If your company is one of India's 1,000 largest listed companies, you file a Business Responsibility and Sustainability Report (BRSR) with your annual report. If you supply one of those companies, you are increasingly asked for the same figures. This guide explains what the report covers and what BRSR Core adds. It also shows how to build answers that stand up when an assessor or assurer asks where a number came from.
What the BRSR is and who files it
The BRSR is the format the Securities and Exchange Board of India (SEBI) sets for environmental, social and governance (ESG) disclosure by listed companies. SEBI introduced it by circular on 10 May 2021, replacing the older Business Responsibility Report (BRR). It has been mandatory for the top 1,000 listed companies by market capitalisation since FY 2022-23.
It did not arrive from nowhere. It is the latest step in a decade of guidance from the Ministry of Corporate Affairs and SEBI, and each step widened who reports and how much.
- Year
- 2011
- What changed
- National Voluntary Guidelines on business responsibility published
- Year
- 2012
- What changed
- BRR required of the top 100 listed companies
- Year
- 2015
- What changed
- BRR extended to the top 500
- Year
- 2019
- What changed
- National Guidelines on Responsible Business Conduct (NGRBC); BRR extended to the top 1,000
- Year
- 2020
- What changed
- Ministry of Corporate Affairs committee proposes the BRSR format
- Year
- 2021
- What changed
- SEBI introduces the BRSR for the top 1,000
- Year
- 2023
- What changed
- SEBI introduces BRSR Core, with phased assurance
| Year | What changed |
|---|---|
| 2011 | National Voluntary Guidelines on business responsibility published |
| 2012 | BRR required of the top 100 listed companies |
| 2015 | BRR extended to the top 500 |
| 2019 | National Guidelines on Responsible Business Conduct (NGRBC); BRR extended to the top 1,000 |
| 2020 | Ministry of Corporate Affairs committee proposes the BRSR format |
| 2021 | SEBI introduces the BRSR for the top 1,000 |
| 2023 | SEBI introduces BRSR Core, with phased assurance |
Unlisted companies do not file a BRSR. Many of them still end up answering its questions, because their listed customers need the data. We come back to that below.
How the report is structured
The report has three sections. Each one draws on different people and documents inside the company.
- Section A, general disclosures: the entity, its products and operations, its workforce and its corporate social responsibility work.
- Section B, management and process: the policies behind each principle, who governs them and how the board oversees them.
- Section C, principle-wise performance: essential indicators, which every filer answers, and leadership indicators, which are voluntary.
Section C follows the nine principles of the NGRBC, published by the Ministry of Corporate Affairs in 2019. Paraphrased, they ask a business to do the following.
- Principle
- 1
- What it asks, paraphrased
- Govern with integrity, in an ethical, transparent and accountable way
- Principle
- 2
- What it asks, paraphrased
- Provide goods and services that are sustainable and safe
- Principle
- 3
- What it asks, paraphrased
- Respect the well-being of all employees, including in the value chain
- Principle
- 4
- What it asks, paraphrased
- Respect the interests of all stakeholders and respond to them
- Principle
- 5
- What it asks, paraphrased
- Respect and promote human rights
- Principle
- 6
- What it asks, paraphrased
- Protect and restore the environment
- Principle
- 7
- What it asks, paraphrased
- Engage with public and regulatory policy responsibly and openly
- Principle
- 8
- What it asks, paraphrased
- Promote inclusive growth and equitable development
- Principle
- 9
- What it asks, paraphrased
- Engage with and provide value to consumers responsibly
| Principle | What it asks, paraphrased |
|---|---|
| 1 | Govern with integrity, in an ethical, transparent and accountable way |
| 2 | Provide goods and services that are sustainable and safe |
| 3 | Respect the well-being of all employees, including in the value chain |
| 4 | Respect the interests of all stakeholders and respond to them |
| 5 | Respect and promote human rights |
| 6 | Protect and restore the environment |
| 7 | Engage with public and regulatory policy responsibly and openly |
| 8 | Promote inclusive growth and equitable development |
| 9 | Engage with and provide value to consumers responsibly |
What BRSR Core adds
In July 2023 SEBI introduced BRSR Core, a subset of BRSR indicators that must be independently assured or assessed. It phases in by market capitalisation: the top 150 listed companies from FY 2023-24, rising to the top 1,000 from FY 2026-27. SEBI's circular of 28 March 2025 revised the framework, including allowing assessment as well as assurance.
The Core indicators are grouped under attributes that cover:
- greenhouse gas footprint
- water footprint
- energy footprint
- circularity and waste
- employee well-being and safety
- gender diversity
- inclusive development
- fairness in dealing with customers and suppliers
- openness of business
Several Core figures are intensities. For emissions, energy and water you report intensity per rupee of turnover, and a version adjusted for purchasing power parity (PPP). So you need clean turnover figures alongside the physical ones.
Every Core figure needs a trail
What it means for suppliers
BRSR asks listed companies to look beyond their own gates. BRSR Core sets out value chain disclosures for the largest listed companies, covering their main upstream and downstream partners. SEBI's 28 March 2025 circular made these disclosures voluntary for FY 2025-26.
Voluntary does not mean nobody asks. Listed companies preparing for these disclosures are already sending suppliers questions on energy, emissions, water, waste, safety and the workforce. If you supply one, expect a questionnaire before any rule requires it.
Your answer feeds straight into their report. A measured figure from you replaces an estimate in theirs, and a figure with a bill behind it is one they can defend to their assurer. That makes you an easier supplier to keep.
Preparing your BRSR in seven steps
- Confirm the scope and the yearDecide which entity and subsidiaries the report covers and which financial year it describes. Check if your market capitalisation puts you in the BRSR Core phase for that year.
- Name an owner for each principleFinance, HR, environment and safety, and the company secretary each hold part of the answer. Give every principle a named owner and a date.
- Map where each figure livesFor every Section C indicator, write down the document it comes from: electricity bills, fuel invoices, water meter readings, waste records, payroll, safety logs, the complaints register.
- Check the policies behind Section BEach policy should have an owner, a recent board approval and a review date. Where the format asks for a web link, the policy must be public. Check that it reaches the value chain where relevant and names a grievance route.
- Collect data and evidence as you goGather figures monthly or quarterly and attach the source document when you enter them, not at year end.
- Calculate derived figures onceWork out totals, ratios and intensities from the underlying entries, so a figure that appears under two principles has one value. Record every emission factor and its version, such as the Central Electricity Authority's grid factor for Indian electricity.
- Review, sign off and fix the versionRun an internal review, get board sign-off, then lock the figures so the version you file is the version your assessor or assurer checks. The filing goes to the stock exchanges in XBRL, a structured data format, so validate the file in the exchange's own utility before you submit it.
Gaps to check before your assurer does
These are the gaps that turn an easy review into a long one. Each is cheap to fix early.
- A policy with no named owner, or one approved years ago and never revisited.
- A policy the format says should be public that is not on your website.
- No grievance or complaints route named, or one that is named but not tracked.
- The same figure reported with two different values in two principles.
- An emissions figure with no record of the factor or its source.
- A Core indicator with data entered but no document attached.
How ESGen helps with BRSR
The ESGen platform has a BRSR and BRSR Core lens. It holds SEBI's format as structure, marks the Core indicators, and keeps the evidence document against each answer. Readiness and evidence-coverage scores show which indicators still lack data or proof. A calculation log records how each figure was worked out, and a sign-off lock fixes the reporting period once it is chosen.
One limit to know. The platform's built-in emission factors are the UK government's, published by the Department for Energy Security and Net Zero (DESNZ). It does not yet calculate Indian electricity emissions with the Central Electricity Authority's grid factor, so ask us how your emissions figures will be handled.
Our team works alongside the platform. We can review the policies behind Section B, and help unlisted suppliers answer the questionnaires their listed customers send. Every plan includes onboarding, where we set up the workspace with you.
ESGen helps prepare structured reporting evidence. We are not an assessor or assurance provider, and no software makes a company compliant on its own. SEBI sets the requirements, so confirm your own obligations with your advisers. See BRSR in the platform, or book a demo and we will walk through it with your own reporting year.
Sources
- SEBI circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562, 10 May 2021 (Business Responsibility and Sustainability Report)
- SEBI circular on the BRSR Core framework, 12 July 2023
- SEBI circular revising the BRSR Core and value chain requirements, 28 March 2025
- SEBI circular on the Business Responsibility Report, 2012, and the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015, as amended in 2019
- Ministry of Corporate Affairs, National Guidelines on Responsible Business Conduct, 2019
- Central Electricity Authority, CO₂ Baseline Database for the Indian Power Sector
This article is general information, not legal or financial advice. Rules change, so check the current guidance before you rely on a threshold or a date.



