SEBI's Business Responsibility and Sustainability Reporting (BRSR) framework has become the cornerstone of ESG disclosure for Indian listed companies. From FY 2022-23, the top 1000 listed companies by market capitalisation were required to file BRSR as part of their Annual Reports. From FY 2023-24, BRSR Core with assured reporting became mandatory for the top 150 companies.
📌 Key deadline: Top 1000 companies must file full BRSR. Top 150 must additionally include BRSR Core with reasonable assurance from an independent third party.
Structure of the BRSR Framework
BRSR is structured around three main sections:
Section A: General Disclosures
Company profile, products and services, number of employees and workers, CSR details, and transparency and disclosures compliances.
Section B: Management and Process Disclosures
Policies and processes aligned with the 9 Principles of the National Guidelines on Responsible Business Conduct (NGRBC) — covering ethics, products, employee wellbeing, stakeholder engagement, human rights, environment, policy advocacy, inclusive growth, and customer value.
Section C: Principle-wise Performance Disclosures
Quantitative and qualitative disclosures on each of the 9 NGRBC principles, including essential and leadership indicators.
BRSR Core: The 9 Assured KPIs
For the top 150 companies, BRSR Core requires third-party assurance on 9 key performance indicators:
- GHG emissions (Scope 1 and 2)
- Energy consumption and intensity
- Water withdrawal and consumption
- Waste generation and disposal
- Gender pay ratio
- Percentage of differently-abled employees
- Complaints related to sexual harassment
- Turnover rate of permanent employees
- Spending on CSR activities
Common Compliance Gaps
Based on BEC's experience supporting companies across sectors, the most common BRSR compliance gaps include:
- Lack of Scope 2 (market-based) emissions data
- Inconsistent water withdrawal measurement across plant locations
- Absence of supply chain ESG assessment processes
- Missing product lifecycle data for extended producer responsibility disclosures
- Inadequate documentation of biodiversity impact near operations
💡 BEC Tip: Start data collection at least 6 months before the financial year end. Most companies struggle not with the reporting format but with the underlying data gaps across facilities.
Conclusion
BRSR is evolving rapidly towards greater rigour and assurance requirements. Companies that build robust ESG data management systems now will be well-positioned as SEBI extends mandatory BRSR Core to the full top 1000 companies in coming years.
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