A listed manufacturing company may operate 5 production plants, purchase electricity from multiple distribution companies, engage hundreds of contract workers and appoint more than 20 vendors for waste collection and recycling. At the end of the financial year, each department submits its sustainability data in a different format.
The finance department reports revenue and procurement numbers. The human resources team maintains workforce and wage data. Plant teams monitor water, energy, waste and safety. The sustainability department combines all these records into the Business Responsibility and Sustainability Report.
The difficulty begins when the reported numbers are selected for independent assessment or assurance.
Electricity consumption may not reconcile with invoices. Waste quantities may not match manifests and recycling certificates. Scope 1 emissions may exclude diesel used in rented equipment. Contractor working hours may be missing from the Lost Time Injury Frequency Rate calculation.
These gaps can delay annual report finalisation, create qualifications in the assessment report and require explanations from senior management.
A professional BRSR Core Assurance Consultant in India helps the company identify such issues before the independent assessment begins. The consultant supports reporting-boundary definition, data validation, calculation review, evidence management, internal control testing and coordination with the independent assessment or assurance provider.
Business Responsibility and Sustainability Reporting, commonly known as BRSR, is India’s principal ESG disclosure framework for listed companies.
The top 1,000 listed entities by market capitalisation are required to include BRSR disclosures in their annual reports. The reporting framework covers environmental performance, employee welfare, human rights, governance, customer responsibility, supply-chain practices and business ethics.
BRSR Core is a focused part of the complete BRSR framework. It includes selected quantitative indicators considered important for comparability and independent verification.
Instead of relying mainly on narrative statements, BRSR Core requires companies to report measurable information such as:
BRSR Core includes 9 ESG attributes. Each attribute contains specific indicators that must be supported by documentary evidence, calculation sheets and an identifiable reporting methodology.
BRSR Core is not a multi-year certification, CPCB registration or environmental authorization. It is an annual reporting requirement connected to a company’s financial year and annual report.
The BRSR Core assessment or assurance requirement has been introduced in phases.
| Financial Year | Listed Entities Covered | Requirement |
|---|---|---|
| FY 2023-24 | Top 150 listed entities | Mandatory assessment or assurance |
| FY 2024-25 | Top 250 listed entities | Mandatory assessment or assurance |
| FY 2025-26 | Top 500 listed entities | Mandatory assessment or assurance |
| FY 2026-27 | Top 1,000 listed entities | Mandatory assessment or assurance |
For FY 2025-26, companies ranked within the top 500 listed entities must prepare their BRSR Core information for independent assessment or assurance.
From FY 2026-27, the requirement will extend to all top 1,000 listed entities covered by the wider BRSR framework.
This expansion is particularly important for mid-cap companies that may have previously submitted BRSR disclosures without establishing formal ESG data controls.
A company may have published energy, emissions and waste data for several years. However, previous publication does not automatically mean that the information is assessment-ready.
The company must still confirm:
BRSR Core assessment requires more than completing an Excel sheet or transferring numbers into the annual report.
Every material figure should have a clear evidence trail. The assessor may test invoices, registers, purchase records, payroll files, meter readings, waste manifests, safety reports and management approvals.
For example, if a company reports 18,750 megawatt-hours of electricity consumption, it should be able to demonstrate how that number was calculated.
The supporting records may include:
If the consolidated number does not match the underlying records, the company may need to revise the disclosure or explain the difference.
The same principle applies to water, waste, workforce, emissions, procurement and financial indicators.
Early preparation reduces the risk of late corrections. It also allows management to improve internal controls instead of merely responding to assessment queries after the financial year has closed.
| Requirement | Main Expectation | Applicable To | Timing | Main Risk |
|---|---|---|---|---|
| BRSR disclosure | Include BRSR in the annual report | Top 1,000 listed entities | Every applicable financial year | Incomplete annual report |
| BRSR Core assessment or assurance | Independent verification of Core KPIs | Covered entities under phased applicability | Before annual report finalisation | Qualified conclusion |
| Industry reporting standards | Follow prescribed calculation and disclosure methods | Listed entities covered by BRSR Core | During data preparation | Methodology inconsistency |
| Provider independence | Appoint an independent and competent provider | Listed entity and assessment provider | Before engagement | Conflict of interest |
| Value-chain disclosure | Voluntary reporting under revised framework | Top 250 listed entities | From FY 2025-26 | Supplier data gaps |
The reporting methodology should remain consistent from one year to the next. When a company changes the reporting boundary, estimation method or calculation approach, the change should be documented and appropriately disclosed.
The greenhouse gas attribute includes Scope 1 and Scope 2 emissions.
Scope 1 emissions generally arise from sources owned or controlled by the company. These may include fuel used in boilers, furnaces, company vehicles, diesel generators and manufacturing processes.
Scope 2 emissions generally arise from purchased electricity, steam, heating or cooling.
The company must also disclose emission intensity using the prescribed denominator and may need to provide an additional sector-specific intensity measure.
A manufacturing company may collect data from 6 plants and more than 40 emission sources. Even a small exclusion can affect the total reported carbon footprint.
Typical evidence includes:
Water reporting includes total withdrawal, total consumption, discharge quantities and water intensity.
A company should not assume that total water purchased is equal to total water consumed. Water may be recycled, discharged, stored, evaporated or incorporated into products.
Where direct meters are unavailable, the company may use a documented calculation based on inlet, outlet and process records. The method must be reasonable, consistently applied and supported by available evidence.
Water data may come from:
A common problem is that plant teams report water in kilolitres while purchase invoices record tanker quantities in litres or cubic metres. Unit conversion should therefore be checked before consolidation.
The energy attribute includes total energy consumption, renewable-energy use and energy intensity.
Energy data may include electricity, natural gas, coal, biomass, diesel, steam and other fuels.
Companies should avoid double counting. For example, if fuel is used to generate electricity internally, the company should follow the prescribed method rather than treating both the fuel and generated electricity as unrelated energy inputs.
The renewable-energy percentage must also be supported by credible records such as:
The waste attribute covers several categories, including plastic waste, e-waste, battery waste, biomedical waste, hazardous waste, construction waste and other non-hazardous waste.
The company must report how much waste was generated and how much was recycled, reused, recovered or disposed of.
A vendor invoice alone may not establish that the waste was finally recycled. The evidence trail should connect the waste generated at the facility with the authorized transporter and final waste processor.
A complete waste file may include:
If a company reports 4,500 tonnes of recycled waste but has certificates for only 4,050 tonnes, the unsupported 450 tonnes may need clarification or correction.
This attribute includes employee and worker wellbeing expenditure, fatalities, permanent disabilities and Lost Time Injury Frequency Rate.
LTIFR is highly sensitive to the number of working hours used in the calculation.
A company may accurately record 3 lost-time injuries but still calculate the rate incorrectly if contract-worker hours are excluded.
The working-hour population should align with the employee and worker categories included in the disclosure.
Supporting records generally include:
Gender-related indicators include wages paid to women, sexual-harassment complaints and the number of complaints upheld.
The wage calculation should match the relevant employee and worker population. Payroll records, contractor records and disclosed headcount should be reconciled.
POSH information should be verified against the records maintained by the Internal Committee while protecting confidential personal information.
A company should also ensure that complaint numbers used in BRSR are consistent with the disclosures made in its board report or other statutory documents.
This attribute includes procurement from MSMEs and small producers, domestic sourcing and wages paid to employees or workers in smaller towns.
MSME classification should be supported by valid vendor records rather than assumptions based on vendor size.
Procurement teams may need to review hundreds or thousands of vendor masters to confirm:
A company with annual procurement of Rs. 800 crore may need to classify each applicable vendor before calculating the percentage purchased from MSMEs.
This attribute includes customer-data breaches and accounts payable days.
Cybersecurity information should reconcile with the incident register, information-security records, legal notifications and customer-impact assessments.
Accounts payable days should be calculated using financial information that agrees with the audited financial statements.
A difference between the finance team’s calculation and the number reported in BRSR Core may create unnecessary assessment queries.
The openness of business attribute includes concentration of purchases and sales through trading houses, dealers and distributors.
It also covers related-party transactions, loans, advances and investments.
These numbers usually come from finance, legal and secretarial records. They should therefore agree with audited financial statements and related-party disclosures.
Because these indicators are connected to financial records, inconsistencies are easier for an independent assessor to identify.
The current framework allows covered companies to obtain either an assessment or assurance of BRSR Core information.
An assessment is performed according to the applicable industry standards developed for BRSR Core.
An assurance engagement may use recognised assurance standards depending on the provider, engagement scope and nature of the reported information.
The company should select the approach after considering:
The cheaper engagement is not always the more efficient option. A company with weak data controls may spend more management time responding to queries, reconstructing evidence and correcting calculations.
The independent assessment or assurance provider should have suitable sustainability knowledge, technical capability and sector understanding.
The provider should also remain independent from the company.
This creates an important distinction between readiness consulting and final independent verification.
A consultant may help the company:
However, the same consultant should not make management decisions and then independently verify those decisions where doing so creates a conflict of interest.
Companies should establish separate scopes for:
This separation protects the credibility of the final conclusion.
The exact timeline depends on the company’s size and number of operating locations.
| Step | Typical Timeline | Main Activity | Key Risk |
|---|---|---|---|
| Applicability assessment | 1 week | Confirm ranking and reporting scope | Wrong entity coverage |
| KPI mapping | 1-2 weeks | Assign KPI owners and data sources | Missing responsibilities |
| Data collection | 3-6 weeks | Collect plant and department records | Incomplete evidence |
| Calculation review | 2-4 weeks | Reconcile and validate calculations | Formula errors |
| Readiness assessment | 2-3 weeks | Test evidence and controls | Late gap identification |
| Corrective action | 2-4 weeks | Resolve missing records and errors | Unclosed observations |
| Independent assessment | 4-10 weeks | External testing and reporting | Annual report delay |
A multi-location company should ideally begin readiness work 4 to 6 months before annual report finalisation.
There is no single standard document list for every company. The required evidence depends on the sector, reporting boundary and disclosed KPIs.
A structured evidence room should normally include:
Every file should be tagged by location, KPI, reporting year, document owner and version.
Value-chain ESG disclosure has been made voluntary for the top 250 listed entities from FY 2025-26.
Related assessment or assurance is voluntary from FY 2026-27.
The revised value-chain approach focuses on significant upstream and downstream partners. An individual partner may be included where it accounts for at least 2% of purchases or sales by value.
The company may limit the reporting population to partners covering 75% of total purchases or sales.
For example, a listed manufacturer with Rs. 1,000 crore in annual purchases may initially identify vendors contributing at least Rs. 20 crore each. It may then continue adding relevant vendors until the selected population covers 75% of total purchase value.
This process requires:
Even where reporting is voluntary, large listed companies may request ESG information from suppliers as part of procurement, vendor assessment or financing requirements.
BRSR Core non-compliance may create regulatory, operational and reputational consequences.
Possible risks include:
The most common problem is not the complete absence of information. It is reporting a number that cannot be fully supported.
A listed auto-component company operating 5 plants was preparing for its first mandatory BRSR Core assessment.
The company reported:
During the readiness review, three important gaps were found.
First, electricity invoices supported only 98.4% of the reported purchased electricity.
Second, 4 months of water-discharge data at one plant had been estimated without an approved calculation methodology.
Third, part of the reported recycled waste had been sent to an aggregator, but final recycling certificates were unavailable.
The company implemented an 8-week corrective programme.
Plant teams reconciled energy invoices with the general ledger. The water-estimation methodology was documented and approved. Missing waste certificates were obtained from final processors. Monthly KPI certification was introduced for every plant.
As a result, the independent assessment team received a structured evidence index instead of disconnected spreadsheets and emails.
The case study demonstrates that BRSR Core readiness is primarily an internal control exercise. It should not be treated as a last-minute annual report activity.
A BRSR Core Assurance Consultant in India supports the company before and during the independent assessment process.
The advisory scope may include:
For companies operating multiple factories, the consultant can also create standard monthly data templates and approval workflows.
This reduces dependence on year-end manual consolidation and improves the reliability of future disclosures.
BRSR Core is changing sustainability reporting in India from broad narrative disclosure to independently verifiable ESG data.
For FY 2025-26, assessment or assurance applies to the top 500 listed entities. From FY 2026-27, the requirement will extend to the top 1,000 listed entities.
Companies should not wait until annual report preparation begins.
Energy invoices, waste certificates, safety records, payroll information and procurement classifications may take several weeks to collect and reconcile. Missing historical evidence may be difficult to recreate after the financial year has ended.
A qualified BRSR Core Assurance Consultant in India can help management establish a structured reporting process, identify evidence gaps, improve calculation controls and prepare the company for independent assessment.
The real objective is not only to complete the assessment. It is to create ESG information that can be trusted by the board, investors, lenders, customers and business teams.
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