ESG Reporting is evolving at a rapid pace globally and while there are established Frameworks that have been developed and have a wide adoption and global recognition, regulators in various countries are also introducing regional mandates to fight climate change and meet the UN Sustainable Development Goals (UN SDGs), and this is no different in India.
SEBI introduced the Business Responsibility and Sustainability Report (BRSR) in 2021 which is based on the nine principles of the National Guidelines for Responsible Business Conduct (NGRBC). This is a transition from the previous Business Responsibility Report (BRR) guidelines that were introduced in 2009 by the Ministry of Corporate Affairs (MCA).
Under the BRSR mandate, India’s top 1,000 listed companies by market capitalization are required to publicly disclose their sustainability performance annually in the prescribed format of the BRSR. .
Companies reporting on the BRSR must familiarize themselves with the following nine principles of the NGRBC:
Based on these 9 principles, the BRSR reporting template has 3 sections:
General Disclosures
Management and Process Disclosures
Principle-wise Performance Disclosures
Section C has a further break-up of Essential Indicators – those that all companies must report on, and Leadership Indicators – those non-mandatory indicators that the company may decide to report on to demonstrate leadership. The BRSR currently has 140 questions including 98 essential indicators (mandatory) and 42 leadership indicators (voluntary).
After checking applicability, companies that must comply with BRSR should develop a strategy including a project plan to ensure compliance and timelines are met. Using specialist consultants and digital tools can help streamline this process. The following considerations can help companies navigate through the complexities of reporting to multiple ESG frameworks including BRSR:
Companies should take a conscious decision on whether they want to produce a BRSR report in-house versus considering an outsourced model by engaging third party consultants or technology providers. There are pros and cons to both models and with the BRSR being a regulatory requirement, companies need to carefully analyze their in-house skillsets to maintain compliance around this or use technology platforms or a managed service to help with the reporting requirements.
While BRSR is an annual report, data should be collected and maintained on a regular basis, and this requires constant monitoring and liaising between different departments. Companies should establish a system for periodic reviews and updates to ensure continuous improvement.
Assurance and verification are critical for ensuring the credibility of BRSR reports. External audits by third-party organizations can provide verification, enhancing the reliability of the reported data and boosting stakeholder confidence.
Most ESG frameworks today have significant interoperability between them and companies can benefit from this. Most of the questions are common across all frameworks and working on framework mapping can increase efficiencies and overall productivity in ESG and BRSR Reporting. GRI and BRSR have released a new interoperability document so companies that respond to one of the frameworks will automatically save time while responding to the other but this does require a certain level of expertise which consulting firms or Managed Service Providers (MSPs) can offer.
India’s Business Responsibility and Sustainability Report (BRSR) framework is continuously evolving, with several key updates and proposed changes aimed at enhancing transparency, easing compliance, and aligning with global sustainability standards. Some of the recent updates include:
The requirements for reporting on a company’s value chain (suppliers and customers) has been deferred by one financial year (now applicable from FY 2025-26, with assessment/assurance from FY 2026-27). Companies need to focus on value chain partners that individually contribute 2% or more to their total purchases or sales, with the option to limit disclosures to cover 75% of total purchases and sales. The reporting for the first year (FY 2024-25) is voluntary for past data.
The term “assurance” for BRSR Core disclosures has been broadened to “assessment or assurance.” This change aims to provide companies with more flexibility while maintaining the integrity of ESG reporting, as these assessments will be based on standards developed by an Industry Standards Forum (ISF) in consultation with SEBI.
A new leadership indicator has been added under Principle 6 (environmental responsibility) to report on Green Credits generated or procured by the listed entity and its top 10 value chain partners. This incentivizes participation in India’s Green Credit Programme.
SEBI, through the Industry Standards Forum (ISF), has released specific industry standards for reporting BRSR Core data. These standards aim to standardize and simplify reporting, making it easier for investors to compare company performance.
For the first year of reporting ESG disclosures for the value chain (FY 2025-26), the disclosure of previous year’s comparative data is voluntary.
The approach for value chain ESG disclosures has shifted from a “comply or explain” basis to a voluntary one.
To maintain good BRSR Reporting Standards, Companies need to:
Each organization will have to take a slightly different approach to their BRSR Reporting process as data management varies across companies and there is no defined set of procedures to follow.
For companies that are still fresh in their sustainability journey, it is advisable to seek external consulting support to avoid any compliance issues with the report. Working with consultants that have produced BRSR reports will be able to guide companies in their approach.
For more seasoned reporters, it is more about the accuracy and validation of data through third-party assurance as the reports need to be published and made available on various public domains. Digitizing the data collection and reporting process can make this seamless.
Sustainext provides specialized support in BRSR Reporting. Our team of professionals can support you throughout the entire process from BRSR training to adoption, reporting, and assurance support.
As a Global Service Provider, we work with Clients from various sectors using a combination of consulting and technology, we can provide clients with a Managed Service that is cost effective, improves efficiencies and accuracies, and reduces turnaround times leading to greater client satisfaction.
