SEBI's Business Responsibility and Sustainability Reporting (BRSR) framework has fundamentally changed how Indian listed companies must account for and disclose their environmental, social, and governance performance. What began as a voluntary reporting exercise has become a mandatory, assurance-backed obligation — and the regulatory pressure continues to intensify year by year.
This guide covers everything a sustainability team, CFO, or company secretary needs to understand about BRSR compliance — from the basics of the framework to the practicalities of Scope 3 calculation, assurance preparation, and value chain disclosure.
What is BRSR and Why Does It Matter?
BRSR (Business Responsibility and Sustainability Report) is SEBI's mandatory ESG disclosure framework, introduced under Regulation 34(2)(f) of the LODR Regulations and made mandatory for the top 1,000 listed companies from FY 2022–23. It replaced the earlier Business Responsibility Report (BRR) with far more granular, structured, and internationally aligned requirements.
BRSR matters for three distinct reasons beyond regulatory compliance. First, investor scrutiny: institutional investors — both domestic mutual funds under SEBI's ESG fund regulations and foreign portfolio investors — increasingly use BRSR disclosures to assess ESG risk. Companies with poor or incomplete BRSR disclosures face investor concerns that affect valuations. Second, supply chain pressure: large listed companies are now required to collect ESG data from their supplier base, meaning that unlisted suppliers who don't have their own ESG systems will struggle to respond. Third, export risk: Indian exporters to the EU face the Carbon Border Adjustment Mechanism (CBAM) from 2026, which imposes carbon tariffs on imports of steel, cement, aluminium, fertilisers, and other carbon-intensive goods. Accurate carbon accounting is essential to manage this risk.
BRSR Structure — The Nine Principles
BRSR is structured around nine National Guidelines for Responsible Business Conduct (NGRBCs), each covering a different dimension of corporate responsibility:
- Principle 1: Businesses conduct and govern themselves with integrity
- Principle 2: Sustainable and safe products and services
- Principle 3: Employee wellbeing
- Principle 4: Stakeholder responsiveness
- Principle 5: Human rights
- Principle 6: Environment — the GHG and carbon accounting section
- Principle 7: Policy advocacy
- Principle 8: Inclusive growth
- Principle 9: Consumer responsibility
Each principle has Essential Indicators (mandatory) and Leadership Indicators (voluntary but increasingly expected by investors and assurance firms).
BRSR Core — The 42 KPIs Requiring Assurance
BRSR Core is a subset of BRSR focused on 42 Key Performance Indicators across environmental, social, and governance dimensions. These KPIs are mandatory for the top 250 companies from FY 2024–25 and must be third-party assured. They cannot be self-reported.
The environmental KPIs under BRSR Core are the most technically demanding and include:
- Total Scope 1 GHG emissions in tCO₂e, with prior year comparisons
- Total Scope 2 GHG emissions (market-based and location-based where applicable)
- Scope 3 emissions for applicable GHG Protocol categories
- GHG emission intensity per rupee of turnover (tCO₂e/₹Cr)
- GHG emission intensity per unit of production
- Percentage reduction in GHG emissions from base year
- Total energy consumed and energy intensity
- Proportion of renewable energy in total energy mix
Calculation methodology: SEBI has endorsed the GHG Protocol Corporate Standard as the methodology for Scope 1 and 2 calculations. For Scope 3, SEBI has endorsed the CEPA (Carbon and Energy Proxy Accounting) spend-based methodology as an acceptable approach for companies without granular supplier data. CarbonFlow supports both activity-based and CEPA methodologies.
Principle 6 — The Environment Section in Detail
Principle 6 is where most organisations invest the most compliance effort, because it requires the most technical data: GHG emissions calculations, energy consumption figures, water data, and waste data — all with quantitative comparisons across current and prior financial years.
Essential Indicator E1 — Energy
Companies must disclose total energy consumption in Joules or multiples, broken down by fuel type (coal, natural gas, diesel, petrol, LPG, biomass), purchased electricity, and renewable sources. Energy intensity per rupee of turnover and per unit of physical output is required.
Essential Indicator E2 — GHG Emissions
This is the core carbon accounting disclosure. Companies must report Scope 1 and Scope 2 emissions in metric tonnes of CO₂ equivalent (tCO₂e), along with emission intensity metrics. For Scope 2, India uses the Central Electricity Authority (CEA) grid emission factor for the relevant state or national average.
Essential Indicator E3 — Air Emissions
Beyond GHGs, companies with significant industrial operations must disclose NOx, SOx, particulate matter, and persistent organic pollutants where applicable.
Third-Party Assurance — What It Means in Practice
Third-party assurance on BRSR Core KPIs means an external, accredited firm independently verifies that your disclosed numbers are accurate, complete, and consistent with the stated methodology. This is analogous to a financial audit — but for sustainability data.
Common assurance providers used by Indian companies include the Big Four accounting firms (Deloitte, PwC, EY, KPMG) and specialist assurance firms including DNV, Bureau Veritas, and TUV Rheinland. Your assurance firm will review your data collection process, calculation methodology, emission factor sources, and any assumptions made.
The key to passing assurance smoothly is having a complete, documented audit trail — source data linked to calculations, emission factors cited with their source and version, and a clear data governance process. This is exactly what CarbonFlow provides.
Value Chain Disclosures — FY 2025–26 and Beyond
From FY 2025–26, the top 250 companies must collect and disclose ESG data from their major value chain partners. SEBI defines these as suppliers and customers accounting for at least 2% of total purchases or sales individually, or those collectively covering 75% of aggregate purchase/sales value.
In practice, this means most large listed companies will need to collect ESG data — at minimum energy and GHG data — from 20–60 key suppliers. This requires a systematic supplier engagement process, which CarbonFlow's Supply Chain Module is designed to handle.
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