SEBI's BRSR: What Every CFO in India Needs to Know Before the Deadline

If you are a CFO of a listed company in India and BRSR is still sitting somewhere in your "to-do later" pile, this is your wake-up call. The Business Responsibility and Sustainability Reporting (BRSR) framework is no longer a future obligation or a box-ticking exercise for your sustainability team. It is a regulatory mandate with teeth — and the deadlines are already here.

This guide breaks down everything a CFO needs to know: what BRSR is, who it applies to, what you must disclose, and how to stay ahead of an increasingly stringent compliance curve.

What Is BRSR, and Why Did SEBI Introduce It?

BRSR stands for Business Responsibility and Sustainability Reporting. Introduced by SEBI in May 2021 and made mandatory from FY 2022–23, it replaced the older Business Responsibility Report (BRR), which was widely criticized for being too qualitative, inconsistent, and impossible to compare across companies.

BRSR changed all of that. It demands standardized, quantitative, and auditable disclosures on how your company performs on environmental, social, and governance (ESG) parameters—not in vague narrative form, but in hard numbers.

SEBI designed the framework to bring Indian companies in line with global sustainability standards, including the Global Reporting Initiative (GRI), the UN Global Compact, and the UN Sustainable Development Goals. For foreign institutional investors and ESG-focused funds, BRSR disclosures are increasingly a prerequisite before they even look at your financials.

Who Must Comply — and When?

This is where many CFOs get caught off guard. BRSR applicability is not static. It expands every year.

The top 1,000 listed companies by market capitalization have been required to file full BRSR reports as part of their annual report since FY 2022–23. The ranking is calculated based on market capitalization as of March 31 each year. If your company moves into the top 1,000, compliance kicks in immediately.

Beyond the base BRSR, SEBI introduced the BRSR Core — a more stringent subset of approximately 49 Key Performance Indicators (KPIs) that require third-party verification. The rollout is phased:

• FY 2023–24: BRSR Core mandatory for the top 150 listed companies

  
  

• FY 2024–25: BRSR Core mandatory for the top 500 listed companies, with voluntary value chain disclosures for the top 250

  
  

• FY 2025–26: BRSR Core mandatory for the top 1,000 listed companies; value chain disclosures become mandatory for the top 250

  
  

• FY 2026–27: Third-party assessment or assurance on value chain ESG disclosures becomes mandatory for the top 250 companies

  
  

In December 2024, SEBI also issued industry standards for BRSR Core reporting—developed by the Industry Standards Forum (ISF) comprising ASSOCHAM, FICCI, and CII—applicable from FY 2024–25 onwards. These standards are not optional guidance. They are the benchmark against which your disclosures will be evaluated.

What Does BRSR Actually Require You to Disclose?

The BRSR framework is organised into three sections:

Section A — General Disclosures: Basic company information, business activities, number of employees, locations, regulatory compliance, and CSR details.

Section B — Management and Process Disclosures: Your policies, processes, and governance structures for responsible business conduct across nine principles of the National Guidelines on Responsible Business Conduct (NGRBC).

Section C — Principle-wise Performance Disclosures: This is where the real data lives. Companies must report on 98 Essential Indicators (mandatory) and 42 Leadership Indicators (voluntary)—covering everything from energy consumption, greenhouse gas emissions, water usage, and waste management to employee diversity, human rights practices, community engagement, and board governance.

For BRSR Core specifically, the framework zeroes in on nine key ESG attributes — including GHG footprint, water footprint, energy consumption, circular economy metrics, diversity ratios, and governance — across roughly 30 mandatory data points that must be verified by an accredited third party.

Filing format matters too. All disclosures must be embedded in your annual report (Form MGT-7) and filed in XBRL format with the stock exchanges.

The Value Chain Dimension: A New Layer of Complexity

One of the most significant — and least understood — additions in the BRSR 2023 update is the requirement for value chain ESG disclosures. This means your reporting obligations now extend beyond your own operations to include your major suppliers and customers.

Specifically, for the top 250 companies, this covers upstream and downstream partners who individually account for 2% or more of your total purchases or sales by value (or those collectively covering 75% of your procurement and sales value).

For FY 2024–25, this was voluntary. From FY 2025–26, it is mandatory. From FY 2026–27, a third-party assessment of these disclosures will also be required.

For a CFO, this means vendor data governance is no longer just an operational issue — it is a regulatory one. You will need to build systems to collect ESG data from your supply chain partners and ensure they can provide it accurately and on time.

What CFOs Must Do Right Now

If you are reading this and your BRSR strategy is still reactive, here is a practical action checklist:

1. Determine your applicability tier. Confirm your company's market capitalisation ranking and which phase of BRSR Core applies to you this financial year.

2. Conduct a data gap assessment. Map out which of the 49 BRSR Core KPIs you can currently report with accuracy and which require new data collection systems — especially for environmental metrics like Scope 1, 2, and 3 emissions.

3. Establish cross-functional ownership. BRSR is not just a finance report. It requires inputs from HR, operations, legal, procurement, and facilities. Assign clear ownership with a reporting calendar.

4. Engage your value chain now. If you are in the top 250 by market cap, do not wait until FY 2025–26 to approach your vendors. Many of them will struggle to provide ESG data without preparation time.

5. Commission third-party assessment early. Whether your statutory auditor or an SEBI-accredited assessment provider, engage them before Q3 of the financial year — not in March.

6. Review the December 2024 Industry Standards. The ISF standards on BRSR Core are now the reference point for intensity ratio calculations (GHG, water, energy, waste), PPP-adjusted revenue metrics, and output-based reporting. Your team needs to be aligned with these standards immediately.

The Cost of Non-Compliance

SEBI does not treat BRSR as a soft obligation. Non-filing or inadequate disclosures can attract penalties under the SEBI (LODR) Regulations, 2015, including fines, exchange-level scrutiny, and reputational risk in the eyes of institutional investors and ESG rating agencies.

Beyond penalties, there is a growing commercial cost to non-compliance. ESG-focused investors — both domestic and foreign — increasingly screen out companies with poor or absent sustainability disclosures. Your BRSR report is, in many ways, your sustainability credit score in the capital markets.

BRSR Is a Strategic Opportunity, Not Just a Compliance Burden

The CFOs who will get ahead of this are not the ones who treat BRSR as an annual filing exercise. They are the ones who recognize that structured ESG disclosure improves internal decision-making, reduces regulatory risk, builds investor confidence, and strengthens their company's license to operate in communities where they work.

At Sustina, we work with corporates and their implementation partners to build robust BRSR and ESG reporting systems — from data collection frameworks and third-party assessments to full sustainability reporting under BRSR Core. If your organization needs a credible, structured partner for this journey, we are here.

Frequently Asked Questions (FAQs)

Q1. Is BRSR mandatory for all listed companies in India?

BRSR in its full form is currently mandatory for the top 1,000 listed companies by market capitalization. However, SEBI encourages all listed companies to adopt BRSR reporting voluntarily, regardless of their size or ranking. Companies outside the top 1,000 can still benefit significantly from voluntary disclosures in terms of investor confidence and ESG ratings.

Q2. What is the difference between BRSR and BRSR Core?

The full BRSR requires disclosures across 140 indicators (98 essential, 42 leadership) covering all nine NGRBC principles. BRSR Core is a more focused subset of approximately 49 KPIs—specifically designed for third-party verification. Think of BRSR as your comprehensive sustainability disclosure and BRSR Core as the audited highlight reel that investors and regulators scrutinize most closely.

Q3. When is the BRSR filing deadline each year?

BRSR disclosures must be submitted as part of the company's annual report. For companies following the standard April–March financial year, the annual report—and therefore the BRSR filing—must be submitted within 60 days of the Annual General Meeting (AGM), which typically means filings fall around June to September each year.

Q4. Who can provide assurance or assessment for BRSR Core disclosures?

Following SEBI's December 2024 update, companies can choose between "assurance" (by their statutory auditor) or "assessment" (by an SEBI-accredited third-party provider). The earlier strict requirement of reasonable assurance has been softened to give companies more flexibility while maintaining credibility. The ISF is developing detailed assessment standards to guide this process.

Q5. Does BRSR apply to subsidiaries of listed companies?

A subsidiary that independently ranks among the top 1,000 listed entities by market capitalization is required to prepare its own standalone BRSR report. The holding company is not automatically required to prepare a BRSR on the subsidiary's behalf. However, consolidated sustainability reporting is a good practice that is gaining traction.

Q6. What happens if my company is not in the top 1,000 this year but was last year?

Once you drop below the top 1,000, BRSR reporting is no longer mandatory, though you may continue voluntarily. However, given that rankings shift annually, it is advisable to maintain your reporting infrastructure so you can resume mandatory compliance swiftly if your ranking improves.

Q7. What is value chain reporting under BRSR, and are we required to do it?

Value chain reporting requires companies to disclose ESG performance data for their major suppliers and customers — specifically those accounting for 2% or more of total purchases or sales. For the top 250 companies by market cap, this became mandatory from FY 2025–26. Third-party assessment of these disclosures will be required from FY 2026–27.

Q8. How is BRSR different from GRI or other global ESG frameworks?

BRSR is India-specific and regulated by SEBI, making compliance non-negotiable for listed companies. Global frameworks like GRI, TCFD, and ISSB's IFRS Sustainability Standards are voluntary for most Indian companies. SEBI has designed BRSR to be broadly aligned with these global standards, so companies reporting under BRSR are largely prepared for international ESG disclosures as well — but the two are not identical.

Q9. Can Sustina help our company with BRSR compliance?

Yes. Sustina offers end-to-end ESG and BRSR advisory services—including data gap assessments, BRSR Core KPI framework design, value chain ESG data collection, sustainability reporting, and third-party assessment coordination. We work with companies across Mumbai and Pune and across India to build credible, audit-ready BRSR systems. Book a free consultation with our team.

Sustina Solutions is a leading CSR and ESG consulting firm based in Mumbai, helping companies and NGOs build measurable, credible, and compliant sustainability strategies. For advisory support on BRSR, ESG reporting, and impact measurement, contact us here.