A listed manufacturing company may close its financial audit on time, but its annual report can still get delayed because ESG data is not ready. This happens when electricity bills are not reconciled, waste records are incomplete, EPR certificates are not mapped, water withdrawal data is scattered across plants, or value chain partners have not provided their sustainability information.
This is where the difference between BRSR Core vs BRSR becomes important. BRSR is the complete ESG disclosure format applicable to the top 1000 listed companies in India. BRSR Core is a selected set of Key Performance Indicators within BRSR that requires assessment or assurance under SEBI’s phased framework.
For FY 2025-26, BRSR Core assessment or assurance applies to the top 500 listed entities by market capitalization. From FY 2026-27, it expands to the top 1000 listed entities. This means many companies that earlier treated ESG reporting as a disclosure exercise must now treat it as a data-control and evidence-based compliance process.
BRSR Core vs BRSR is not only a reporting comparison. It affects board governance, investor communication, annual report finalization, value chain engagement, internal audit, and environmental compliance records.
BRSR stands for Business Responsibility and Sustainability Report. It is the ESG disclosure framework prescribed by SEBI for applicable listed entities in India. It replaced the earlier Business Responsibility Report and became mandatory for the top 1000 listed companies by market capitalization from FY 2022-23.
BRSR is structured around 9 principles of the National Guidelines on Responsible Business Conduct. These principles cover ethics, product responsibility, employee well-being, stakeholder engagement, human rights, environment, policy advocacy, inclusive growth, and customer value.
The purpose of BRSR is to make sustainability reporting more measurable. Earlier, many ESG statements were broad and narrative-driven. BRSR requires companies to disclose specific numbers, such as energy consumption, water consumption, waste generation, greenhouse gas emissions, employee turnover, gender diversity, safety incidents, complaints, and social impact data.
For manufacturers, importers, recyclers, plant operators, chemical companies, electronics companies, plastic packaging users, battery companies, and large suppliers, BRSR is closely connected with environmental compliance. Data disclosed under BRSR often comes from CPCB, SPCB, EPR, Consent to Operate, hazardous waste, plastic waste, e-waste, battery waste, and pollution control records.
Key numbers to remember:
BRSR Core is a focused subset of BRSR. It contains selected KPIs that SEBI considers important for verification, comparability, and investor confidence. These KPIs are grouped under 9 ESG attributes.
The major difference is that BRSR is a wider disclosure framework, while BRSR Core is the evidence-ready portion of that framework. A company may disclose many sustainability points in the full BRSR, but BRSR Core indicators need stronger controls because they are subject to assessment or assurance.
BRSR Core was introduced to improve the reliability of ESG data. It helps investors understand whether reported ESG numbers are supported by proper records, calculation methods, internal controls, and evidence trails.
For example, if a company reports 25,000 tonnes of total waste generated in BRSR, the BRSR Core readiness process should be able to support that number with plant-wise waste logs, weighbridge slips, hazardous waste manifests, recycler invoices, disposal certificates, and statutory returns.
In practical terms, BRSR Core requires a company to answer 5 questions for every KPI:
What is being reported?
Why is it material?
How was it calculated?
What is the reporting period?
What evidence supports the number?
| Point | BRSR | BRSR Core |
|---|---|---|
| Meaning | Full Business Responsibility and Sustainability Report | Selected KPI subset inside BRSR |
| Applicability | Top 1000 listed companies | Phased rollout from top 150 to top 1000 listed companies |
| Main purpose | ESG disclosure | Assessment or assurance-ready ESG data |
| Framework base | 9 NGRBC principles | 9 ESG attributes |
| Reporting style | Narrative and quantitative | Mostly quantitative and evidence-backed |
| Verification | Disclosure-focused | Assessment or assurance-focused |
| Business risk | Incomplete annual report disclosure | Weak evidence, assessment observations, assurance gaps |
| Data ownership | ESG, HR, EHS, finance, legal, procurement | ESG, internal audit, EHS, finance, HR, board committees |
| Compliance impact | Annual report and stakeholder transparency | Investor confidence, governance quality, data credibility |
BRSR is wider. BRSR Core is deeper. BRSR explains the company’s ESG position, while BRSR Core checks whether selected ESG numbers are reliable.
A company can complete a BRSR draft in a few weeks if the data is available. However, BRSR Core readiness may require 3 to 6 months because data owners, evidence files, calculation methods, internal review, and assurance readiness must be built properly.
This is why companies should not wait until the annual report deadline. BRSR Core should be managed through quarterly internal review, especially for energy, water, waste, emissions, safety, diversity, and supplier-related data.
BRSR applies to the top 1000 listed companies by market capitalization. BRSR Core follows a phased applicability timeline. This phased rollout is important because many companies that were previously only filing BRSR now need to prepare for assessment or assurance.
For FY 2025-26, the requirement becomes more significant because BRSR Core assessment or assurance applies to the top 500 listed entities. From FY 2026-27, the same requirement expands to the top 1000 listed entities.
| Financial Year | BRSR Applicability | BRSR Core Applicability | Practical Impact |
|---|---|---|---|
| FY 2022-23 | Top 1000 listed entities | Not applicable under initial BRSR Core glide path | Full BRSR became mandatory |
| FY 2023-24 | Top 1000 listed entities | Top 150 listed entities | First BRSR Core verification phase |
| FY 2024-25 | Top 1000 listed entities | Top 250 listed entities | Wider assessment or assurance readiness |
| FY 2025-26 | Top 1000 listed entities | Top 500 listed entities | Major expansion to larger mid-cap entities |
| FY 2026-27 | Top 1000 listed entities | Top 1000 listed entities | Full rollout of BRSR Core |
For a listed company, the applicability check should be done at the start of the financial year. The company should confirm whether it falls under the top 150, top 250, top 500, or top 1000 category based on market capitalization.
The risk of a wrong applicability check is high. If a company assumes BRSR Core is not applicable and later finds that it falls within the covered category, it may not have enough time to prepare evidence files, engage assessors, reconcile data, or complete board-level review.
| Regulation or Framework | Requirement | Timeline | Applicable To | Risk |
|---|---|---|---|---|
| SEBI BRSR framework | BRSR disclosure in annual report | Mandatory from FY 2022-23 | Top 1000 listed entities | Annual report non-compliance |
| BRSR Core framework | Selected ESG KPIs for assessment or assurance | FY 2023-24 to FY 2026-27 glide path | Top listed entities by market capitalization | Weak evidence or assurance gaps |
| SEBI LODR Regulation 34 | Annual report disclosure requirement | Annual reporting cycle | Listed entities | Stock exchange query or disclosure risk |
| Value chain ESG disclosure | ESG data from major upstream and downstream partners | Voluntary for top 250 from FY 2025-26 | Top 250 listed entities and their suppliers | Supplier data gaps |
| Environmental laws | Compliance records for waste, water, emissions, consents, and EPR | Ongoing | Manufacturers, importers, recyclers, plant operators | CPCB, SPCB, or EPA action |
This regulatory structure shows that BRSR is not a standalone ESG document. It is linked with operational compliance. If a company reports waste recovery, renewable energy, emissions reduction, water recycling, or circular economy performance, it must have reliable records to support those claims.
For example, a battery importer may need to align BRSR data with Battery Waste Management Rules, EPR registration, sales data, battery categories, EPR certificates, and annual returns. Similarly, a plastic packaging brand owner may need to align BRSR data with plastic EPR registration, category-wise packaging data, recycler certificates, annual returns, and CPCB portal filings.
| Step | Owner | Suggested Timeline | Documents Required | Risk if Delayed |
|---|---|---|---|---|
| 1. Applicability check | Company secretary and compliance team | April to May | Market capitalization records, listed entity details | Wrong reporting obligation |
| 2. KPI mapping | ESG team and internal audit | April to June | BRSR format, BRSR Core KPIs, prior year BRSR | Missing data points |
| 3. Department-wise data collection | HR, EHS, finance, legal, procurement | Monthly or quarterly | Energy bills, water records, waste records, HR MIS | Inconsistent ESG data |
| 4. Evidence reconciliation | ESG, EHS, finance, plant heads | Quarterly | Invoices, meters, returns, certificates, consents | Assessment observations |
| 5. Value chain data collection | Procurement and sustainability team | Q2 to Q4 | Supplier ESG questionnaire, purchase and sales data | Supplier non-response |
| 6. Assessment or assurance | External assessor or assurance provider | Before annual report finalization | KPI evidence file, methodology, management representation | Delay in annual report |
| 7. Board review and filing | Board, audit committee, company secretary | Annual report cycle | Final BRSR, BRSR Core, assessment or assurance report | Governance and exchange risk |
A strong company should not collect BRSR Core data once a year. It should create quarterly ESG data packs. These packs should include plant-wise energy, water, waste, emissions, safety, HR, procurement, and compliance data.
For multi-location companies, a central ESG team should reconcile plant-level data before the annual report cycle. This is important because one wrong unit conversion can distort the final number. For example, one plant may report water in kilolitres, another in cubic metres, and another in litres. Without conversion control, the final BRSR number may become inaccurate.
BRSR Core generally requires stronger data evidence because the numbers may be checked by a third party. The evidence should be traceable, dated, approved, and linked to the reporting period.
For environmental KPIs, companies should maintain meter readings, bills, statutory returns, sampling reports, recycler invoices, EPR certificates, and plant-wise registers. For social KPIs, companies should maintain payroll records, safety reports, training attendance, grievance registers, diversity data, and contractor workforce records.
For governance KPIs, companies should maintain board policies, complaints records, anti-corruption training data, supplier codes, whistleblower records, and committee minutes where applicable.
Important evidence examples:
Value chain disclosure is one of the most important changes for FY 2025-26 and FY 2026-27 planning. It affects not only listed companies but also their suppliers, vendors, contractors, recyclers, transporters, and service providers.
Under the revised framework, value chain coverage is linked with upstream and downstream partners that individually comprise 2 percent or more of the listed entity’s purchases or sales by value. However, the listed entity may limit disclosure to cover 75 percent of purchases and sales by value respectively.
This means even an unlisted MSME can be asked to provide ESG data if it is a major supplier to a listed company. A packaging supplier, component manufacturer, chemical supplier, recycler, logistics vendor, or contract manufacturer may suddenly receive ESG questionnaires from listed customers.
For top 250 listed entities, value chain ESG disclosures are voluntary from FY 2025-26. Assessment or assurance of value chain disclosures is voluntary from FY 2026-27.
Key numbers:
For many Indian companies, the biggest BRSR Core risk is environmental data mismatch. ESG teams may report sustainability numbers, while plant teams may maintain statutory compliance records separately. If the two records do not match, the company may face questions during assessment or assurance.
For example, if a company reports 10,000 tonnes of waste recycled under BRSR, but its hazardous waste annual return shows a different number, the assessor may ask for reconciliation. If a plastic packaging company reports circular economy performance but does not have matching EPR certificates, the claim becomes weak.
Similarly, if a battery importer reports responsible end-of-life management, it should be able to show EPR registration, battery category data, sales data, EPR certificates, and annual or quarterly return records. If an e-waste producer reports recycling performance, it should match CPCB portal data and recycler certificates.
Important compliance records include:
The biggest risk in BRSR Core reporting is not only wrong data. It is unsupported data. A company may have sustainability initiatives, but if the numbers are not backed by documents, the assessment or assurance process can raise observations.
BRSR is part of the annual report. Therefore, gaps in BRSR or BRSR Core can become governance issues. Investors, lenders, stock exchanges, customers, and rating agencies may use this data to evaluate the company’s ESG maturity.
There is also an environmental compliance risk. If a company discloses waste, water, emissions, recycling, or EPR information that does not match CPCB or SPCB records, the issue may move beyond ESG reporting into regulatory compliance.
Major risk areas include:
Under environmental laws, non-compliance can lead to serious consequences. For example, failure to comply with certain waste management rules can attract penalty under Section 15 of the Environment Protection Act, 1986. This makes environmental data accuracy important for both ESG reporting and legal compliance.
A listed manufacturer has 5 plants across 3 states. The company falls under the top 500 listed entities for FY 2025-26. Its ESG team starts preparing BRSR Core data in February 2026, only 1 month before annual report drafting begins.
The team finds that 2 plants have energy data in monthly bills, 1 plant has diesel records only in purchase invoices, and 2 plants have not maintained proper water recycling records. Waste disposal data is also inconsistent because some vendors issued invoices in kilograms and others in tonnes.
The company now needs 45 to 60 days only for reconciliation. This creates pressure on the annual report team and increases the risk of assessment observations.
Better approach: The company should have created quarterly ESG data packs from Q1 itself.
An importer of electronic goods reports responsible waste management in BRSR. However, its EPR registration data, IEC records, GST sales data, product category data, and EPR certificate procurement are not reconciled.
During BRSR Core readiness review, the ESG team identifies that the quantity placed in the market is different from the quantity used for EPR obligation calculation. This creates a data gap that can affect both ESG reporting and CPCB portal compliance.
Better approach: Importers should reconcile GST, IEC, product sales, EPR portal filings, and ESG disclosures at least quarterly.
A packaging supplier is not listed on any stock exchange. However, it supplies packaging material to a top 250 listed FMCG company. Its supply value crosses the 2 percent threshold of the listed company’s purchase value.
The listed customer asks the supplier for ESG data, including energy use, renewable energy, water consumption, waste generation, employee safety, wages, and environmental approvals.
The supplier has valid business documents but does not maintain ESG data in a structured format. As a result, the supplier struggles to respond to the ESG questionnaire.
Better approach: Suppliers to listed companies should prepare basic ESG and compliance data even if BRSR is not directly applicable to them.
The first step is a BRSR Core gap assessment. This assessment should compare the company’s previous BRSR disclosure with the latest BRSR Core requirements, available evidence, data owners, calculation methods, and internal controls.
The second step is to build an ESG data register. This register should identify every KPI, department owner, data source, frequency, supporting document, reviewer, and final approver.
The third step is evidence management. Evidence should be stored in a structured folder system by financial year, plant, department, and KPI. A company with 10 plants may need more than 500 individual evidence files for one reporting year if it wants smooth assessment or assurance.
The fourth step is value chain readiness. Procurement teams should identify top suppliers and customers based on purchase and sales value. ESG questionnaires should be sent early, not at the annual report stage.
Recommended steps:
BRSR Core changes ESG from a statement-based exercise to a control-based exercise. Companies must move from “we are sustainable” to “we can prove our sustainability data.”
This is especially important because ESG data is now used by investors, banks, customers, rating agencies, procurement teams, and regulators. A weak BRSR Core process can affect investor trust, supplier ranking, sustainability ratings, and board-level confidence.
For companies in regulated sectors, BRSR Core can also improve environmental compliance. When energy, water, waste, EPR, emissions, and safety data are reviewed regularly, companies are more likely to identify compliance gaps before they become regulatory issues.
A company that builds strong BRSR Core systems can gain 3 practical advantages:
BRSR Core vs BRSR is one of the most important ESG reporting distinctions for Indian listed companies. BRSR is the complete sustainability disclosure framework. BRSR Core is the selected KPI layer that requires assessment or assurance under SEBI’s phased framework.
For FY 2025-26, BRSR Core applies to the top 500 listed entities. From FY 2026-27, it applies to the top 1000 listed entities. Companies should therefore treat BRSR Core as a year-round compliance process, not as a year-end reporting formality.
The cost of early preparation is lower than the cost of delayed data collection, annual report pressure, assessment observations, exchange queries, investor concerns, or environmental compliance gaps. Businesses that connect BRSR Core with CPCB, SPCB, EPR, waste management, energy, water, emissions, and safety records will be better positioned for India’s next stage of ESG reporting.
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