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BRSR and ESG climate reporting in India: what companies must disclose

A plain guide to SEBI's BRSR and BRSR Core: who must file, the Principle 6 climate indicators including Scope 1 and 2 intensity, the assurance glide path, value chain rules, what it means for MSME suppliers, and how ESG reporting differs from CSR.

What changed for value chain disclosures?

The 2023 circular asked the top 250 listed entities to report BRSR Core indicators for their value chain (key suppliers and customers) on a comply-or-explain basis from FY 2024-25, with limited assurance from FY 2025-26. The value chain was defined as partners making up 75% of purchases or sales by value.

The March 2025 circular eased this:

  • Value chain disclosures for the top 250 are now voluntary from FY 2025-26.
  • Assessment or assurance of those disclosures is voluntary from FY 2026-27.
  • The value chain now means upstream and downstream partners that individually make up 2% or more of the company's purchases or sales by value. The company may limit disclosure to partners covering 75% of purchases and sales.
  • In the first year, reporting last year's numbers is voluntary.
  • A company that reports value chain data must say what percentage of its purchases and sales those partners cover.

Sources: SEBI Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562, Business responsibility and sustainability reporting by listed entities (10 May 2021); SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122, BRSR Core: Framework for assurance and ESG disclosures for value chain (12 July 2023); SEBI, Annexure I: Format of BRSR Core (July 2023); SEBI, Annexure II: Updated BRSR format (July 2023); SEBI Circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, Measures to facilitate ease of doing business: assurance or assessment, ESG disclosures for value chain, green credits (28 March 2025); Companies Act, 2013, Section 135 (India Code); Ministry of Corporate Affairs, General Circular No. 14/2021: FAQs on CSR; GHG Protocol Corporate Accounting and Reporting Standard (WRI/WBCSD); EcoVadis Sustainability Rating Methodology disclosure document (2026); CDP Supply Chain programme

This article was prepared with AI assistance and checked by the GreenEye team against the sources shown in each section.

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