BRSR in India: SEBI requirements, BRSR Core, reporting structure and value-chain disclosures

Business Responsibility and Sustainability Reporting under SEBI. Regulatory position considered: September 2026.

Executive summary: BRSR

The Business Responsibility and Sustainability Report (BRSR) is India's regulatory framework for structured sustainability disclosures by listed entities. It was introduced by the Securities and Exchange Board of India (SEBI) to move sustainability reporting toward standardized, quantitative and comparable disclosures.

BRSR is linked to Regulation 34(2)(f) of the SEBI Listing Obligations and Disclosure Requirements Regulations, 2015 (LODR Regulations). The current SEBI LODR Regulations page reflects amendments through July 14, 2026.

BRSR became mandatory for the top 1,000 listed entities by market capitalization from FY 2022–23, while other listed entities may voluntarily submit BRSR. The framework is built around the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC) and contains mandatory Essential Indicators and voluntary Leadership Indicators.

SEBI subsequently introduced BRSR Core, a focused set of quantitative sustainability KPIs designed to improve the credibility and comparability of important sustainability information. Its implementation was phased according to market capitalization, reaching the top 1,000 listed entities for FY 2026–27.

The framework has also evolved to address value-chain sustainability information, although SEBI subsequently made value-chain ESG disclosures voluntary for the top 250 listed entities from FY 2025–26 and clarified the applicable scope.

For organizations preparing BRSR, the central challenge is therefore no longer simply collecting information. It is establishing consistent definitions, reliable source data, evidence, calculations, controls, review mechanisms and an auditable trail for sustainability information.

1. Introduction to BRSR

Sustainability information increasingly influences investors, regulators, customers, lenders, employees and other stakeholders. Traditional financial reporting primarily describes financial performance; BRSR expands corporate disclosure toward the organization's environmental, social and governance performance and impacts.

SEBI describes BRSR as a framework intended to provide quantitative and standardized ESG disclosures, allowing greater comparability across companies, sectors and time. The framework is therefore designed around measurable information rather than purely narrative sustainability statements.

2. Evolution from BRR to BRSR

SEBI originally introduced the Business Responsibility Report (BRR), based on the earlier responsible-business framework, which focused on reporting the adoption of responsible business principles.

SEBI subsequently introduced BRSR through its May 10, 2021 circular. BRSR was voluntary for FY 2021–22 and became mandatory for the top 1,000 listed entities from FY 2022–23; the earlier BRR requirement was discontinued after FY 2021–22. The change represented a significant move from broad responsible-business statements toward structured sustainability metrics and disclosures.

3. Who Needs to Report BRSR?

The principal mandatory applicability is the top 1,000 listed entities by market capitalization, measured as specified under the applicable SEBI framework, based on March 31 of the financial year. Other listed entities may voluntarily provide BRSR disclosures.

The requirement should therefore be assessed every year rather than assuming that a company permanently remains within or outside the threshold.

4. Where BRSR Fits into the Annual Report

BRSR forms part of the annual-report disclosure architecture under the SEBI LODR framework: SEBI's BRSR provisions sit within the annual-disclosure requirements, and the prescribed format is provided through the relevant SEBI framework. BRSR should therefore not be treated as an isolated marketing sustainability report—it is a regulatory disclosure requiring controlled and supportable information.

5. The Nine BRSR Principles

Together these principles cover the major environmental, social and governance dimensions of responsible business conduct.

6. Structure of the BRSR

Section A — General Disclosures

Section A establishes the identity and operating context of the listed entity, including its CIN, name, year of incorporation, registered and corporate offices, contact details, website, reporting financial year, stock exchanges, paid-up capital, BRSR contact person, reporting boundary, business activities, products and services, locations, markets served, employees and workers (including differently abled employees and workers), women's participation and representation, employee turnover, holding structure, subsidiaries and associates, CSR details and transparency-related information. The prescribed format, for example, asks entities to disclose products and services accounting for 90% of turnover, and their operational locations.

Reporting boundary

One of the most important BRSR concepts is the reporting boundary: a company must identify whether its disclosures are prepared on a standalone or consolidated basis, and keep that boundary consistent throughout the report. This matters most when data comes from parent companies, subsidiaries, joint operations, manufacturing locations, offices and international operations—a change in boundary can materially affect sustainability metrics.

Section B — Management and Process Disclosures

Section B covers the policies, governance and management systems behind responsible business practices: policy coverage, approval and implementation, board-level responsibility, stakeholder engagement, grievance mechanisms, governance structures, sustainability responsibilities, assessment mechanisms, value-chain considerations and management of material sustainability issues. It shows not only what the organization reports, but how it manages the issues being reported.

Section C — Principle-wise Performance Disclosure

Section C is the core performance component, examining performance against each of the nine principles. Each principle is divided into Essential Indicators (mandatory) and Leadership Indicators (voluntary, though listed entities are encouraged to report them). This distinction is important when designing a BRSR data-collection system.

7. What Each Principle Covers

• Principle 1 — Ethics, transparency and accountability: ethics, anti-corruption, anti-bribery, conflict of interest, governance, transparency, stakeholder complaints, disciplinary actions and business responsibility policies.
• Principle 2 — Sustainable products and services: product design, resource efficiency, sustainable materials, product safety, recycling, circularity, lifecycle impacts, sustainable technology and R&D.
• Principle 3 — Employee well-being: employee and worker numbers, gender representation, permanent and non-permanent workforce, differently abled employees and workers, turnover, well-being measures, training, health and safety, social security, grievances and workplace incidents—one of the most data-intensive social areas.
• Principle 4 — Stakeholder engagement: stakeholder identification and consultation, vulnerable groups, engagement and response mechanisms, key concerns and social-impact considerations.
• Principle 5 — Human rights: human rights policy and due diligence, grievances, discrimination, child and forced labour, human-rights risks, training, incidents and value-chain considerations.
• Principle 6 — Environment: energy (consumption, renewables, intensity), water (withdrawal, consumption, discharge, water-related risks), emissions (Scope 1, Scope 2, GHG intensity, other air emissions), waste (generation, management, recycling, disposal, intensity) and environmental compliance (incidents, notices, regulatory actions, ecologically sensitive areas).
• Principle 7 — Responsible public policy: industry and trade associations, policy advocacy, public-policy positions, responsible lobbying and areas of engagement.
• Principle 8 — Inclusive growth: social-impact programmes, community and rural development, beneficiary groups, impact assessments, vulnerable communities and social investment.
• Principle 9 — Consumer responsibility: consumer complaints by category (data privacy, advertising, cybersecurity, delivery of essential services, restrictive and unfair trade practices), product recalls, product information and corrective actions.

8. BRSR Core

BRSR Core is not a replacement for the complete BRSR. It is a focused subset of selected KPIs across nine ESG attributes, designed to improve the reliability and comparability of important sustainability information. SEBI introduced the BRSR Core framework in July 2023, with the following original glide path:

The nine ESG attributes are: greenhouse gas footprint; water footprint; energy footprint; embracing circularity; enhancing employee well-being; enabling gender diversity; enabling inclusive development; fairness in customer relationships; and open business. The framework also introduced metrics designed to improve comparability, including intensity measures and, where applicable, PPP-adjusted economic-value intensity measures.

Assessment and assurance

The original July 2023 framework prescribed reasonable assurance of BRSR Core according to the phased applicability. SEBI subsequently introduced changes to assessment/assurance terminology and implementation, so organizations should work from the latest applicable SEBI regulations, circulars and guidance. SEBI's 2025 FAQ also clarifies that the LODR framework does not prescribe one specific global assurance standard: assurance providers may use an appropriate globally accepted sustainability or non-financial reporting assurance standard, with the standard used being disclosed.

Industry standards

SEBI has supported standardization through the Industry Standards Forum (ISF)—representatives of ASSOCHAM, CII and FICCI under the aegis of the stock exchanges—which formulated industry standards in consultation with SEBI. SEBI issued a circular on Industry Standards on Reporting of BRSR Core in December 2024, promoting greater consistency in interpretation and reporting.

9. Value-Chain Disclosures

The original July 2023 BRSR Core framework proposed ESG disclosures for upstream and downstream value-chain partners cumulatively covering 75% of purchases and sales by value. SEBI subsequently relaxed this. Under the March 28, 2025 position described in SEBI's FAQ:

• Value-chain ESG disclosures for the top 250 listed entities are voluntary from FY 2025–26.
• Associated third-party assessment or assurance is also voluntary.
• In-scope partners are identified using a 2% or more individual purchases/sales threshold, with an option to limit disclosure to partners cumulatively covering 75% of purchases/sales by value.

Even where disclosure is voluntary, organizations may collect value-chain information—energy, GHG emissions, water, waste, employee information, health and safety, gender diversity, human rights, social impact and customer-related information—for internal sustainability management. A digital platform can provide partners with structured questionnaires while keeping a clear distinction between company data and value-chain partner data, which is particularly important for Scope 3 emissions.

Green Credits

SEBI introduced an additional voluntary Leadership Indicator under Principle 6 covering Green Credits generated or procured by the listed entity and its top ten value-chain partners (by value of purchases and sales). It should not be confused with the mandatory core environmental metrics.

10. Cross-Referencing Other Sustainability Reports

SEBI's BRSR guidance permits entities using internationally accepted frameworks such as GRI, SASB, TCFD or Integrated Reporting to cross-reference relevant disclosures to BRSR requirements, and to cross-reference information already disclosed in the annual report rather than reproduce it. This is highly relevant for a unified sustainability-data architecture.

11. Data Quality and Evidence

BRSR reporting should not be treated as a simple questionnaire. A reliable process establishes:

• Data ownership – every metric has a responsible department or person.
• Source identification – the organization knows where each number originated.
• Evidence – supporting records are retained.
• Calculation methodology – formulas and assumptions are documented.
• Boundary consistency – the reporting boundary stays consistent, or changes are explained.
• Review and approval – data is reviewed and approved by management before reporting.
• Audit trail – changes to important information are traceable.

This becomes particularly important for BRSR Core metrics subject to third-party assessment or assurance.

12. BRSR Data Architecture

BRSR data comes from almost every function: finance (revenue, turnover, capital and operating expenditure, CSR spend), HR (employees, workers, gender, turnover, training, benefits, diversity), EHS (energy, water, waste, emissions, incidents, environmental compliance), procurement (suppliers, value-chain information, responsible sourcing), legal and compliance (regulatory actions, notices, complaints, litigation), IT (cybersecurity, data privacy), sales and customer service (consumer complaints, product information, recalls, customer satisfaction) and the sustainability team (ESG metrics, targets, initiatives and BRSR coordination).

13. Common Preparation Challenges

• Fragmented data spread across departments and systems.
• Manual collection of spreadsheets that consumes considerable time.
• Inconsistent definitions between departments calculating the same indicator.
• Evidence gaps where a reported number lacks retrievable documentation.
• Boundary inconsistencies between reporting teams.
• Calculation errors from manual formulas.
• Version control problems when multiple spreadsheets compete.
• Late approvals close to reporting deadlines.
• Assurance readiness when information is not traceable enough for independent assessment.

14. BRSR and SustainStep

A platform such as SustainStep can position BRSR as one part of a broader sustainability data architecture. Instead of creating a separate dataset only for BRSR, organizations can maintain a single validated sustainability dataset and map it to multiple frameworks. One validated emissions dataset can potentially support BRSR, BRSR Core, GRI, CDP, TCFD/IFRS S2-related disclosures, internal dashboards and GHG inventories; workforce information can support BRSR, GRI and internal human-capital reporting.

A recommended BRSR workflow

1. Configure – set the financial year, entity structure, reporting boundary and applicable requirements.
2. Assign – allocate questions and data points to responsible departments.
3. Collect – capture data through forms, integrations, spreadsheets, documents and other sources.
4. Extract – use document and data-extraction capabilities to identify relevant information.
5. Validate – check completeness, units, calculations, unusual values and consistency.
6. Evidence – link supporting evidence to individual data points.
7. Review – route information to appropriate reviewers.
8. Approve – obtain required internal approvals.
9. Map – connect validated data with BRSR, BRSR Core and other frameworks.
10. Report – generate the required disclosures.
11. Assess – prepare the dataset and evidence trail for third-party assessment/assurance where applicable.
12. Improve – use the results to identify gaps, targets and improvement opportunities.

15. BRSR Is More Than a Reporting Exercise

The same information can show management where emissions are increasing, where energy efficiency can improve, where water risks exist, where waste performance needs attention, where workforce turnover is high, where safety incidents are concentrated, where diversity gaps exist, where human-rights risks may occur, where customer complaints are increasing and where governance controls need strengthening. This turns BRSR from a compliance exercise into a management intelligence resource.

16. BRSR Readiness Checklist

• Regulatory: applicability and reporting period confirmed; latest SEBI requirements reviewed; applicable BRSR Core requirements identified.
• Organizational: reporting boundary defined; data owners, subsidiaries and relevant operations identified.
• Data: all required indicators collected; consistent units; calculations validated; year-on-year movements checked.
• Evidence: source documents stored and linked to reported data; calculation records and assumptions documented.
• Governance: management review completed; approvals obtained; change history maintained.
• BRSR Core: applicable Core KPIs identified; appropriate methodologies applied; assessment/assurance evidence prepared where applicable.
• Value chain: decision on voluntary disclosure made; relevant partners and coverage of purchases/sales defined where reporting is undertaken.
• Reporting: all applicable Essential Indicators completed; Leadership Indicators considered; existing disclosures cross-referenced; final report reviewed for consistency.

17. BRSR vs BRSR Core

18. Key Regulatory Timeline

The regulatory position should always be checked against the latest SEBI regulations and circulars before a company files its report.

Conclusion

BRSR represents a significant shift in corporate sustainability disclosure in India, establishing a structured framework covering environmental performance, employee and social matters, human rights, stakeholders, responsible products, public policy, inclusive development, consumers and governance. BRSR Core has further increased the importance of reliable, measurable and traceable data, while SEBI's changes to value-chain reporting show that the framework continues to evolve.

Effective BRSR preparation therefore requires a controlled information system in which data has an owner, every important number has a source, calculations have a defined methodology, evidence is retained, information is validated and the final disclosure can be traced back to its underlying records. For SustainStep, this is the opportunity to move BRSR management from fragmented spreadsheets toward a single, validated sustainability intelligence system that supports BRSR, BRSR Core, other frameworks and continuous improvement.

BRSR is the disclosure. The real value is the sustainability intelligence behind the disclosure.

Primary regulatory sources: SEBI LODR Regulations, SEBI BRSR framework, BRSR Core circular, Industry Standards on BRSR Core and SEBI's subsequent FAQs and circulars.

Related SustainStep capabilities: Data Management, Value Chain Assessment and SustainStep AI Engine.