BRSR reporting: a complete guide to SEBI's Business Responsibility and Sustainability Report

The Business Responsibility and Sustainability Report (BRSR) is how India's largest listed companies disclose their environmental, social and governance performance. This guide explains who must file it, what it contains, how BRSR Core and assurance fit in, and how to build a reporting process that holds up year after year.

What the BRSR is

The Securities and Exchange Board of India (SEBI) introduced the BRSR in 2021 to replace the older Business Responsibility Report. It became mandatory for the top 1,000 listed companies by market capitalisation from the 2022-23 financial year, after a voluntary year in 2021-22. It is filed as part of the annual report.

The BRSR is built on the National Guidelines on Responsible Business Conduct (NGRBC), which set out nine principles. That foundation matters: the report is not only a list of metrics but a statement of how the business manages its responsibilities to employees, communities, customers and the environment.

Compared with its predecessor, the BRSR asks for far more quantitative data. Energy, water, emissions and waste are reported as numbers with intensity ratios, and many indicators require two years of figures so readers can see the trend.

How the report is structured

The BRSR has three sections.

• Section A, general disclosures: details of the company, its products and operations, employees, holding and subsidiary companies, CSR and transparency, including complaints from stakeholders.
• Section B, management and process disclosures: the policies, governance structures and oversight the company has in place for each of the nine principles.
• Section C, principle-wise performance: indicators for each principle, split into essential indicators that every company must report and leadership indicators that are voluntary.

The nine principles cover ethics and transparency, sustainable and safe products, employee well-being, stakeholder engagement, human rights, the environment, responsible public policy advocacy, inclusive growth, and consumer responsibility. Principle 6 on the environment carries most of the quantitative load: energy consumption, water withdrawal and discharge, air emissions, Scope 1 and Scope 2 greenhouse gas emissions, waste generated and how it is managed, and intensity metrics per rupee of turnover.

BRSR Core and assurance

In 2023 SEBI introduced BRSR Core, a subset of key performance indicators selected because they are measurable and verifiable. It covers areas such as greenhouse gas footprint, water footprint, energy footprint, circularity and waste, employee well-being and safety, gender diversity, inclusive development, fairness in engaging with customers and suppliers, and openness of business.

BRSR Core indicators need independent third-party review, phased in by market capitalisation: the top 150 listed entities from FY 2023-24, the top 250 from FY 2024-25, the top 500 from FY 2025-26 and the top 1,000 from FY 2026-27. FY 2026-27, which began on 1 April 2026, is the current reporting year, so the full top 1,000 are now in scope.

SEBI's circular of March 2025 changed two things. Companies may now choose between a third-party assessment and reasonable assurance of BRSR Core. Value chain disclosures became voluntary for the top 250 listed entities from FY 2025-26, and their assessment or assurance is voluntary from FY 2026-27. The value chain is limited to partners that each make up at least 2 percent of purchases or sales, and disclosure can stop once 75 percent of each is covered. Each company should confirm its obligations against the latest SEBI circular for its reporting year.

The practical consequence is the same whichever route applies: the numbers in your BRSR need a clear audit trail. An assurance provider will ask how each figure was calculated, which source documents support it, who approved it and whether the methodology was applied consistently.

Where companies struggle

Most first-time reporters find that the hardest part is not writing the report but collecting reliable data from across the organization. Common problems include:

• Data spread across plants, departments and spreadsheets, with no single owner for each indicator.
• Different units and conversion factors used by different sites, which makes consolidation error-prone.
• Scope 2 emissions calculated with outdated grid emission factors.
• Employee and safety data held by HR and EHS teams in formats that do not match the BRSR tables.
• Value chain data that suppliers have never been asked to provide.
• No record of who checked a number or what evidence supports it, which slows down assurance.

These are process problems, so they are solved by process: clear ownership, consistent methods and a system that keeps evidence next to the data.

A step-by-step plan to prepare your BRSR

1. Map every BRSR indicator to an owner, a data source and a calculation method. A simple matrix of indicator, owner, source, frequency and method is the backbone of the whole process.
2. Run a gap assessment against the previous year. Identify indicators that were estimated, missing or inconsistent, and decide how to close each gap.
3. Standardise units and emission factors across sites. Document the factors you use for fuels, electricity and refrigerants, and their sources.
4. Collect data monthly or quarterly, not once a year. Year-end collection compresses all the checking into a few weeks and leaves no time to fix errors.
5. Attach evidence at the point of entry: invoices, meter readings, HR registers and waste manifests.
6. Review and approve each data point before consolidation, with a recorded reviewer.
7. Draft the narrative sections early, using the policies and governance structures already in place, and update them as the numbers come in.
8. Prepare an assurance pack for BRSR Core indicators with calculations, sources and approvals in one place.

Linking BRSR with other frameworks

Many Indian companies also report to CDP, follow GRI, respond to customer questionnaires or prepare for IFRS S1 and S2. The BRSR overlaps with all of these. Greenhouse gas data follows the GHG Protocol, many social indicators resemble GRI disclosures, and climate governance questions echo the TCFD and IFRS S2.

Collecting data once and mapping it to several frameworks saves significant effort. A good framework mapping also reduces the risk of reporting different numbers for the same metric in different places, which is one of the first things investors and assurers notice.

How NCV helps

Our consultants run BRSR gap assessments, set up indicator ownership and methods, and prepare the report and assurance pack. SustainOS then turns that design into a repeatable process: each department enters its data with evidence attached, approvals are recorded, emissions are calculated automatically, and the BRSR tables are produced from the same validated data that feeds your other disclosures.