Table of Contents
In 2021, India took a historic step that quietly changed the DNA of corporate accountability.
For years, sustainability reports in India were glossy, voluntary, and often inconsistent — filled with aspirations rather than auditable data.
But when SEBI introduced the Business Responsibility and Sustainability Report (BRSR), the story changed.
What was once a CSR narrative became a compliance obligation.
What was once optional storytelling became data-driven, verifiable accountability.
Let’s dive deep into what BRSR really means, how it works, and why it’s transforming India Inc. — from compliance to competitive advantage.
🏛️ 1. The Origin: From BRR to BRSR
🌱 A decade of evolution
| Phase | Regulation | Year | Key Focus |
|---|---|---|---|
| BRR (Business Responsibility Report) | SEBI mandated top 100 listed companies to report on CSR and ethics | 2012 | Voluntary, narrative-driven |
| Expanded BRR | Extended to top 500 companies | 2015 | More disclosures, but no standard metrics |
| BRSR (Business Responsibility & Sustainability Report) | SEBI Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 | 2021 | Quantitative, structured, aligned with GRI/TCFD |
| BRSR Core | SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 | 2023 | Mandatory assurance for 49 KPIs |
The shift was radical:
India went from “tell us your CSR stories” to “show us your sustainability data, prove it, and get it assured.”
🧭 2. The Foundation: NGRBC Principles
BRSR is built on the National Guidelines for Responsible Business Conduct (NGRBC) — a 9-principle framework that defines what “responsible business” means in the Indian context.
| Principle | Theme |
|---|---|
| P1 | Ethics, transparency, and accountability |
| P2 | Sustainable goods and services |
| P3 | Employee well-being |
| P4 | Stakeholder engagement |
| P5 | Human rights |
| P6 | Environment protection |
| P7 | Policy influence responsibly |
| P8 | Inclusive growth and equitable development |
| P9 | Customer value and transparency |
These nine principles serve as the moral and operational compass for Indian corporates — blending environmental, social, and governance (ESG) ethics with India’s development agenda.
📊 3. Structure of BRSR
The BRSR framework is divided into three sections:
🧩 Section A: General Disclosures
Covers company overview, products, operations, and financial footprint.
➡️ Why it matters: establishes organizational boundaries and value chain scope.
⚙️ Section B: Management & Process Disclosures
Explains governance, policies, stakeholder engagement, grievance redressal, and ethics systems.
➡️ Why it matters: shows how sustainability is managed, not just what is measured.
📈 Section C: Principle-wise Performance
Detailed KPIs under each of the 9 principles — now quantitative, comparable, and assurable.
➡️ Why it matters: this is where ESG becomes measurable, auditable, and actionable.
🧾 4. Enter BRSR Core: The Assurance Revolution
In July 2023, SEBI introduced the BRSR Core, tightening the screws on reliability.
For the first time, India’s ESG data had to be verified by external auditors — just like financial numbers.
🔍 Key Features of BRSR Core:
- 49 Key Performance Indicators (KPIs) selected from BRSR — most critical, quantifiable metrics.
- Mandatory limited assurance by an independent third-party auditor.
- BRSR reporting is now mandatory for India’s top 1,000 listed companies by market cap as of 2026-27.
- Scope 3 emissions, supply chain, safety, and diversity metrics included.
🎯 Objective:
To ensure ESG disclosures are consistent, comparable, and credible across companies and sectors.
BRSR Core ensures that what companies disclose in sustainability reports is:
- Quantifiable
- Standardized across sectors
- Externally verified
- Linked to India’s NGRBC principles
🧱 5. The Structure of BRSR Core
The 49 KPIs are grouped across the three ESG pillars — Environmental, Social, and Governance, aligned with the nine principles of the NGRBC.
Let’s decode them 👇
🌿 A. Environmental Indicators (15 KPIs)
(Aligned with Principle 2: Sustainable Goods and Services, and Principle 6: Environment Protection)
These metrics assess how companies use natural resources, manage emissions, and protect ecosystems.
| Category | KPI Focus | Example Metric | Why It Matters |
|---|---|---|---|
| Energy | Total energy consumption (renewable & non-renewable), intensity per ₹ revenue | MWh/₹ crore | Shows energy efficiency & clean energy transition |
| GHG Emissions | Scope 1, 2, and 3 emissions | tCO₂e/year | Core climate accountability metric |
| Water Use | Water withdrawal, recycling rate, intensity | m³/unit output | Measures water stewardship |
| Waste Management | Hazardous & non-hazardous waste generated, recycled | Tonnes/year | Reflects circular economy readiness |
| Renewable Energy | Share of renewable energy in total mix | % | Indicates climate transition commitment |
| Environmental Fines / Penalties | Monetary value of environmental non-compliance | ₹ | Links ESG to financial accountability |
🌍 Example:
UltraTech Cement reports a 14% reduction in specific carbon emissions and 23% use of alternative fuels under BRSR Core, verified by third-party auditors — directly linking data quality to climate strategy credibility.
👥 B. Social Indicators (24 KPIs)
(Aligned with Principles 3–5 & 8–9: Employee Well-being, Human Rights, Inclusive Growth, and Customer Value)
Social KPIs assess how responsibly a company treats its employees, communities, and customers.
| Category | KPI Focus | Example Metric | Why It Matters |
|---|---|---|---|
| Diversity & Inclusion | Women employees in workforce, leadership, board | % women employees | Shows gender equity progress |
| Health & Safety | Lost Time Injury Frequency Rate (LTIFR), fatalities | Cases per million hours | Critical for workforce well-being |
| Training & Development | Average training hours per employee | Hours/year | Measures employee empowerment |
| Wages & Benefits | % of employees paid at or above minimum wage | % | Social equity and ethical practices |
| Grievance Redressal | Number and resolution rate of employee grievances | % resolved | Measures workplace culture & governance |
| Contract Labor Data | % of contract workforce covered under benefits | % | Reflects fair treatment and compliance |
| Community Investment | CSR spend as % of profit, beneficiaries reached | ₹ crore, people impacted | Shows commitment to SDG-linked outcomes |
| Human Rights & Supply Chain | Suppliers screened for human rights and ESG criteria | % | Extends ESG accountability beyond corporate walls |
| Customer Safety & Privacy | Product recalls, data breaches | Count | Protects brand trust and consumer value |
💡 Example:
Apollo Hospitals links energy efficiency with health outcomes: better climate control in operating theatres led to 23% fewer infections — a real example of ESG translating into impact.
⚖️ C. Governance Indicators (10 KPIs)
(Aligned with Principles 1, 7 & 9: Ethics, Transparency, and Responsible Policy Influence)
Governance KPIs evaluate integrity, oversight, and accountability at the board and leadership levels.
| Category | KPI Focus | Example Metric | Why It Matters |
|---|---|---|---|
| Board Diversity | % of independent & women directors | % | Strong proxy for ethical oversight |
| ESG Committee | Presence & frequency of ESG committee meetings | Count/year | Measures governance commitment |
| CEO Pay Ratio | CEO pay vs. median employee pay | Ratio | Indicator of fairness and equity |
| Whistle-blower Mechanism | Complaints received, resolved, and pending | % resolved | Tests corporate ethics in practice |
| Policy Advocacy Disclosure | Political contributions or lobbying | ₹ | Ensures transparency in influence |
| Tax Transparency | Country-wise tax paid | ₹ crore | Emerging global metric of fair play |
| Cybersecurity Incidents | Number of breaches, impact | Count | Links governance with resilience |
| ESG-linked Compensation | Share of variable pay tied to ESG goals | % | Drives accountability through incentives |
🏢 Example:
Vedanta added an independent ESG committee and started publishing live dashboards of safety incidents and emissions.
Their transparency helped regain investor confidence, upgraded ESG ratings (BB → BBB), and attracted new ESG funds.
⚖️ 6. The Legal & Governance Shift
Under BRSR Core, ESG data isn’t just “soft” disclosure anymore — it carries legal accountability.
Boards and CFOs are now directly responsible for ESG assurance quality, just as they are for financial statements.
Key legal implications:
- Companies Act, 2013: Directors must ensure a true and fair view of financial and non-financial disclosures.
- SEBI (LODR) Regulations: Misreporting or omissions in BRSR can attract fines up to ₹1 crore.
- RBI Guidelines: Banks and NBFCs must assess climate and ESG risks in lending decisions.
In essence, bad ESG data = regulatory risk.
Boards now need directors with ESG literacy and audit committees with sustainability oversight.
🧠 7. How to Become BRSR-Ready: A Practical Roadmap
| Stage | Key Actions | Tools / Enablers |
|---|---|---|
| 1. Gap Assessment | Map current ESG disclosures vs. BRSR Core KPIs | Internal Audit, ESG Consultant |
| 2. Data Architecture | Build centralized ESG database | SAP, IBM Envizi, ESG Data Warehouse |
| 3. Governance Setup | Define ownership for each KPI | ESG Committee, Data Owners |
| 4. Assurance Planning | Engage auditors early | Limited assurance scope definition |
| 5. Integration with Strategy | Align ESG KPIs with business goals | Balanced Scorecard, SBTi targets |
| 6. Continuous Monitoring | Use dashboards, analytics | Power BI / Tableau ESG dashboards |
| 7. Stakeholder Communication | Publish integrated, GRI-mapped reports | Investor Relations & Sustainability Teams |
📈 8. Challenges Companies Face
| Challenge | Impact | How to Overcome |
|---|---|---|
| Data fragmentation | Inconsistent ESG metrics | Create one ESG data platform |
| Lack of ESG-skilled auditors | Delayed assurance | Build internal pre-assurance team |
| Scope 3 complexity | Underreporting supply chain emissions | Phased data collection & estimation models |
| Cultural resistance | ESG seen as extra work | Link ESG KPIs to leadership incentives |
🌟 9. Why BRSR Is India’s ESG Turning Point
Unlike many global ESG frameworks that evolved from the West, BRSR is Indian by design and global in ambition.
It aligns with:
- GRI Standards (impact materiality)
- TCFD (climate financial disclosure)
- ISSB / IFRS S2 (sustainability reporting)
And crucially, it brings ESG accountability under SEBI’s regulatory net — making it mandatory, standardized, and investor-grade.
💬 10. The Bigger Picture: ESG as an Economic Strategy
BRSR is not just compliance — it’s India’s entry ticket to the global sustainable capital market.
Already, ESG-themed AUM in India has crossed ₹15,000 crore and growing.
Global investors now assess Indian companies through the BRSR Core lens before investing.
Companies that master ESG data today will access:
- Cheaper capital (through green and sustainability-linked bonds)
- Better valuations (ESG index inclusion)
- Stronger trust (with regulators, customers, and employees)
❤️ Final Takeaway
The BRSR isn’t about filling forms — it’s about building trust with data.
It’s a wake-up call for Indian corporates to move from “compliance mode” to “competitive mode.”
As companies like HDFC Bank, L&T, and Vedanta have shown — when ESG reporting is done right, it doesn’t slow you down; it accelerates you.
The winners in India’s next decade of growth won’t be those who just meet SEBI’s requirements —
They’ll be the ones who use ESG data to build smarter systems, attract better capital, and earn deeper trust.
Read more blogs on sustainability here.
🔗 Reference links
- SEBI circular on BRSR Core — assurance & ESG disclosure for value chain:
🔗 https://www.sebi.gov.in/legal/circulars/jul-2023/brsr-core-framework-for-assurance-and-esg-disclosures-for-value-chain_73854.html Securities and Exchange Board of India - SEBI January 2025 update: key changes in BRSR reporting & industry standards:
🔗 https://assets.kpmg.com/content/dam/kpmgsites/in/pdf/2025/01/firstnotes-sebi-introduces-certain-key-changes-in-brsr-reporting.pdf.coredownload.inline.pdf KPMG Assets - Government of India: National Guidelines on Responsible Business Conduct (NGRBC) — nine principles of responsible business:
🔗 https://iica.nic.in/sob_ngrb.aspx IICA+2Human Rights+2 - IndiaBriefing article summarizing recent changes in BRSR ESG disclosures & industry standards:
🔗 https://www.india-briefing.com/news/brsr-reporting-in-india-key-changes-to-esg-disclosures-introduced-by-sebi-36261.html India Briefing - Linkage document between global ESG standards (e.g. Global Reporting Initiative) and BRSR framework:
🔗 https://www.globalreporting.org/media/ioqnxtmx/sebi_brsb_gri_linkage_doc.pdf