Consider an Indian manufacturing company operating three factories across Haryana, Gujarat and Maharashtra. The company has been supplying components to domestic and international customers for more than 15 years.
One of its major customers requests a sustainability performance report covering electricity consumption, carbon emissions, water usage, waste management and employee safety.
The management assumes the information will be easy to provide because the factories already maintain environmental records.
However, the reporting team discovers several problems. Electricity bills are available, but consolidated consumption figures are missing. Waste disposal records are maintained separately at each facility. The HR department has employee information, but contractor safety data is incomplete. Nobody has calculated the company’s greenhouse gas emissions.
The information exists in different formats, but it is not ready for sustainability reporting.
This illustrative case study highlights a common reporting challenge for Indian businesses: collecting environmental information is not the same as preparing reliable ESG disclosures.
Sustainability reporting in India has become increasingly important as companies face regulatory requirements, investor expectations and supply-chain demands.
The Securities and Exchange Board of India (SEBI) requires specified listed entities to prepare Business Responsibility and Sustainability Reports (BRSR). International frameworks such as the Global Reporting Initiative (GRI) Standards also help organisations communicate their environmental, social and governance performance.
For businesses, the challenge is understanding which framework applies, what information must be collected and how to prepare accurate disclosures.
This guide explains BRSR requirements, GRI Standards, ESG data preparation, reporting procedures and practical considerations for Indian companies.
Sustainability reporting is the process of measuring, documenting and communicating how an organisation manages environmental, social and governance matters.
Unlike traditional financial reporting, which focuses on revenue, profitability and financial position, sustainability reporting examines a company’s wider impacts and responsible business practices.
It generally covers three areas.
Environmental performance includes energy consumption, greenhouse gas emissions, renewable energy, water usage, wastewater management, waste generation and recycling.
Social performance covers employee welfare, workforce diversity, occupational health and safety, human rights, training and community engagement.
Governance performance includes board oversight, ethical business practices, anti-corruption policies, regulatory compliance and grievance mechanisms.
For example, a company producing industrial equipment may report annual electricity consumption, workplace incidents, employee training hours and waste recycling quantities.
These disclosures help stakeholders understand business performance beyond financial results.
For Indian companies, sustainability reporting may be mandatory under applicable regulations, voluntary under recognised standards or requested through commercial relationships.
Business Responsibility and Sustainability Reporting (BRSR) is an ESG disclosure framework introduced by SEBI.
It replaced the earlier Business Responsibility Report (BRR) and established a more structured approach to sustainability disclosures.
Under the SEBI framework, BRSR reporting became mandatory from FY 2022-23 for the top 1,000 listed entities by market capitalisation.
The framework is aligned with the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC).
These principles address responsible business conduct, employee well-being, environmental protection, human rights, consumer interests and stakeholder engagement.
BRSR is mandatory for listed entities covered by SEBI’s applicable requirements.
Other listed entities may voluntarily submit BRSR disclosures.
Private limited companies, unlisted manufacturers and MSMEs are not automatically subject to SEBI’s BRSR mandate. However, they may prepare sustainability reports to satisfy investors, lenders, customers or international business partners.
BRSR contains three principal reporting sections.
| Section | Information required |
|---|---|
| Section A | General company disclosures, business operations, employees and products |
| Section B | Management processes, corporate policies and governance |
| Section C | Principle-wise performance against nine NGRBC principles |
The framework includes essential indicators and leadership indicators.
Essential indicators are mandatory for applicable entities, while leadership indicators provide additional voluntary disclosures.
For businesses preparing their reports, the challenge is not simply completing these sections. They must ensure that disclosed information is consistent with operational records and supported by evidence.
BRSR Core is a selected subset of BRSR containing key performance indicators under nine ESG attributes.
It was introduced to improve the comparability and reliability of sustainability information disclosed by listed companies.
BRSR Core includes indicators covering greenhouse gas emissions, energy, water, waste, employee well-being, gender diversity and other responsible business parameters.
SEBI introduced a phased schedule for mandatory third-party assessment or assurance of BRSR Core disclosures.
| Financial year | Applicable listed entities |
|---|---|
| FY 2023-24 | Top 150 |
| FY 2024-25 | Top 250 |
| FY 2025-26 | Top 500 |
| FY 2026-27 | Top 1,000 |
SEBI’s March 28, 2025 circular provided the option of assessment or assurance under the applicable framework.
This distinction matters because companies should not rely on outdated guidance suggesting that only reasonable assurance is permitted.
Large businesses increasingly seek sustainability information from suppliers, contractors and other value-chain partners.
Under SEBI’s revised framework, value-chain ESG disclosures are voluntary for the top 250 listed entities from FY 2025-26. Related assessment or assurance is voluntary from FY 2026-27.
For suppliers, this can mean receiving requests for electricity consumption, emissions, waste management and workforce information even when they are not independently required to publish a BRSR.
The Global Reporting Initiative (GRI) Standards provide an internationally recognised approach to sustainability impact reporting.
They help organisations identify and communicate significant impacts on the economy, environment and people.
Unlike BRSR, which applies mandatorily to specified Indian listed entities, GRI reporting is generally voluntary unless required by another applicable obligation.
GRI Standards are organised into three categories.
The Universal Standards establish the foundation for sustainability reporting.
They include GRI 1: Foundation, GRI 2: General Disclosures and GRI 3: Material Topics.
These standards address reporting principles, organisational information and the identification of significant sustainability impacts.
Sector Standards help organisations identify sustainability impacts relevant to particular industries.
For example, companies operating in sectors with significant environmental impacts may need to consider industry-specific subjects when identifying material topics.
Topic Standards cover specific subjects such as energy, emissions, water, waste, employment and occupational health and safety.
Organisations select relevant disclosures based on their material topics and the applicable GRI requirements.
A key part of GRI reporting is the materiality assessment, which identifies the organisation’s most significant impacts.
Although both frameworks address sustainability, their reporting objectives differ.
| Parameter | BRSR | GRI |
|---|---|---|
| Framework authority | SEBI | Global Reporting Initiative |
| Main objective | Standardised responsible business disclosures | Reporting significant organisational impacts |
| Applicability | Mandatory for specified listed entities | Generally voluntary |
| Geographic relevance | India | International |
| Reporting structure | Sections A, B and C | Universal, Sector and Topic Standards |
| Primary users | Investors, regulators and other stakeholders | Broad stakeholder groups |
An Indian listed company may prepare BRSR to meet regulatory obligations and also use GRI Standards for wider sustainability reporting.
However, the two frameworks are not interchangeable. Companies must check the specific disclosure requirements of each framework before relying on common datasets.
Reliable ESG data preparation is the foundation of effective sustainability reporting.
Many businesses already maintain environmental and operational records, but information may be scattered across departments and factory locations.
A structured system helps consolidate this information.
Environmental information commonly includes:
For example, a factory may maintain monthly electricity bills but still need a consolidated annual energy consumption statement.
Social information may include employee headcount, workplace safety incidents, training hours, workforce diversity and grievance records.
Governance information may include board composition, compliance policies, ethics training and risk management procedures.
Data should be supported by reliable documents rather than estimates without a defensible methodology.
Preparing a sustainability report requires a systematic approach.
Determine whether BRSR is mandatory or whether the company intends to adopt GRI or another framework voluntarily.
Confirm the financial year and applicable disclosure requirements.
Identify the facilities, subsidiaries and operations included in the report.
A company with multiple manufacturing plants must establish consistent rules for consolidating information.
Identify significant environmental, social and governance impacts.
The assessment should follow the selected framework and consider business activities, stakeholder concerns and operational risks.
Different departments should be responsible for collecting and reviewing specific information.
| Department | ESG information |
|---|---|
| Operations | Production and energy consumption |
| Environment / EHS | Water, waste, emissions and environmental records |
| Human Resources | Employees, training and safety |
| Procurement | Supplier information |
| Finance | Financial and operational data |
| Legal / Compliance | Policies and governance documentation |
Convert collected information into the units and indicators required for reporting.
This may involve energy calculations, greenhouse gas accounting, recycling percentages and workforce-related performance indicators.
Reported figures should be reconciled with invoices, operational registers, monitoring records and calculation worksheets.
Map verified information to the selected reporting framework.
Complete internal reviews, management approvals and applicable independent assessment or assurance before publication.
Greenhouse gas accounting is an important component of sustainability reporting.
The widely used GHG Protocol divides organisational emissions into three scopes.
Scope 1: Direct emissions from owned or controlled sources, such as boilers, generators and certain company vehicles.
Scope 2: Indirect emissions associated with purchased electricity, steam, heating or cooling.
Scope 3: Other indirect emissions across the value chain, including relevant purchased goods, transportation, business travel and waste-related activities.
Consider a hypothetical manufacturing facility consuming 12,00,000 kWh of purchased electricity annually.
For demonstration, assume an electricity emission factor of 0.70 kg CO2e per kWh.
Annual emissions = 12,00,000 × 0.70
= 8,40,000 kg CO2e
= 840 tonnes CO2e
This calculation is illustrative. Actual reporting requires appropriate emission factors, organisational boundaries, accounting methods and supporting records.
For multi-site companies, consistent calculation methods are particularly important when comparing annual emissions.
Document requirements depend on the reporting framework, industry and organisational structure.
However, companies commonly need the following records.
| ESG category | Supporting documentation |
|---|---|
| Energy | Electricity bills, diesel records, fuel registers |
| Water | Water bills, meter readings, monitoring records |
| Waste | Waste registers, disposal manifests, recycling records |
| Emissions | Activity data, emission factors, calculation sheets |
| Employees | Payroll, workforce and training records |
| Workplace safety | Incident registers, safety training records |
| Suppliers | Procurement data and supplier questionnaires |
| Governance | Policies, board records and compliance registers |
Businesses should maintain consistent reporting periods and document ownership.
The purpose is to establish an audit trail so that reported information can be traced to its original source.
Companies preparing ESG reports for the first time may encounter several practical difficulties.
One common problem is inconsistent data collection. Different factories may maintain information in different units or reporting formats.
Another issue is missing historical records. A company may have current energy data but insufficient information to establish a reliable baseline year.
Incorrect emission factors, incomplete supplier data and inconsistent reporting boundaries can also affect disclosure accuracy.
Some organisations make the mistake of reporting sustainability policies without providing measurable evidence of implementation.
To improve reporting quality, businesses should establish internal responsibilities, standardised data templates, calculation methodologies and periodic validation procedures.
Sustainability reporting is increasingly relevant beyond listed companies.
Indian manufacturers supplying multinational customers may receive ESG questionnaires covering carbon emissions, energy consumption, labour practices and waste management.
Exporters operating in carbon-intensive industries may also face separate product-level environmental data requirements, depending on destination markets and applicable regulations.
For example, European customers may request greenhouse gas information from suppliers as part of their own reporting or supply-chain assessments.
These commercial requirements should not be confused with mandatory BRSR reporting.
For private businesses beginning their sustainability journey, establishing a basic ESG data inventory can be a practical first step.
Sustainability reporting can provide benefits beyond regulatory compliance.
First, collecting energy, water and waste information helps management understand resource consumption and identify operational improvement opportunities.
Second, transparent ESG disclosures can support communication with investors, lenders and customers.
Third, organised sustainability records can make it easier to respond to supplier assessments and procurement questionnaires.
Fourth, consistent performance indicators help organisations monitor progress against environmental and social objectives.
The value of sustainability reporting depends on reliable information and meaningful management action, not simply publishing an annual report.
Preparing a sustainability report requires technical knowledge, regulatory understanding and cooperation between multiple departments.
A sustainability reporting consultant can help identify the applicable framework, review available information and establish reporting procedures.
Consulting support may include materiality assessments, ESG data collection systems, greenhouse gas inventories, disclosure mapping and documentation reviews.
Consultants can also help companies identify gaps in their ESG information and prepare supporting records for applicable third-party assessment or assurance.
For manufacturing businesses, integrating environmental compliance information with sustainability reporting can help reduce duplicated data collection and improve consistency.
Green Permits Consulting provides environmental compliance and sustainability advisory services for Indian manufacturers, corporates and businesses.
Our ESG-related services include BRSR and GRI reporting support, greenhouse gas accounting, ESG data preparation, sustainability assessments and environmental compliance advisory.
We help businesses understand applicable reporting frameworks, organise relevant operational information and improve documentation readiness.
For organisations operating multiple manufacturing facilities, Green Permits can assist in developing structured ESG data collection and reporting processes suited to their operations.
The objective is to make sustainability reporting more practical, consistent and useful for business decision-making.
Sustainability reporting in India is becoming an important part of corporate transparency, environmental management and responsible business practices.
BRSR provides structured disclosures for specified listed entities, while GRI Standards support internationally recognised sustainability impact reporting.
However, preparing a credible report requires more than choosing a reporting framework. Businesses need reliable ESG data, consistent calculation methods, clear responsibilities and supporting documentation.
Companies that establish these processes early can improve reporting accuracy, strengthen operational visibility and respond more effectively to stakeholder requirements.
For Indian businesses, sustainability reporting should be viewed as an ongoing process of measuring performance and improving responsible business practices rather than simply preparing an annual document.
BRSR reporting is mandatory for the top 1,000 listed entities by market capitalisation under SEBI’s applicable framework. Other businesses may report voluntarily or have separate reporting obligations.
Private limited companies are not automatically subject to SEBI’s BRSR mandate. However, customers, investors or lenders may request sustainability information.
BRSR is an Indian listed-entity disclosure framework, while GRI Standards provide an internationally recognised approach to reporting organisational impacts.
ESG data preparation involves collecting, calculating, validating and organising environmental, social and governance information for sustainability disclosures.
Assurance or assessment requirements depend on the reporting framework and applicable regulations. Specified listed entities must follow the relevant BRSR Core requirements.
Green Permits supports Indian businesses with ESG reporting preparation, greenhouse gas accounting, environmental compliance and sustainability advisory.
Our services also cover environmental authorisations and recycling plant setup consulting, helping industries address operational compliance and resource-management requirements.
Need help preparing BRSR disclosures, GRI reports or ESG data?
Green Permits Consulting can assist your organisation with reporting readiness assessments, ESG documentation, greenhouse gas accounting and sustainability reporting support.
Website: https://www.greenpermits.in/
📞 Phone: +91 78350 06182
📧 Email: wecare@greenpermits.in
