BRSR Reporting — SEBI Compliance for Listed Companies
By CA V. Viswanathan — FCA, ACS, CFE, IBBI Registered Valuer (IBBI/RV/03/2019/12333). Updated for FY 2025-26.
Business Responsibility and Sustainability Reporting (BRSR) is mandatory for the top 1,000 listed companies in India by market capitalisation under SEBI (LODR) Regulations, 2015. Introduced in FY 2022-23 and progressively expanded each year, BRSR replaced the earlier Business Responsibility Report (BRR) and aligned Indian disclosures with global ESG frameworks like GRI, SASB and the TCFD. From FY 2024-25, BRSR Core (a subset of nine attributes assured by an independent reasonable assurance provider) became mandatory for the top 150 listed companies, expanding to top 250 in FY 2025-26 and top 1,000 by FY 2026-27. Value-chain reporting (covering upstream and downstream partners contributing 75% of purchases or sales) is now phased in.
Who Must File BRSR in FY 2025-26
BRSR applies to the top 1,000 listed companies as ranked by market capitalisation on 31 March of the previous financial year. The list is published by NSE/BSE annually. For FY 2025-26 reporting (filed with the FY 2024-25 Annual Report), the top 250 must additionally obtain reasonable assurance on BRSR Core indicators. For FY 2025-26 disclosures (filed in FY 2026-27), the assurance threshold expands to the top 500. Unlisted subsidiaries, associate companies, and joint ventures of listed parents are not directly covered, but their data flows through value-chain reporting. Foreign-listed Indian companies and INVIT/REIT issuers are exempt, but most large-cap PSUs and private-sector blue-chips are squarely within scope.
Structure of the BRSR Format
The BRSR is divided into three sections. Section A captures general disclosures: company overview, products, operations, employees, holding/subsidiary structure, CSR contribution, transparency complaints, and a stakeholder engagement summary. Section B sets out the company's policy and management process against the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC) — covering ethics, product responsibility, employee well-being, stakeholder responsiveness, human rights, environment, public policy, inclusive growth, and consumer protection. Section C contains the principle-wise performance disclosures. Each principle has 'Essential Indicators' (mandatory) and 'Leadership Indicators' (voluntary). It is in Section C that companies disclose Scope 1, Scope 2 and Scope 3 emissions, water consumption, waste data, gender pay ratios, training hours, accessibility infrastructure, supplier audits, complaints under POSH, and other quantitative ESG metrics.
BRSR Core — Reasonable Assurance Required
BRSR Core is a defined subset of nine ESG attributes that must be reported with reasonable assurance from an independent assurance provider (not the statutory auditor). The nine attributes cover: greenhouse gas emissions intensity, water consumption intensity, energy consumption intensity, waste generation intensity, board/KMP gender diversity, gross wages paid to women, employee well-being expenditure, complaint resolution metrics, and turnover from products/services with a positive social/environmental impact. The assurance provider must hold appropriate accreditation; ICAI's Sustainability Reporting Standards Board has issued SSAE 3000-aligned guidance. Material misstatement of a BRSR Core indicator is treated as a disclosure deficiency with consequences under SEBI (LODR) Regulations.
Value-Chain BRSR — Upstream and Downstream Partners
From FY 2024-25, the top 250 listed companies must disclose BRSR Core indicators for their value-chain partners — defined as those contributing at least 2% individually and cumulatively 75% of purchases or sales. This is a comply-or-explain requirement in year one and phased to mandatory thereafter. Practically, this means listed companies must build supplier data-collection systems, vendor onboarding ESG questionnaires, and audit trails. Most companies underestimate the IT and process effort. Virtual Auditor's typical implementation engagement begins 4-6 months before the reporting deadline.
Penalties and Consequences
BRSR is filed as part of the listed company's Annual Report. Non-disclosure or material misstatement attracts penalties under Section 23A and 23E of the SEBI Act (₹1 lakh/day, capped at ₹1 crore per offence) and disclosure-related directives from SEBI. Stock exchanges may issue show-cause notices, levy fines, and refer matters to SEBI's adjudication officer. Independent directors carry personal accountability under SEBI (LODR) Regulation 17 for the integrity of disclosures. ESG-rating downgrades by agencies like CRISIL, MSCI, S&P Global, and Sustainalytics typically follow disclosure deficiencies and affect cost of capital — institutional investors with ESG mandates may exit the stock.
Implementation Roadmap
Step 1 — Map applicability and identify which BRSR principles are most material to your sector (use SASB sector standards as a starting point). Step 2 — Set up data ownership: each principle should have an internal owner (Head of HR for principles 3 and 5, Head of Operations for principle 6, etc.). Step 3 — Build the data architecture (ERP integrations, supplier portals, GHG accounting tools — EcoVadis, Sphera, Persefoni). Step 4 — Conduct a baseline materiality assessment with stakeholder consultation. Step 5 — Draft Section B policy disclosures. Step 6 — Compile Section C quantitative data with audit trails. Step 7 — Engage a reasonable assurance provider for BRSR Core. Step 8 — Board review and inclusion in Annual Report. Virtual Auditor offers end-to-end BRSR implementation as a fixed-fee engagement.
How Virtual Auditor Delivers This
Virtual Auditor's CA-CS-IBBI Valuer team handles brsr reporting — sebi compliance for listed companies as an integrated engagement — no hand-offs between firms, single point of accountability, fixed-fee transparency. CA V. Viswanathan (FCA, ACS, CFE, IBBI RV) personally reviews every engagement deliverable. Offices in Chennai, Bangalore, and Mumbai serve clients across India. Free 30-minute scoping consultation available — no obligation.
Get Started — Free Consultation
Call +91 99622 60333 or email support@virtualauditor.in to schedule a free 30-minute consultation with CA V. Viswanathan. No obligation. We will give you a clear scope, timeline, and fixed-fee quote within 24 hours of the call.
Frequently Asked Questions
Is BRSR mandatory for unlisted companies?
No. BRSR is mandatory only for the top 1,000 listed companies on BSE/NSE by market cap. However, unlisted subsidiaries of these companies must contribute data through value-chain reporting, and many large unlisted companies voluntarily publish BRSR-aligned reports to attract institutional investment.
Who can provide reasonable assurance for BRSR Core?
An independent assurance provider with appropriate professional qualifications (typically a member firm of ICAI, ICSI, or an accredited ESG assurance firm). The assurance provider must be independent of the statutory auditor and the company. ICAI has issued specific guidance under SSAE 3000.
What are Scope 1, 2 and 3 emissions in BRSR?
Scope 1: direct emissions from owned sources (company vehicles, on-site fuel combustion). Scope 2: indirect emissions from purchased electricity, steam, heating, cooling. Scope 3: all other indirect emissions across the value chain — purchased goods, employee commuting, business travel, downstream product use. BRSR Core requires Scope 1 and Scope 2 intensity disclosure with reasonable assurance; Scope 3 is part of leadership indicators.
How is the top 1,000 list determined?
By average market capitalisation of the previous financial year as published by NSE and BSE. The list is updated annually. A company falling out of the top 1,000 may continue voluntary disclosure but is no longer mandated.
What is the difference between BRSR and BRR?
BRR (Business Responsibility Report) was the predecessor framework, voluntary then mandatory for top 100/500/1000 companies under different phases. BRSR replaced BRR from FY 2022-23 with significantly expanded quantitative disclosures (Section C), alignment with global ESG frameworks, and the introduction of BRSR Core with assurance.
Are CSR-related disclosures part of BRSR?
Yes. Section A captures CSR contribution and amount spent. Principle 8 (inclusive growth) under Section B/C details CSR activities, beneficiaries, and impact. BRSR consolidates the previously fragmented CSR and sustainability disclosures.
What is value-chain reporting under BRSR?
Disclosure of BRSR Core indicators for upstream and downstream partners contributing 2%+ individually and 75% cumulatively of purchases/sales. Phased: comply-or-explain in year one, mandatory thereafter. Requires supplier data collection systems.