BRSR Reporting Guide

The Business Responsibility and Sustainability Report (BRSR) is the statutory environmental, social and governance disclosure format set by the Securities and Exchange Board of India (SEBI) under the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015, Regulation 34(2)(f). It is not a voluntary sustainability report and not a rating. It is a prescribed format that an in-scope listed entity completes and files with the stock exchanges as part of its annual report.

Who files it. Filing became mandatory for the top 1,000 listed entities by market capitalisation from financial year 2022-23, following a voluntary year in financial year 2021-22. The test is a market capitalisation rank, not a turnover figure, so an entity moves in or out of scope as its rank changes.

What replaced what. The BRSR succeeded the earlier Business Responsibility Report (BRR), a narrower disclosure that carried far fewer indicators and no assurable subset. The BRSR widened the disclosure set, restructured it around the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), and later added an assurable core. An entity reading older guidance should check whether it refers to the BRR or the BRSR, because the indicator sets are not interchangeable.

How large the report is. The format carries around 140 disclosure indicators, of which around 98 are essential and around 42 are leadership. The count is approximate and varies by version of the format, so it is read as an order of magnitude rather than a fixed statutory number.

How it is filed. Submission is made in PDF and in XBRL alongside the annual report. The XBRL filing is what makes the disclosure machine-readable for the exchanges and for downstream users of the data.

The commercial side of BRSR, where a consultant runs the gap analysis, builds the data systems and readies the file for independent assurance, sits on the BRSR reporting services page. This guide holds the how-it-works detail.

Reading the BRSR is much easier once the three-section structure is clear, because the sections ask fundamentally different kinds of question.

Why Section C carries the weight

Section C is the principle-wise engine of the report. Each of its nine blocks asks the entity to report indicators that operationalise one principle. In practice this means ethics and anti-corruption data sit under Principle 1, product life-cycle and safety data under Principle 2, workforce wellbeing and safety data under Principle 3, stakeholder engagement under Principle 4, human-rights due-diligence data under Principle 5, environmental data covering energy, emissions, water, waste and biodiversity under Principle 6, policy-advocacy positions under Principle 7, social-impact and inclusive-sourcing data under Principle 8, and consumer, product-labelling and data-privacy metrics under Principle 9.

Principle 6 is the environmental heart of Section C, which is why the majority of the assurable BRSR Core environmental indicators cross-reference back to Principle 6 essential indicators.

Provenance matters here. The Ministry of Corporate Affairs released the National Guidelines on Responsible Business Conduct (NGRBC) on 15 March 2019, revising the 2011 National Voluntary Guidelines on Social, Environmental and Economic Responsibilities of Business and aligning them with the United Nations Sustainable Development Goals and the United Nations Guiding Principles on Business and Human Rights. SEBI then built the BRSR disclosure format on those nine principles. Attributing the principles themselves to SEBI is a common and avoidable error.

Every block of Section C maps to one of these nine principles, so the principle list doubles as the table of contents for the performance half of the report.

Essential indicators are the compulsory floor. Every in-scope entity completes them for all nine principles. Leadership indicators are an optional ceiling that an entity may adopt to demonstrate maturity on a given principle. Presenting leadership indicators as compulsory is incorrect, and so is treating a full essential-tier filing as incomplete because leadership questions were left unanswered.

Across the whole report the format carries around 140 indicators, of which around 98 are essential and around 42 are leadership. The design runs principle by principle: each principle has its own essential questions and its own leadership questions, so an entity can be fully compliant on the essential tier of all nine principles while choosing selectively which leadership indicators to answer.

This matters for assurance. The BRSR Core key performance indicators that require reasonable assurance or third-party assessment are drawn from the ESSENTIAL indicators, chiefly under Principle 6 covering environment, and additionally under Principle 3 for employee wellbeing and safety, Principle 5 for gender diversity, Principle 8 for inclusive development, and Principles 9 and 1. They are not drawn from the leadership tier. An entity planning for assurance therefore hardens its essential-indicator data first.

Two of these attributes reflect an explicitly Indian and emerging-market framing. Job creation in smaller towns is measured as wages paid to persons employed in smaller towns as a percentage of total wage cost, categorised on the Reserve Bank of India rural, semi-urban, urban and metropolitan classification. Open-ness of business, measured through related-party concentration, is likewise not a standard feature of international frameworks.

Only the four environmental attributes carry intensity ratios: greenhouse gas emissions, water, energy and waste. The other five attributes covering employee wellbeing and safety, gender diversity, inclusive development, fairness, and openness use percentages, rates such as the Lost Time Injury Frequency Rate, and counts. They do not use per-turnover intensity.

For each of those four, three denominators are in play across the wider BRSR and BRSR Core:

• Nominal per rupee of turnover. The wider BRSR, at the Principle 6 essential indicators, already asks for intensity per rupee of turnover in nominal rupees.
• Per rupee of turnover adjusted for purchasing power parity. Computed as the total quantity, for example total Scope 1 and Scope 2 emissions in metric tonnes, divided by total revenue from operations adjusted for purchasing power parity, using the purchasing power parity conversion rate for the United States dollar against the Indian rupee.
• Output-based, or physical, intensity. Computed as the total quantity divided by a company and sector specific output measure, such as number of vehicles produced, metric tonnes of material produced, room-nights, or number of seats and travel class.

Why purchasing power parity is used

The stated purpose of the adjustment is global comparability. Intensity ratios based on revenue adjusted for purchasing power parity make cross-country comparison fairer to low-cost and developing economies, so an Indian entity environmental efficiency is not distorted by nominal exchange-rate and price-level differences when a foreign investor or buyer benchmarks it against peers abroad.

The conversion rate itself is an externally published figure rather than a number SEBI issues. The reporting entity applies the latest available rate for India and discloses the rate it used, so two entities reporting in the same year should be checked for the rate each applied before their ratios are compared directly.

The pairing is deliberate. The monetary ratio lets an investor compare across sectors and jurisdictions; the output ratio lets an operator compare against physical peers making the same product.

Reasonable assurance is the higher bar. It involves extensive testing, larger samples, evaluation of internal controls, and a positive form of conclusion. Limited assurance is the lower bar, involving less extensive procedures and a negative form of conclusion. The two are not interchangeable, and a BRSR Core requirement for reasonable assurance is not satisfied by a limited assurance engagement.

Assessment became an alternative in March 2025. SEBI circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42 dated 28 March 2025 renamed the approach column of the format from "Data and Assurance" to "Data and Assessment or Assurance", clarifying that an entity may obtain either reasonable assurance or a third-party assessment carried out under standards developed by the Industry Standards Forum in consultation with SEBI.

Independence is a hard rule. The assurance or assessment provider must be free of any conflict of interest with the listed entity, and must not sell products or provide non-audit or non-assurance services to the entity or its group. This is the boundary that separates preparation from verification.

What a consultant does, and does not do. Preparing the underlying data, mapping each indicator to its NGRBC principle and essential indicator, computing the intensity ratios and readying the file for independent assurance is advisory work. Reasonable assurance and third-party assessment are performed by independent accredited third parties. Any ESG rating is issued separately by an ESG Rating Provider registered with SEBI. GreenSutra works only on the preparation side and does not verify, assure, assess, score or rate a BRSR filing.

A note on how ratings weight the three pillars

Pillar weighting differs between rating providers, and is not always environment-heaviest. One published ESG rating methodology dated May 2026 weights governance highest, ahead of environment and social. The common assumption that the environmental pillar dominates an ESG rating is therefore unsafe as a general statement, and a governance narrative can carry as much weight as emissions data. Because the weights differ by provider, they are meaningful only against a named methodology and date rather than as an industry standard. The question on improving an ESG rating sets out the published weights with their source.

Who it applies to. Value chain disclosure applies to the top 250 listed entities by market capitalisation. The figure 250 is a market capitalisation rank, not a rupee turnover threshold. Reading it as a turnover cut-off is a common conflation, and it produces the wrong answer on scope.

How partners are identified now. Under the original framework of 12 July 2023 the value chain comprised partners cumulatively accounting for 75 percent of purchases or sales by value, on a comply-or-explain basis. The circular of 28 March 2025 revised the identifying test to partners individually comprising 2 percent or more of the entity purchases or sales by value, while permitting an entity to limit disclosure to partners cumulatively covering 75 percent. So 75 percent survives only as an optional disclosure cap. It is no longer the identifying definition.

The status is now voluntary. The same March 2025 circular changed value chain ESG disclosure, and its third-party assessment or assurance, from comply-or-explain to voluntary. Reporting of value chain ESG data for financial year 2024-25 is voluntary in financial year 2025-26, with assessment or assurance of that data also voluntary.

Green credits. The March 2025 circular also introduced a voluntary green credits disclosure indicator, covering green credits generated or procured by the listed entity, from financial year 2024-25. It is a disclosure line, not an obligation to acquire anything.

The BRSR format allows a listed entity already preparing sustainability reports under internationally accepted frameworks such as GRI, SASB, TCFD or Integrated Reporting to cross-reference those disclosures to the corresponding BRSR items rather than restate them. That permission is what makes a single measurement programme viable for an entity facing several reporting audiences.

In practice one measured indicator, for example Scope 1 and Scope 2 greenhouse gas emissions, water consumption or energy consumption, maps across GRI topic standards, the European Sustainability Reporting Standards used under the EU Corporate Sustainability Reporting Directive, and the ISSB baseline in IFRS S1 and IFRS S2, the latter building on the TCFD recommendations.

One boundary is worth stating plainly. India has not mandated IFRS S1 or IFRS S2. SEBI uses the BRSR and BRSR Core. Alignment with the ISSB baseline or with TCFD therefore functions for an Indian listed entity as an investor, lender or overseas-customer expectation, not as a domestic legal requirement. A formal SEBI-to-ISSB mapping should not be asserted as law.

Exporters facing buyer questionnaires and EU customer requirements will find that angle developed in the ESG reporting guide, which covers the international frameworks and the CSRD phase-in rather than the SEBI format.