The Complete BRSR Compliance Guide for Indian Listed Companies

What is BRSR?

The Business Responsibility and Sustainability Report (BRSR) is a mandatory ESG disclosure framework introduced by the Securities and Exchange Board of India (SEBI) under Regulation 34(2)(f) of the LODR Regulations, 2015. It replaced the earlier Business Responsibility Report (BRR) in FY 2022–23.

BRSR aligns Indian ESG reporting with global frameworks — the GRI Standards, TCFD, and the UN Sustainable Development Goals — while maintaining relevance to India's specific regulatory and development context. Companies file their BRSR as part of their Annual Report.

BRSR covers three major sections: general disclosures (company profile, products, supply chain), management and process disclosures across nine National Guidelines for Responsible Business Conduct (NGRBCs), and principle-wise performance indicators split between Essential Indicators (mandatory) and Leadership Indicators (voluntary but increasingly expected).

Who Must Comply with BRSR?

BRSR mandatory filing applies to the top 1,000 listed companies by market capitalisation on Indian stock exchanges. This covers a large proportion of India's listed equity value and spans every major sector.

• Top 1,000 listed companies by market cap — mandatory full BRSR from FY 2022–23
• Top 250 companies — BRSR Core with mandatory third-party assurance from FY 2024–25
• Top 500 companies — BRSR Core assurance expanding from FY 2026–27
• All 1,000 companies — SEBI has signalled intent to bring all under BRSR Core assurance by FY 2027–28

BRSR Core — Enhanced Requirements

BRSR Core was introduced in 2023 and made mandatory for the top 250 listed companies from FY 2024–25. It focuses on 42 Key Performance Indicators (KPIs) that represent the most material and verifiable sustainability disclosures.

These 42 KPIs must undergo third-party assurance — companies cannot self-certify BRSR Core disclosures. Assurance must be provided by an accredited third-party firm.

Principle 6 — Environment (The Carbon Accounting Section)

Principle 6 of BRSR covers environmental stewardship and is the most technically demanding section for most organisations. It requires detailed disclosure on greenhouse gas emissions, energy, water, waste, and biodiversity impacts.

Essential Indicators (Mandatory for all)

• Total energy consumed (in Joules or multiples) — renewable vs non-renewable
• Energy intensity per rupee of turnover and per unit of production
• Scope 1 and Scope 2 GHG emissions in metric tonnes CO₂ equivalent
• GHG emission intensity per rupee of turnover and per unit of production
• Total Scope 3 emissions for applicable categories
• Total water withdrawal, consumption, and discharge
• Total waste generated, recycled, and disposed

Leadership Indicators (Voluntary, but increasingly assessed)

• Scope 3 emissions by category (15 GHG Protocol categories)
• Science-based targets for emissions reduction
• Net zero commitments and progress against baseline
• Carbon credits purchased, retired, and inventory balance
• Green credit disclosure
• Biodiversity impact assessment

Scope 1, 2 & 3 Emissions — What BRSR Requires

BRSR uses the GHG Protocol Corporate Accounting and Reporting Standard as the basis for emissions calculation. This divides emissions into three scopes:

Scope 1 (Direct Emissions): All direct GHG emissions from sources owned or controlled by the organisation — stationary combustion (boilers, generators), mobile combustion (fleet vehicles), process emissions (chemical reactions), and fugitive emissions (refrigerant leaks).

Scope 2 (Energy Indirect Emissions): Indirect emissions from the generation of purchased electricity, steam, heat, or cooling consumed by the organisation. In India, CarbonFlow uses the Central Electricity Authority (CEA) grid emission factors, which are updated annually by the Ministry of Power.

Scope 3 (Other Indirect Emissions): All other indirect emissions across the value chain. BRSR requires disclosure of applicable Scope 3 categories. The CEPA (Carbon and Energy Proxy Accounting) methodology endorsed by SEBI allows spend-based calculation for companies without granular supplier data.

Assurance Requirements

From FY 2024–25, BRSR Core KPIs for the top 250 companies must undergo third-party assurance. Two levels of assurance are accepted:

• Reasonable assurance: Higher standard, similar to a financial audit. Assurer states positively that disclosures are fairly presented.
• Limited assurance: Lower standard, assurer states no evidence of material misstatement (negative assurance).

Common assurance providers used by Indian listed companies include Deloitte, PwC, EY, KPMG, DNV, Bureau Veritas, and TUV Rheinland. The assurance firm reviews the calculation methodology, data sources, and documentation — not the sustainability strategy.

Value Chain Disclosures — FY 2025–26 Mandate

From FY 2025–26, the top 250 companies must disclose ESG information about their major value chain partners — defined as suppliers or customers accounting for at least 2% of purchases or sales, or cumulatively covering 75% of total purchase or sales value.

This is one of the most operationally complex BRSR requirements. It requires companies to:

• Identify and tier suppliers meeting the coverage threshold
• Collect ESG data from each covered supplier — typically via a questionnaire or portal
• Validate and consolidate supplier data for disclosure
• Report on supplier ESG performance in the BRSR

CarbonFlow's Supply Chain Module automates this process with a supplier-facing portal, automated reminders, data validation, and BRSR roll-up reporting.

India's Carbon Credit Trading Scheme (CCTS)

India's Carbon Credit Trading Scheme (CCTS) was operationalised in June 2025 under the Energy Conservation (Amendment) Act, 2022. It creates a domestic, legally binding carbon market administered by the Bureau of Energy Efficiency (BEE).

Under CCTS, designated energy-intensive industries receive carbon credit targets. Companies that reduce emissions below their target earn carbon credits which can be sold. Companies that exceed their target must purchase credits.

SEBI's March 2025 circular allows companies to disclose green credits under BRSR Leadership Indicators, creating additional incentive to participate in carbon and green credit markets.

CarbonFlow tracks CCTS carbon credit purchases, retirements, and balance inventory — and maps these directly to BRSR Leadership disclosure requirements.

Compliance Roadmap to FY 2027

How CarbonFlow Automates BRSR Compliance

Manual BRSR compliance — collecting data across departments, calculating emissions using spreadsheet-based models, formatting disclosures, and managing the assurance process — typically takes a team of 3–5 people 3–4 months per year.

CarbonFlow reduces this to days, not months, with a structured workflow that produces audit-grade outputs from day one.

• Data ingestion: Connect your ERP, utility providers, and procurement systems. CarbonFlow classifies incoming data automatically.
• GHG calculation: Scope 1–2–3 calculated using GHG Protocol methodology and India-specific emission factors. Every number is traceable to source.
• BRSR report generation: One-click export of the complete Principle 6 section in SEBI-format Excel and PDF.
• Assurance support: Full calculation audit trail provided to your assurance firm. Reduces assurance time by 60%+.
• Value chain: Supplier portal, automated chasing, and roll-up for FY 2025–26 mandates.