A listed manufacturing company may operate 4 factories, employ more than 2,000 people and work with hundreds of suppliers. However, when the annual BRSR reporting process begins, the sustainability team often discovers that electricity, fuel, water, waste, employee safety and supplier information are stored in different formats across multiple departments.
The finance department may report diesel purchases in rupees, while the plant team records consumption in litres. Human resources may count permanent employees but exclude contract workers. Waste records may show the quantity sent to recyclers without confirming whether the recycler held a valid authorisation during the reporting period.
These differences can create serious problems during BRSR Core assessment or assurance. Incorrect calculations, missing records or inconsistent reporting boundaries can delay the annual report, increase verification costs and expose the company to regulatory and reputational risk.
A professional BRSR Reporting Consultant in India helps companies create a structured ESG reporting system, validate numerical data, prepare supporting evidence and align the final disclosure with the latest SEBI requirements.
BRSR stands for Business Responsibility and Sustainability Report. It is the environmental, social and governance disclosure framework prescribed by the Securities and Exchange Board of India for specified listed entities.
Under Regulation 34(2)(f) of the SEBI Listing Obligations and Disclosure Requirements Regulations, BRSR is mandatory for the top 1,000 listed entities based on market capitalisation. The framework became mandatory from FY 2022-23 after an initial voluntary reporting period.
BRSR is based on the 9 principles of the National Guidelines on Responsible Business Conduct. These principles cover ethics, product responsibility, employee wellbeing, stakeholder engagement, human rights, environmental protection, public policy, inclusive growth and customer responsibility.
The BRSR format contains 3 major sections:
The official reporting format also requires the company to define whether the report covers only the listed entity on a standalone basis or includes subsidiaries and other entities on a consolidated basis. The selected boundary should remain consistent throughout the report.
Important numerical features of BRSR include:
BRSR applies primarily to the top 1,000 listed entities based on market capitalisation. A company that crosses the prescribed market-capitalisation threshold must assess its applicability carefully and begin collecting ESG data before the end of the financial year.
Unlisted companies are generally not directly required to file BRSR under Regulation 34(2)(f). However, they may still receive detailed ESG questionnaires from listed customers, lenders, investors or multinational buyers.
An unlisted auto-component supplier, packaging manufacturer, recycler or chemical producer may therefore need BRSR-aligned information even when it has no direct stock-exchange filing obligation. This usually happens when the company forms part of the upstream value chain of a listed entity.
Companies commonly requiring BRSR support include:
BRSR Core is a focused subset of the full BRSR framework. It includes measurable ESG indicators that are subject to independent assessment or assurance for specified listed entities.
The BRSR Core framework contains 9 major attributes. These attributes are designed to improve consistency, comparability and credibility in sustainability reporting.
The 9 BRSR Core attributes cover:
Unlike broad sustainability statements, BRSR Core indicators require numerical data. A company may need to disclose energy in gigajoules, water in kilolitres, greenhouse-gas emissions in tonnes of carbon dioxide equivalent, waste in metric tonnes and workplace injuries through defined safety ratios.
For example, a manufacturing company may need to calculate:
SEBI introduced a phased applicability schedule so that larger listed entities entered the BRSR Core framework first.
| Financial year | Listed entities covered |
|---|---|
| FY 2023-24 | Top 150 listed entities |
| FY 2024-25 | Top 250 listed entities |
| FY 2025-26 | Top 500 listed entities |
| FY 2026-27 | Top 1,000 listed entities |
The expansion means that companies ranked between 501 and 1,000 should prepare their BRSR Core systems during FY 2026-27 rather than waiting until the annual-report drafting stage.
SEBI subsequently permitted an assessment-or-assurance approach from FY 2024-25 onward. This change was introduced to make the verification process profession-agnostic and reduce unnecessary compliance costs while maintaining reporting credibility.
The phased schedule creates 3 immediate priorities:
| Regulation or circular | Numerical requirement | Applicable to | Main compliance risk |
|---|---|---|---|
| SEBI LODR Regulation 34(2)(f) | Top 1,000 listed entities | Applicable listed companies | Incomplete annual-report disclosure |
| BRSR Core circular dated 12 July 2023 | 9 Core ESG attributes | Companies under the phased schedule | Unsupported numerical KPIs |
| Industry Standards dated 20 December 2024 | Standardised calculation methods | BRSR Core entities | Inconsistent methodology |
| SEBI circular dated 28 March 2025 | Assessment or assurance permitted | Applicable listed entities | Incorrect provider appointment |
| SEBI LODR FAQs updated in April 2025 | 2% value-chain threshold and 75% coverage option | Value-chain reporting entities | Incorrect partner selection |
| NSE BRSR filing guidance | PDF and XBRL filed on the same day as the annual report | Listed entities | Data mismatch or delayed filing |
SEBI issued Industry Standards on Reporting of BRSR Core on 20 December 2024. These standards are intended to create consistency in KPI calculation, reporting methodology and supporting evidence.
NSE guidance states that BRSR must be submitted in both PDF and XBRL formats. The PDF and XBRL submissions are required on the same day as the annual report submission to the stock exchanges.
Important compliance numbers include:
Value-chain reporting examines the ESG performance of important upstream and downstream business partners.
Upstream partners may include raw-material suppliers, contract manufacturers, service providers and logistics companies. Downstream partners may include distributors, dealers, institutional customers and other major buyers.
Under SEBI’s current framework, value-chain ESG disclosures are voluntary for the top 250 listed entities from FY 2025-26. Independent assessment or assurance of these disclosures is also voluntary under the revised framework.
A value-chain partner may fall within scope when it individually accounts for more than 2% of the listed entity’s purchases or sales by value.
A listed entity may limit its value-chain disclosure to partners covering up to 75% of total purchases and 75% of total sales, respectively. The company should also disclose the percentage of purchases and sales actually covered.
The main numerical thresholds are:
A BRSR report cannot be prepared accurately from management interviews alone. Every important number should be linked to a calculation sheet, statutory record, invoice, register, certificate or approved internal report.
The reporting consultant normally begins by preparing a question-wise data checklist. Each question is assigned to a data owner, reviewer and approving authority.
For a company with 4 plants, the same calculation method must be used at all 4 locations. One factory should not report water withdrawal while another reports water consumption. Similarly, one site should not include contract workers in safety data while another excludes them.
Corporate and financial information may include:
Environmental records may include:
Social and workforce records may include:
The BRSR reporting process should ideally begin 10 to 14 weeks before the annual report is finalised. Large companies with several factories or subsidiaries may require 16 weeks or more.
The first step is an applicability assessment. The company should confirm whether full BRSR, BRSR Core and value-chain disclosures apply for the relevant financial year.
The second step is defining the reporting boundary. A company must decide whether the disclosure is being prepared on a standalone basis or consolidated basis. Changing the boundary between environmental, financial and workforce sections can produce misleading intensity ratios.
The third step is departmental data collection. Finance, human resources, EHS, procurement, legal, IT, secretarial and operations teams normally contribute separate sets of information.
The fourth step is numerical validation. Figures should be reconciled with audited financial data, invoices, production registers and statutory environmental records.
| Step | Recommended period | Main responsibility | Numerical control |
|---|---|---|---|
| Applicability assessment | Week 1 | Company secretary and ESG team | Market-capitalisation ranking |
| Reporting-boundary confirmation | Week 1 | Finance and management | Standalone or consolidated |
| Gap assessment | Weeks 1-2 | Consultant and departments | Question-wise completion score |
| Data collection | Weeks 3-6 | EHS, HR, finance and procurement | 12-month data coverage |
| Calculation and reconciliation | Weeks 6-8 | Consultant and finance | Unit and formula validation |
| Management review | Weeks 8-9 | CFO, CS and ESG head | Exception closure |
| Assessment readiness | Weeks 9-12 | Independent provider | Evidence sampling |
| Board and annual-report review | Weeks 12-13 | Board and secretarial team | Final approval |
| PDF and XBRL verification | Weeks 13-14 | Filing team | 100% figure matching |
The 10 to 14-week schedule is a practical implementation estimate. It is not a statutory SEBI processing timeline.
The process should achieve the following controls:
Consider an illustrative example of an Indian engineering company called Apex Motion Components Limited. The name is fictional, but the situation reflects common problems faced by multi-location manufacturers.
The company operated 4 plants across Haryana, Gujarat, Maharashtra and Tamil Nadu. It employed approximately 2,150 permanent employees, 680 workers and 1,120 contract workers. Its annual turnover was about ₹3,800 crore.
Apex had filed its BRSR in the previous year, but FY 2025-26 was its first year within the top 500 BRSR Core assessment-or-assurance requirement.
Three months before the annual report deadline, Meera, the company’s sustainability manager, sent data requests to the 4 plants. She expected the process to take 2 weeks.
Instead, the team discovered 47 major data gaps.
The Haryana plant reported diesel in litres. The Maharashtra plant submitted only the total fuel cost in rupees. The Gujarat plant included company vehicles in its fuel consumption, while the Tamil Nadu plant reported only generator fuel.
The company reported 18,600 megawatt-hours of electricity consumption. However, invoice-level reconciliation showed 19,420 megawatt-hours. The difference of 820 megawatt-hours represented approximately 4.2% of the corrected total.
Water data created another problem. The plants initially reported total withdrawal of 164,000 kilolitres, but one plant had included recycled water in fresh-water withdrawal. After correction, fresh-water withdrawal reduced to 146,500 kilolitres.
Employee safety figures were also incomplete. The HR department had calculated person-hours for 2,830 permanent employees and workers but had excluded 1,120 contract workers. Because contractors worked inside the production facilities, their exclusion affected the Lost Time Injury Frequency Rate calculation.
The company had also reported that 92% of its waste was recycled. During evidence review, only 78% could initially be supported by valid manifests and recycler certificates. Several certificates were available, but their validity dates did not cover the entire reporting period.
The company appointed a BRSR consultant to coordinate the correction process.
During the next 11 weeks, the consultant created:
The consultant worked with finance to convert fuel expenditure into verified physical quantities using invoices. HR collected contractor attendance and working-hour records. EHS teams reviewed waste manifests, recycler authorisations and disposal quantities.
At the end of the exercise, the number of unresolved data gaps reduced from 47 to 6. The remaining 6 items were disclosed with appropriate explanations rather than being supported through assumptions.
Meera was able to present one reconciled data pack to the CFO, company secretary and independent assessment provider. The annual report was completed without changing the BRSR numbers after board approval.
The case demonstrates an important lesson. BRSR problems are rarely caused by the absence of ESG activity. They are usually caused by missing ownership, inconsistent definitions and weak supporting evidence.
One of the biggest challenges is collecting consistent data from multiple plants. Units may use different templates, calculation periods and definitions.
Another challenge is connecting ESG information with financial data. BRSR Core includes several intensity ratios based on revenue or production. A small difference in turnover or production quantity can change the reported intensity.
Contract-worker data is another frequent gap. Companies may maintain attendance and safety information through different contractors without creating one consolidated record.
Value-chain information can also be difficult because large companies may deal with hundreds or thousands of suppliers and customers.
Common problems include:
The company must appoint a competent and independent assessment or assurance provider for BRSR Core where applicable.
SEBI has clarified that the provider does not have to be a chartered accountant. The board of the listed entity must ensure that the provider has appropriate sustainability expertise.
Independence is essential. A provider offering consulting, management, system design or certain other non-assurance services to the listed entity or its group companies may face a conflict of interest.
SEBI has also clarified that an internal auditor cannot act as the BRSR Core assurance provider. A statutory auditor may be appointed, subject to competence, independence and other applicable requirements.
The company should therefore maintain a clear separation between:
BRSR is a SEBI and stock-exchange reporting requirement. It is not a CPCB registration, pollution-control consent or environmental authorisation.
Therefore, incorrect BRSR filing does not automatically result in CPCB portal suspension, customs detention or factory closure. However, environmental violations may need to be publicly disclosed in the BRSR and can create significant investor and reputational risk.
A company that reports zero environmental penalties while an SPCB order or environmental compensation case exists may face questions about the completeness of its disclosure.
Section 15A of the SEBI Act covers failure to furnish required information, returns or reports, and the filing of false, incorrect or incomplete information. Depending on the facts and enforcement process, the penalty may be not less than ₹1 lakh and may extend to ₹1 lakh for each day of continuing failure, subject to a maximum of ₹1 crore. This should not be interpreted as an automatic BRSR fine in every case.
Major BRSR risks include:
A BRSR consultant begins by determining the company’s exact reporting obligation. This includes full BRSR applicability, BRSR Core applicability, the reporting boundary and value-chain requirements.
The consultant then converts the SEBI format into a practical departmental checklist. Instead of sending one large questionnaire to the company, the information is divided among finance, HR, EHS, procurement, legal, IT, operations and secretarial teams.
The consultant also reviews the numerical logic behind the disclosures. Electricity, fuel, water, waste, production, wages and safety information are checked against supporting records.
For companies operating in regulated sectors, the BRSR process should also be connected with environmental approvals, waste authorisations and EPR records.
Green Permits’ ESG support scope includes BRSR, GRI and CSRD or ESRS disclosure support, greenhouse-gas accounting, materiality assessment, ESG due diligence and BRSR Core assurance-readiness assistance.
Professional support may include:
A well-prepared BRSR provides more than regulatory compliance. It creates a measurable ESG baseline for management.
When energy, water and waste data are collected consistently, companies can compare the performance of different plants. A facility consuming 15% more electricity per unit of production can be identified and investigated.
Workforce data can reveal differences in injury rates, training hours, employee turnover or gender representation. Procurement data can show the percentage of purchases from MSMEs, local suppliers and value-chain partners.
The main benefits include:
Appointing a BRSR Reporting Consultant in India should not be treated as a simple report-writing assignment.
BRSR connects at least 7 major business functions – finance, human resources, EHS, procurement, legal, IT and company secretarial. For a multi-plant organisation, hundreds of invoices, registers, manifests and operational records may need to be reviewed before the final numbers are approved.
The top 500 listed entities fall within the BRSR Core phased requirement for FY 2025-26. The scope expands to the top 1,000 listed entities for FY 2026-27. Companies entering this requirement should establish reporting systems before year-end rather than waiting for annual-report preparation.
The cost of early preparation is generally lower than the cost of correcting unsupported figures during assessment, board review or stock-exchange filing.
A structured BRSR process gives management reliable information, improves assessment readiness and helps the company communicate its sustainability performance with greater credibility.
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BRSR is mandatory for the top 1,000 listed entities based on market capitalisation. Other listed entities may adopt the framework voluntarily.
BRSR is based on 9 principles of the National Guidelines on Responsible Business Conduct.
BRSR Core contains 9 major ESG attributes covering emissions, energy, water, waste, workforce, diversity, inclusive development, business fairness and openness of business.
The phased schedule covers the top 500 listed entities for FY 2025-26. It expands to the top 1,000 listed entities for FY 2026-27.
