By Dev Rao | Updated March 2026
What Is BRSR?
The Business Responsibility and Sustainability Report (BRSR) is India's mandatory ESG (Environmental, Social, and Governance) disclosure framework for listed companies. Introduced by the Securities and Exchange Board of India (SEBI) through an amendment to Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR), the BRSR replaced the earlier Business Responsibility Report (BRR) and became mandatory for the top 1,000 listed companies by market capitalization from FY 2022-23 onwards.
The BRSR is structured around the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), issued by the Ministry of Corporate Affairs in 2019. It requires companies to report 140 indicators — 98 essential (mandatory) and 42 leadership (voluntary but recommended) — covering environmental metrics (greenhouse gas emissions, energy consumption, water use, waste management), social metrics (workforce diversity, gender pay ratios, occupational safety, training hours), and governance metrics (ethics policies, anti-corruption, stakeholder engagement).
For foreign investors in Indian listed companies — whether through FDI, portfolio investment, or as part of a joint venture or supply chain — BRSR disclosures are now the primary source of standardized ESG data on Indian companies. If your company is listed on an Indian stock exchange or is a value chain partner of a top-250 listed company, BRSR compliance is either mandatory or imminent.
Legal Basis
- Regulation 34(2)(f) of SEBI (LODR) Regulations, 2015 — Mandates the inclusion of BRSR as part of the annual report for applicable listed entities. Amended via SEBI Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated May 10, 2021.
- SEBI Circular dated July 12, 2023 — Introduced the BRSR Core framework with enhanced KPIs, value chain disclosure requirements, and a phased assurance roadmap for the top 150/250/500/1,000 companies.
- SEBI Circular dated March 28, 2025 — Eased value chain disclosure requirements, making them voluntary instead of mandatory, and introduced voluntary green credit disclosures.
- National Guidelines on Responsible Business Conduct (NGRBC), 2019 — The nine-principle framework published by the Ministry of Corporate Affairs that underpins the BRSR structure.
- Companies Act, 2013 — Section 134(3)(o) — Requires the Board's report (filed as part of the annual return) to include a statement on compliance with applicable environmental laws and conservation efforts.
The 9 NGRBC Principles
Every BRSR disclosure is organized around these nine principles. Each principle has corresponding essential and leadership indicators that companies must report on:
| Principle | Full Name | Key Disclosures |
|---|---|---|
| P1 | Businesses should conduct and govern themselves with integrity and in a manner that is ethical, transparent, and accountable | Anti-corruption policies, ethics code, whistleblower complaints, fines for misconduct |
| P2 | Businesses should provide goods and services in a manner that is sustainable and safe | Sustainable sourcing, life cycle assessments, recycled/reused inputs, extended producer responsibility |
| P3 | Businesses should respect and promote the well-being of all employees including those in their value chains | Workforce details by gender/category, benefits coverage, health and safety metrics, training hours, return-to-work rates |
| P4 | Businesses should respect the interests of and be responsive to all their stakeholders | Stakeholder identification, engagement mechanisms, grievance redressal, material issues mapping |
| P5 | Businesses should respect and promote human rights | Human rights due diligence, forced/child labor prevention, POSH compliance, discrimination complaints |
| P6 | Businesses should respect and make efforts to protect and restore the environment | Scope 1/2/3 GHG emissions, energy consumption, water withdrawal/discharge, waste generation/recycling, biodiversity assessments |
| P7 | Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent | Trade association memberships, advocacy positions, anti-competitive conduct cases |
| P8 | Businesses should promote inclusive growth and equitable development | CSR expenditure, community engagement, local procurement, input material sourcing from MSMEs |
| P9 | Businesses should engage with and provide value to their consumers in a responsible manner | Product labeling, data privacy, consumer complaints, product recalls, cybersecurity policies |
BRSR Format: Essential vs. Leadership Indicators
The BRSR report consists of three sections:
- Section A: General Disclosures — Company information, products/services, operations, employees, CSR details, regulatory compliance status. This section provides the baseline context.
- Section B: Management and Process Disclosures — Policies and governance structures aligned to each of the 9 NGRBC principles. Documents whether the company has formal policies, board-level oversight, and defined processes for each principle.
- Section C: Principle-wise Performance Disclosures — The core of the BRSR. Contains 98 essential indicators (mandatory) and 42 leadership indicators (voluntary). Essential indicators are quantitative and comparable across companies. Leadership indicators demonstrate advanced ESG maturity (e.g., science-based emission targets, living wage implementation, Scope 3 measurement).
Applicability and Phased Implementation
| Financial Year | BRSR Requirement | BRSR Core Assurance | Value Chain Disclosure |
|---|---|---|---|
| FY 2022-23 | Mandatory for top 1,000 listed companies by market capitalization | Not required | Not required |
| FY 2023-24 | Top 1,000 companies | Reasonable assurance for top 150 companies | Voluntary for top 250 companies |
| FY 2024-25 | Top 1,000 companies | Reasonable assurance for top 250 companies | Comply-or-explain for top 250 companies |
| FY 2025-26 | Top 1,000 companies | Reasonable assurance for top 500 companies | Voluntary (eased by SEBI March 2025 circular) |
| FY 2026-27 | Top 1,000 companies | Reasonable assurance for top 1,000 companies | Voluntary with assurance (for top 250) |
BRSR Core: The Assurance-Ready Subset
BRSR Core is a subset of approximately 30 Key Performance Indicators (KPIs) extracted from the full 140-indicator BRSR framework. These KPIs are designed to be independently verifiable — they require reasonable assurance (the same confidence level as a statutory financial audit) from a third-party assurance provider. Key BRSR Core KPIs include Scope 1 and Scope 2 greenhouse gas emissions, energy consumption intensity, water withdrawal and discharge, waste generated and diverted from disposal, gender diversity in workforce and leadership, median remuneration ratios, occupational health and safety incidents, and training hours per employee.
Value Chain Disclosure Requirements
SEBI initially required the top 250 listed companies to disclose ESG data about their value chain partners — upstream suppliers and downstream customers individually contributing 2% or more of total purchases/sales by value, collectively covering at least 75% of transactions. This was a significant burden, as it required companies to collect ESG data from their suppliers and customers.
In December 2024, SEBI's board approved easing these requirements. The March 28, 2025 circular changed value chain ESG disclosure from "comply-or-explain" to fully voluntary, giving companies more time to build the data collection systems. Mandatory value chain assurance, originally planned for FY 2025-26, has been deferred. This easing is particularly relevant for foreign companies in the supply chains of Indian listed companies — the immediate compliance pressure has reduced, but the direction of travel toward mandatory value chain disclosure is clear.
Comparison with Global ESG Frameworks
| Parameter | India BRSR | EU CSRD/ESRS | GRI Standards | ISSB (IFRS S1/S2) |
|---|---|---|---|---|
| Mandatory/Voluntary | Mandatory for top 1,000 listed companies | Mandatory for ~50,000 EU companies (phased) | Voluntary (widely adopted globally) | Voluntary (adopted by some jurisdictions) |
| Scope | 140 indicators across ESG | ~1,100+ data points across 12 standards | Modular — company selects material topics | Focused on climate and sustainability-related financial risks |
| Assurance | Reasonable assurance (phased: top 150→1,000 by FY 2026-27) | Limited assurance initially; reasonable assurance planned | No mandatory assurance | Jurisdiction-dependent |
| Value Chain | Voluntary (eased in 2025) | Mandatory upstream and downstream | Encouraged but not mandated | Required for material climate risks |
| Governing Body | SEBI | European Commission / EFRAG | Global Sustainability Standards Board | International Sustainability Standards Board |
| Alignment | NGRBC, UN SDGs | EU Taxonomy, Paris Agreement | Universal Standards | TCFD recommendations |
How This Affects Foreign Investors in India
Foreign-Invested Listed Companies
If a foreign company has invested in an Indian listed entity (through FDI, joint ventures, or portfolio holdings), and that entity is within the top 1,000 by market capitalization, BRSR compliance is mandatory. The foreign parent or investor should ensure the Indian entity has the systems, data collection processes, and assurance arrangements in place. Non-compliance results in penalties under SEBI LODR and reputational risk.
Supply Chain Impact
Even if your company is not listed in India, you may be affected if you are a supplier to or customer of a top-250 Indian listed company. While value chain ESG disclosure is currently voluntary (post the March 2025 easing), the direction is clear — large Indian companies will increasingly request ESG data from their supply chain partners. Foreign suppliers should proactively prepare ESG data aligned with BRSR Core KPIs.
Cross-Border ESG Reporting
For companies listed in both India and another jurisdiction (EU, UK, Singapore), BRSR disclosures must be reconciled with CSRD, GRI, or ISSB reporting. The good news is that BRSR is largely aligned with GRI Standards and UN SDGs, so a company already reporting under GRI can map most BRSR indicators to existing data. The BRSR's 9 NGRBC principles broadly correspond to GRI's Universal Standards and Topic Standards.
Penalties for Non-Compliance
BRSR is enforced through the SEBI LODR framework. Non-compliance consequences include:
- Monetary penalty: INR 2,000 per day of default for failure to submit the annual report (which includes BRSR) under Regulation 34 of SEBI LODR.
- Stock exchange action: The stock exchange can issue warnings, impose fines, suspend trading, or freeze promoter holdings under the Standard Operating Procedure for non-compliance with LODR provisions.
- SEBI enforcement: SEBI can initiate adjudication proceedings under Section 15HB of the SEBI Act, 1992, with penalties up to INR 1 crore for failure to comply with regulations.
- Reputational risk: Non-compliance is publicly disclosed and affects ESG ratings from agencies like CRISIL, ICRA, and S&P Global — impacting foreign investor sentiment and capital access.
Common Mistakes
- Treating BRSR as a check-the-box exercise rather than a data infrastructure project. BRSR requires actual measurement of Scope 1/2 GHG emissions, water withdrawal by source, waste by type, gender pay ratios, and training hours. Companies that attempt to fill in the BRSR template at year-end without having measurement systems in place produce unreliable data that fails assurance. Start building the data collection infrastructure 6-12 months before the reporting period.
- Confusing essential indicators (mandatory) with leadership indicators (voluntary) and skipping both. The 98 essential indicators are non-negotiable for top-1,000 companies. However, ESG-conscious foreign investors specifically look at leadership indicators (science-based targets, living wage, Scope 3 emissions) to evaluate ESG maturity. Reporting only essential indicators signals minimal compliance rather than genuine commitment.
- Assuming BRSR Core assurance is the same as a regular audit. BRSR Core assurance requires "reasonable assurance" — the same confidence level as a statutory financial audit — not "limited assurance" (which is a lower bar). The assurance provider must follow standards developed by the Industry Standards Forum (ISF) in consultation with SEBI. Many companies engage their statutory auditor for BRSR assurance, but the skill set required (environmental engineering, social metrics, GHG protocols) is different from financial auditing.
- Ignoring the value chain disclosure trajectory. Although SEBI eased value chain requirements to voluntary in March 2025, this is a temporary reprieve. The regulatory direction is unmistakably toward mandatory value chain ESG disclosure with assurance. Companies that delay building supplier/customer ESG data collection systems will face a scramble when the mandate returns — likely within 2-3 years.
- Not mapping BRSR to the parent company's global ESG framework. A foreign-invested Indian listed company reporting under both BRSR and EU CSRD (or GRI) often maintains two separate ESG data silos. This is wasteful. The 9 NGRBC principles map closely to GRI Universal Standards. Build one integrated ESG data system and generate multiple reports from it.
Practical Example
GreenWave Technologies Ltd is an Indian listed company (ranked 320th by market capitalization) with 40% foreign institutional ownership. Its parent, GreenWave Holdings BV (Netherlands), is subject to the EU's Corporate Sustainability Reporting Directive (CSRD). Here is GreenWave Technologies' BRSR compliance timeline:
FY 2024-25 Obligations:
- File full BRSR (140 indicators) as part of the annual report
- Obtain reasonable assurance on BRSR Core KPIs (top 250 company threshold)
- Value chain disclosure on comply-or-explain basis for suppliers/customers contributing 2%+ of purchases/sales
- Cost of BRSR assurance: INR 15-25 lakh (paid to an independent assurance provider)
Key Metrics Reported:
- Scope 1 GHG emissions: 12,400 tCO2e (from own operations — fuel, process emissions)
- Scope 2 GHG emissions: 8,600 tCO2e (from purchased electricity)
- Energy consumption intensity: 0.42 GJ per INR lakh of revenue
- Water withdrawal: 2.8 million kiloliters (65% from municipal supply, 35% groundwater)
- Gender diversity: 28% women in workforce, 15% in senior management
- Median remuneration ratio (male:female): 1.08:1
- Training hours per employee: 32 hours (FY 2024-25)
- Lost Time Injury Frequency Rate (LTIFR): 0.6 per million person-hours
GreenWave's Dutch parent uses the BRSR data as a direct input for its CSRD submission, mapping BRSR Principle 6 indicators (environment) to ESRS E1 (Climate) and E3 (Water). This eliminates duplicate data collection and ensures consistency across jurisdictions. The foreign institutional investors review the BRSR Core assurance report alongside the financial audit report to assess ESG risk exposure before the annual general meeting.
Key Takeaways
- BRSR is India's mandatory ESG disclosure framework, applicable to the top 1,000 listed companies by market capitalization since FY 2022-23, structured around 9 NGRBC principles with 140 indicators (98 essential, 42 leadership).
- BRSR Core is a subset of approximately 30 KPIs requiring reasonable assurance — phased from the top 150 companies (FY 2023-24) to all top 1,000 companies by FY 2026-27.
- Value chain ESG disclosure was eased to voluntary in March 2025 but is expected to become mandatory within 2-3 years.
- Non-compliance carries penalties of INR 2,000 per day under SEBI LODR, plus stock exchange sanctions and potential SEBI enforcement up to INR 1 crore.
- BRSR aligns with GRI, TCFD, and UN SDGs — companies reporting under global frameworks can map existing data to BRSR indicators.
- Foreign-invested Indian listed companies should build integrated ESG data systems that serve both BRSR and parent company reporting requirements (CSRD, GRI, ISSB).
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