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Regulatory Framework · India

India's BRSR, and why it reaches your business

SEBI requires large listed companies to publish a Business Responsibility and Sustainability Report, with a core set of its metrics subject to external assessment or assurance. Suppliers are not filers — but that external check is what turns a listed company's disclosure into a data request pointed at you.

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Summary for orientation only, current at the review date above. SEBI has revised BRSR Core and the value-chain requirements more than once — confirm anything load-bearing against current SEBI circulars or a qualified adviser.

The short version
  • BRSR binds large listed companies, ranked by market capitalisation — not by revenue or headcount.
  • An SME does not file one and cannot be in breach of it. You are not an addressee.
  • BRSR Core is the externally checked subset — assessment or assurance since SEBI's March 2025 framework. That check is why estimates get harder to defend, and why you get asked.
  • It is much broader than climate: nine principles covering employment, human rights, consumers and community as well as environment.
  • What a supplier is asked for is energy, emissions, waste, water and workforce — VSME B3, B7, B6, B8.

What the BRSR is

The Business Responsibility and Sustainability Report is a disclosure format mandated by SEBI, India's securities regulator, for large listed companies. It replaced the earlier Business Responsibility Report and is filed as part of the annual report.

Its spine is the nine principles of the National Guidelines on Responsible Business Conduct — ethics and transparency, product safety, employee wellbeing, stakeholder responsiveness, human rights, environment, public policy engagement, inclusive growth and consumer value. That breadth is worth registering: BRSR is not a climate framework with extras. Climate is one principle among nine, and an Indian supplier questionnaire will often spend more of its length on employment practice than on emissions.

Who files, and who does not

The obligation attaches to listed companies, selected by market capitalisation rank — introduced for the top 1,000 listed companies. This is a listing-based test, which has two consequences readers often miss: a very large unlisted company is not caught, and a listed company outside the ranked group is not caught either.

If your business is not listed, BRSR does not address you. You do not file one, and you cannot be in breach of it. What reaches you is a request from a customer who does file — commercial rather than regulatory, but backed by a disclosure they have to stand behind.

BRSR Core, and why the external check changes the ask

BRSR Core is a defined subset of key performance indicators that SEBI singled out for external checking rather than pure self-declaration. Since SEBI's March 2025 framework the requirement is expressed as assessment or assurance — a lower and more flexible bar than the earlier reasonable-assurance formulation, and one that does not guarantee a provider examines every input.

It still moves the supplier conversation, just less absolutely than a hard assurance mandate would. A figure that a third party may look at is one a procurement team wants a method behind, so sector defaults for supplier inputs get harder to defend. What it does not do is make estimates impossible — a well-documented estimate remains a legitimate answer, which is worth knowing before you promise a customer precision you cannot produce.

Value-chain disclosure sits alongside it and is voluntary: under the same March 2025 framework, BRSR Core value-chain disclosure is voluntary from FY 2025-26, and assessment or assurance of it voluntary from FY 2026-27. So a request reaching you is commercial rather than the by-product of a compulsory filing — worth answering well, because the direction of travel is one-way, but you are not obstructing a legal obligation if you push back on scope. That is a materially different position from Germany, where the due-diligence duty on your customer is real and current.

What they actually ask you for

Strip the covering letter away and a BRSR-driven supplier request is asking for four things. All four are fields in a Passport.

Energy and emissions

Electricity and fuel use, and the Scope 1 and Scope 2 totals from them. VSME B3 — with the factor and its vintage stated so the number can be checked.

Waste

Annual tonnage and how much is diverted rather than disposed of. VSME B7 (resource use, circularity and waste). A rough but honest figure beats a precise invented one.

Water

Withdrawal or consumption where it is metered. VSME B6 — often the easiest of the four to answer and the one most often left blank.

Workforce

Headcount and composition, and safety. VSME B8 and B9 — BRSR's social principles reach further into employment practice than most climate-only regimes do.

For Scope 2, EcoDiligence uses the Ember 2024 Indian grid figure of 0.69 kgCO₂/kWh, reflecting a coal-heavy grid. Note the unit: this is a CO₂-only factor. It excludes methane and nitrous oxide, so the resulting figure is conservative relative to a full CO₂e factor. We disclose that on the profile rather than quietly relabelling the unit — a supplier who can say which factor they used and what it covers is in a much stronger position than one quoting a rounder number from nowhere.

Indian profiles carry an India BRSR Compatible badge alongside VSME. To be exact: that means the data is structured so it maps onto what a BRSR filer asks a supplier for. It is not a BRSR filing — we do not produce one — and nothing here is independently assured.

Common questions

The Business Responsibility and Sustainability Report is a disclosure format mandated by SEBI, India's securities regulator, for large listed companies. It replaced the earlier Business Responsibility Report and is filed as part of the annual report. Its structure follows the nine principles of the National Guidelines on Responsible Business Conduct, covering ethics and transparency, product safety, employee wellbeing, stakeholder responsiveness, human rights, environment, public policy, inclusive growth and consumer value.

Listed companies, identified by market capitalisation rank rather than by revenue or headcount — the requirement was introduced for the top 1,000 listed companies. It is a listing-based obligation: an unlisted company, however large, is not caught, and a listed company outside the ranked group is not caught either.

No. An SME does not file a BRSR and cannot be in breach of the requirement. What reaches an SME is a request from a listed customer that does file one. That request is commercial rather than regulatory — but it is backed by a filing the customer has to make and, for the BRSR Core indicators, may have to have externally assessed or assured.

BRSR Core is a subset of the full report: a defined list of key performance indicators that SEBI singled out for external checking rather than pure self-declaration. Since SEBI's March 2025 framework the requirement is expressed as assessment OR assurance, which is a lower and more flexible bar than the earlier reasonable-assurance formulation — an assurance provider does not necessarily examine every input. It still changes the supplier conversation, because a figure that a third party may look at is one a procurement team wants a method behind, but it does not make estimates categorically impossible.

Because parts of their own disclosure depend on inputs they do not hold. Two things point that way, though neither is a hard mandate on your customer today: BRSR Core indicators are subject to assessment or assurance, which raises the standard of evidence for anything sourced outside the company, and BRSR Core value-chain disclosure is voluntary under SEBI's March 2025 framework from FY 2025-26, with assessment or assurance of it voluntary from FY 2026-27. So a request you receive is commercial rather than the by-product of a compulsory value-chain filing. It is still worth answering well — the direction of travel is one-way — but you are not obstructing a legal obligation if you push back on scope.

No. BRSR is India-specific, built on the National Guidelines on Responsible Business Conduct, and it is considerably broader than climate — it covers employment practice, human rights, consumer issues and community impact alongside environmental metrics. The ISSB baseline is narrower in subject and deeper on climate governance and financial effect. A company can be subject to both, and the two ask overlapping but differently shaped questions.

Use a published national factor and say which one and which year. EcoDiligence uses the Ember 2024 figure of 0.69 kgCO₂ per kWh for India, reflecting a coal-heavy grid. Note that this is a CO₂-only factor: it does not include methane and nitrous oxide, so the resulting Scope 2 figure is conservative relative to a full CO₂e factor. We state that on the profile rather than quietly relabelling the unit.

India is a dedicated Smart Pack. Profiles calculate Scope 1 and Scope 2 on a published Indian grid factor, carry the waste, water and workforce data that BRSR-driven supplier requests ask for, and show an India BRSR Compatible badge alongside VSME. Be precise about what that badge is: the data is structured so it maps onto what a BRSR filer asks a supplier for. It is not a BRSR filing, we do not produce one, and nothing here is independently assured.

The scope, BRSR Core and value-chain positions summarised here were reviewed on August 24, 2026. SEBI has revised the Core attribute list and the value-chain timetable more than once, so specifics should be confirmed against current SEBI circulars. This page is orientation, not legal or accounting advice. SEBI is independent of EcoDiligence.

EcoDiligence ESG Passports are self-reported summaries structured for ESG disclosure workflows. Content is not independently assured. Information aligned with EFRAG VSME and IFRS S2 (ISSB) frameworks does not constitute formal compliance or certification.

Give a figure with a method behind it

Energy, emissions, waste, water and workforce — structured at a permanent link, with the factor and its basis on the record. Free to start.

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