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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 does Principle 6 ask about climate and the environment?

Principle 6 of the NGRBC says businesses should respect and make efforts to protect and restore the environment. In the BRSR format updated by SEBI in July 2023, its essential indicators ask for:

No.Essential indicator (summary)
1Total energy consumption (in joules or multiples), split by renewable and non-renewable sources, and energy intensity
2Whether any site is a "designated consumer" under the Perform, Achieve and Trade (PAT) scheme
3-5Water withdrawal, consumption, discharge and water intensity; any Zero Liquid Discharge system
6Air emissions other than greenhouse gases (such as NOx, SOx, particulate matter)
7Scope 1 and Scope 2 greenhouse gas emissions and their intensity
8Projects to reduce greenhouse gas emissions
9-10Waste generated, recovered and disposed, by category, and waste intensity
11-13Operations near ecologically sensitive areas, environmental impact assessments, and compliance with environmental law

The leadership indicators (voluntary) include water use in water-stressed areas, Scope 3 emissions and their intensity, biodiversity impacts, business continuity planning, significant environmental impacts from the value chain, and the share of value chain partners assessed on environmental matters. SEBI's circular of 28 March 2025 added an eighth leadership indicator from FY 2024-25: how many Green Credits were generated or procured by the company and by its top ten value chain partners.

So in short: Scope 1 and Scope 2 are essential (mandatory) in BRSR; Scope 3 is a leadership (voluntary) indicator.

How the intensity numbers work

BRSR asks for emissions intensity in more than one form:

  • Per rupee of turnover: total Scope 1 + Scope 2 emissions divided by revenue from operations.
  • Per rupee of turnover adjusted for purchasing power parity (PPP): added in 2023 "for better global comparability". The BRSR Core format divides total Scope 1 + Scope 2 emissions by revenue from operations adjusted for PPP, using a USD/INR PPP rate, with revenue taken from the audited profit and loss statement.
  • Per unit of physical output (optional): for example per tonne of product, per vehicle or per room-night.

The BRSR Core format says greenhouse gas emissions may be measured in line with the GHG Protocol Corporate Accounting and Reporting Standard, and that emission factors can come from IPCC values or actual testing, with any company-specific method disclosed.

Illustrative example (not real data)

A listed manufacturer reports, for one financial year:

  • Scope 1 (fuel burned on site, company vehicles, refrigerant leaks): 12,000 tonnes CO2e
  • Scope 2 (purchased electricity): 18,000 tonnes CO2e
  • Revenue from operations: Rs 1,500 crore

Scope 1 + Scope 2 = 30,000 tonnes CO2e. Intensity per crore rupees of turnover = 30,000 / 1,500 = 20 tonnes CO2e per crore rupees (BRSR asks the figure per rupee, which is 0.000002 tonnes per rupee). No emission factor is used in this step: the factors were already applied when calculating Scope 1 and Scope 2. For the PPP-adjusted ratio, the company would divide by its revenue adjusted using the PPP rate it discloses.

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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