake either third-party assessment or assurance of BRSR Core. SEBI has also clarified standards and independence considerations applicable to such providers.

This means companies should avoid waiting until year-end to collect Core information.

Monthly or quarterly ESG data management generally makes verification easier.

What About BRSR Core Value Chain Disclosures?

Value-chain ESG reporting is particularly relevant to suppliers.

SEBI's framework has evolved in this area.

Under the updated position, ESG disclosures for the value chain of the top 250 listed entities are voluntary from FY 2025-26. Associated third-party assessment or assurance is also voluntary.

The current framework identifies relevant upstream and downstream partners using thresholds linked to the value of purchases and sales, while allowing companies to limit the coverage subject to specified conditions.

This is important even for private and unlisted businesses.

A company may not be required to submit BRSR itself but could still receive ESG data requests because it supplies a large listed company.

That supplier may then be asked for information on electricity, water, emissions, waste, workforce or other ESG indicators.

Documents Required for BRSR and BRSR Core

Good ESG reporting depends on strong supporting documentation.

Companies should avoid calculating the entire report from estimates prepared at the end of the year.

Important documents may include:

Environmental Documents

Electricity bills, diesel records, renewable energy documentation, water bills, meter records, waste manifests, pollution monitoring reports and recycler certificates can support environmental disclosures.

Applicable regulatory documents may also include Consent to Establish, Consent to Operate, Environmental Clearance, hazardous waste authorization and EPR registrations.

Human Resource Documents

Employee master records, payroll information, gender data, workforce numbers, training registers and safety records may be required.

Companies with contract workers should also maintain proper records instead of tracking only permanent employees.

Health and Safety Documents

Important records can include accident registers, safety training, PPE distribution, medical examination records, emergency drills and corrective action reports.

Governance Documents

Companies should maintain relevant policies, management approvals, grievance information and other governance records supporting their disclosures.

BRSR Reporting Process

A structured BRSR process can reduce errors significantly.

Step 1: Identify Applicability

Determine whether the company falls within mandatory BRSR and BRSR Core requirements.

Step 2: Map ESG KPIs

Identify which ESG indicators need data from each department.

For example, electricity data may come from finance and plant operations, while employee information comes from HR.

Step 3: Assign Data Owners

Each KPI should have a responsible person or department.

Without clear ownership, ESG information often becomes fragmented.

Step 4: Collect Supporting Evidence

Do not record only the final number.

Maintain the underlying documents used to calculate it.

Step 5: Verify Calculations

Check units, formulas, reporting boundaries and year-on-year consistency.

Step 6: Conduct Internal Review

Before final reporting, an internal ESG review can identify missing records and calculation errors.

Step 7: Assessment or Assurance

Where BRSR Core assessment or assurance applies, supporting data should be organized for the independent provider.

Common BRSR Compliance Challenges

One of the biggest challenges companies face is scattered data.

HR may maintain employee numbers, finance may hold utility bills, the EHS department may control environmental records and procurement may hold supplier information.

If departments work independently, discrepancies can appear.

Another common issue is inconsistent units.

For example, one factory may record water in litres while another uses kilolitres.

Similarly, energy data may be recorded using different units across manufacturing sites.

Poor documentation can also create problems.

A company may report that 800 tonnes of waste were recycled, but during verification it must be able to demonstrate how the figure was calculated and where the waste was sent.

Benefits of Strong BRSR Compliance

BRSR compliance should not be treated purely as an annual filing exercise.

When managed properly, ESG data can help companies understand their operational performance.

Energy data can identify inefficient facilities.

Water data can highlight opportunities for reuse.

Waste data can reveal material recovery opportunities.

Employee information can help management identify workplace and safety trends.

Strong ESG systems may also improve preparedness for investors, institutional lenders, customers and supply-chain ESG assessments.

How a BRSR Consultant Can Help

Preparing BRSR involves multiple departments and large amounts of ESG information.

A professional ESG consultant can help establish a more structured reporting system.

Support may include:

• BRSR applicability assessment
• BRSR Core readiness
• ESG data mapping
• KPI identification
• ESG document checklist
• Environmental compliance review
• Data gap assessment
• Carbon and GHG data support
• Internal ESG review
• Assessment or assurance readiness
• Sustainability reporting support
• Value-chain ESG data preparation

For manufacturing companies, consultants can also connect ESG information with existing environmental compliance records such as CTE, CTO, EPR and waste authorizations.

This can reduce duplication and create a more reliable ESG reporting system.

BRSR Core vs BRSR: Which One Should Companies Prepare For?

Companies should not look at BRSR and BRSR Core as competing frameworks.

BRSR is the broader report.

BRSR Core sits within that reporting ecosystem and focuses on selected KPIs requiring stronger verification for applicable entities.

A good approach is therefore to first build a strong BRSR data system and then create additional controls around the BRSR Core indicators.

Even businesses that are currently outside mandatory applicability can benefit from understanding the framework, particularly if they are growing rapidly, planning a listing, seeking investment or supplying major listed companies.

Conclusion

BRSR Core vs BRSR are important parts of India's evolving ESG reporting framework.

BRSR provides the broader structure for environmental, social and governance disclosures, while BRSR Core focuses on selected KPIs where additional assessment or assurance requirements apply to covered listed entities.

Companies should therefore focus not only on preparing the final report but also on developing reliable ESG data systems throughout the year.

Maintaining monthly data, assigning KPI owners, keeping supporting documents and conducting internal reviews can make BRSR compliance significantly easier.

Green Permits supports Indian companies with BRSR reporting, BRSR Core readiness, ESG audits, ESG disclosure preparation, carbon accounting, environmental compliance assessment and sustainability advisory services.

For professional assistance with BRSR and ESG compliance:

Website: https://www.greenpermits.in

Phone: +91 78350 06182

Email: wecare@greenpermits.in