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 is BRSR and where did it come from?
Before BRSR, large listed companies filed a shorter Business Responsibility Report (BRR), whose format SEBI set in Circular CIR/CFD/CMD/10/2015 dated 4 November 2015.
In 2021 SEBI amended Regulation 34(2)(f) of the LODR Regulations (Gazette notification dated 5 May 2021) and then issued Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated 10 May 2021. That circular introduced BRSR with a format and a guidance note. Key points from it:
- BRSR replaced the BRR.
- Filing was voluntary for financial year (FY) 2021-22 and mandatory from FY 2022-23 for the top 1,000 listed companies by market capitalisation.
- Disclosures follow the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC).
- Each principle has essential indicators (mandatory) and leadership indicators (voluntary, though SEBI asks companies to try to report them).
- Companies that already report under frameworks such as GRI, SASB, TCFD or Integrated Reporting may cross-reference those reports.
The BRSR format has three parts: Section A (general disclosures about the company), Section B (management and process disclosures, such as policies) and Section C (principle-wise performance, where the numbers sit).
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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