SEBI's BRSR Framework — What Is Required
SEBI introduced the Business Responsibility and Sustainability Report (BRSR) as a replacement for the Business Responsibility Report (BRR) in May 2021. The BRSR is now mandatory for the top 1,000 listed companies by market capitalisation from Financial Year 2022-23. For all other listed companies, BRSR is voluntary but strongly encouraged.
From FY 2023-24, SEBI introduced BRSR Core — a subset of high-priority ESG key performance indicators (KPIs) requiring third-party assurance for the top 150 listed companies. This makes ESG data as independently verifiable as audited financial statements for India's largest corporations.
The BRSR is structured around India's National Guidelines for Responsible Business Conduct (NGRBC), which outline 9 principles covering responsible business practices across environmental, social, and governance dimensions. The report is filed as part of the Annual Report and submitted to SEBI.
The 9 NGRBC Principles Covered in BRSR
- Principle 1: Businesses should conduct and govern themselves with integrity, and in a manner that is ethical, transparent, and accountable.
- Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe.
- Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value chains.
- Principle 4: Businesses should respect the interests of and be responsive to all their stakeholders.
- Principle 5: Businesses should respect and promote human rights.
- Principle 6: Businesses should respect and make efforts to protect and restore the environment.
- Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent.
- Principle 8: Businesses should promote inclusive growth and equitable development.
- Principle 9: Businesses should engage with and provide value to their consumers in a responsible manner.
What BRSR Disclosures Actually Cover
The BRSR format has three sections — General Disclosures, Management & Process Disclosures, and Principle-wise Performance Disclosures. Key quantitative disclosures include:
- Environmental: Total energy consumed (Scope 1 and 2 GHG emissions in tCO₂e), water withdrawal and consumption by source, total waste generated and disposal methods, percentage of capital and operating expenditure on environmental initiatives
- Social: Employee headcount by gender, differently-abled percentage, median wages by gender, employee turnover rate, training hours per employee, number of workplace injuries, CSR expenditure, community development projects and outcomes
- Governance: Board composition (independent directors, women directors), number of board meetings, percentage of board training on ESG, complaints on ethics/bribery/corruption and their resolution, number of anti-competitive conduct notices received
Our ESG Reporting Service
We review your existing Annual Report, any prior BRR or voluntary ESG disclosures, and your data collection processes to understand what data you already track and where gaps exist against BRSR requirements.
We work with your finance, HR, operations, and legal teams to design a data collection framework that captures the quantitative metrics required for BRSR. This includes defining measurement boundaries, emission factors for GHG calculations, and data validation protocols.
We draft the full BRSR in SEBI's required format, incorporating your quantitative data with appropriate narrative disclosures explaining your policies and processes under each of the 9 NGRBC principles.
We review the draft BRSR for legal accuracy — ensuring disclosures on compliance, litigation, and regulatory matters are consistent with your actual legal position and do not inadvertently create liability.
For companies requiring BRSR Core assurance, we coordinate with your third-party assurance provider and advise on how to present disclosures in a manner that facilitates smooth verification.
ESG Reporting for Unlisted Companies
While BRSR is mandatory only for listed companies, unlisted businesses are increasingly required to provide ESG data by institutional investors, private equity funds, large enterprise customers (as part of supply chain due diligence), and export markets. The frameworks most commonly used are:
- GRI (Global Reporting Initiative): The most widely used voluntary ESG reporting framework globally, used across all sectors and company sizes.
- TCFD (Task Force on Climate-related Financial Disclosures): Focused specifically on climate risk disclosures, increasingly required by lenders and investors.
- UN Sustainable Development Goals (SDGs): Companies map their activities and community investments against the 17 UN SDGs as a reporting framework.
We advise unlisted companies on which framework is most appropriate for their situation and stakeholder base, and assist with drafting voluntary ESG disclosures accordingly.
Frequently Asked Questions
No. BRSR as mandated by SEBI applies only to listed companies — specifically, the top 1,000 by market capitalisation. For all other listed companies, it is voluntary. For unlisted private companies, BRSR is voluntary, though increasingly expected by investors and large enterprise customers. That said, we are seeing more private equity funds and sophisticated angel investors require ESG disclosures from portfolio companies as part of investment conditions and annual reporting obligations.
CSR (Corporate Social Responsibility) reporting under Section 135 of the Companies Act 2013 covers community development expenditure — the 2% of net profits that qualifying companies must spend on social activities. BRSR is a much broader sustainability disclosure covering your organisation's environmental impact, governance practices, employee welfare, supply chain practices, and community engagement across all 9 NGRBC principles. A company can have excellent CSR spending and poor BRSR performance (or vice versa). They are separate requirements that complement each other.
The National Guidelines for Responsible Business Conduct (NGRBC) are India's framework for ESG expectations from businesses, published by the Ministry of Corporate Affairs. They define 9 principles covering ethics, sustainable products, employee welfare, stakeholder responsiveness, human rights, environmental protection, responsible advocacy, inclusive growth, and customer responsibility. BRSR is structured around these 9 principles — understanding them is essential to preparing a meaningful BRSR rather than a box-ticking exercise.
Need Help With Your BRSR or ESG Report?
Whether you are preparing your first BRSR or upgrading to BRSR Core assurance, we can help. Contact us for a scoped advisory proposal.