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Business Responsibility & Sustainability Reporting (BRSR) — What to Get Right Before You Start

PNPC Global Content Team·

Key takeaways

  • BRSR has three sections: Section A general disclosures, Section B management and process disclosures, and Section C performance against the nine NGRBC principles.
  • BRSR replaced the narrative Business Responsibility Report and asks for data such as emissions, energy and water use, workforce diversity, safety incidents and CSR spend.
  • BRSR Core came from SEBI's circular dated 12 July 2023, and its assurance glide path widens progressively toward the top 1,000 by FY 2026-27.
  • Unlisted companies with no IPO plan are not currently mandated to file, though value-chain partners may still receive ESG data requests from listed anchor customers.

Business Responsibility & Sustainability Reporting (BRSR) — What to Get Right Before You Start

Business Responsibility and Sustainability Reporting (BRSR) is no longer a voluntary sustainability narrative — it is a mandatory SEBI disclosure, backed by prescribed formats, quantitative KPIs, and for an expanding set of companies, third-party assurance. At PNPC Global, we prepare and assure BRSR and BRSR Core reports the way we approach statutory audit: with primary evidence, documented workpapers, and a defensible position on every disclosed number. For listed companies navigating Section A general disclosures, Section B management processes, Section C principle-wise performance, and the value-chain BRSR Core extension, we bring both ESG subject-matter expertise and the assurance discipline that only a practising CA firm can offer.

What You're Really Buying

Business Responsibility and Sustainability Reporting (BRSR) is a standardised ESG (Environmental, Social, Governance) disclosure format prescribed by the Securities and Exchange Board of India (SEBI) under Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. Introduced via SEBI circular dated 5 May 2021, BRSR replaced the earlier Business Responsibility Report (BRR) format and became mandatory, on a comply-or-explain basis initially, for the top 1,000 listed companies by market capitalisation from financial year 2022-23 onwards. The report is structured in three sections: Section A covers general entity disclosures (products, operations, employees, CSR, and stakeholder engagement); Section B covers management and process disclosures (policies, governance oversight, and grievance redressal aligned to each of the nine NGRBC principles); and Section C requires principle-wise quantitative and qualitative performance disclosures against the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), 2018, issued by the Ministry of Corporate Affairs.

For the full scope, current process and what PNPC includes, see the dedicated Business Responsibility & Sustainability Reporting (BRSR) service page.

Is This Relevant to Your Business?

  • Listed company falling within SEBI's top 1,000 by market capitalisation — BRSR filing as part of the Annual Report is mandatory under Regulation 34(2)(f) of SEBI LODR
  • Listed company falling within SEBI's phased BRSR Core assurance cohort (beginning with the top 150 by market cap for FY 2023-24, widening progressively toward the top 1,000 by FY 2026-27 per SEBI's notified glide path) — independent reasonable assurance on the BRSR Core KPIs is mandatory and the assurance report must be filed with stock exchanges
  • Company preparing for an IPO on the main board — BRSR/ESG disclosure readiness is now routinely examined in pre-IPO governance and disclosure diligence even before the entity formally enters SEBI's market-cap-based mandate
  • Significant value-chain partner (supplier or customer) that has received an ESG data request from an anchor listed company reporting BRSR Core value-chain disclosures — even though not directly regulated, the practical need to respond with credible, assurable data is real

When It Isn't the Right Fit

  • Unlisted private company with no near-term IPO plan, no ESG-linked financing, and no anchor-customer ESG data request — a full BRSR-format report is not currently mandated and a lighter internal ESG readiness assessment may be more proportionate
  • You need only a one-off carbon footprint estimate for internal awareness or a marketing claim, not a regulatory filing — a scoped GHG inventory exercise (without the full BRSR structure or assurance) may suffice, though PNPC would flag the greenwashing risk of publicising an unverified claim
  • You need the company's core financial statement audit or tax audit — that remains a separate statutory engagement (Companies Act audit, Income-tax audit) governed by its own standards, timelines, and reporting; BRSR assurance under SEBI's framework is a distinct scope

Common Questions

What is BRSR — in plain terms?

BRSR (Business Responsibility and Sustainability Report) is a mandatory, standardised ESG disclosure that SEBI requires certain listed companies to file as part of their Annual Report. It replaced the older, narrative-style Business Responsibility Report (BRR) with a structured format that asks for specific quantitative data — emissions, energy and water use, workforce diversity, safety incidents, CSR spend — alongside qualitative disclosures on governance and policy, organised around nine principles of responsible business conduct.

Which companies must file BRSR?

BRSR became mandatory under SEBI LODR Regulation 34(2)(f) for the top 1,000 listed companies by market capitalisation, applicable from financial year 2022-23 onwards. The exact cohort is determined annually based on market capitalisation as of the end of the immediately preceding financial year, as notified by SEBI/stock exchanges. Companies outside this threshold may adopt BRSR voluntarily.

What is BRSR Core, and how is it different from full BRSR?

BRSR Core is not a separate report — it is a defined subset of high-priority, quantifiable KPIs drawn from the full BRSR disclosures, spanning nine ESG attributes (such as GHG emissions, energy and water intensity, employee wellbeing, and workforce representation). SEBI introduced BRSR Core via its circular dated 12 July 2023 and made these specific KPIs subject to mandatory independent reasonable assurance — a requirement that does not currently extend to the entirety of the full BRSR report.

Where PNPC Fits In

Speak directly with a PNPC Chartered Accountant about your BRSR and BRSR Core obligations. Not an ESG narrative-writer. Not a generic compliance vendor. A practising CA firm that treats every disclosed sustainability number with the same evidentiary discipline as a statutory audit figure — because increasingly, that is exactly what SEBI, your investors, and your assurance provider expect it to be.

PNPC Global has advised Chennai, Bangalore and Hyderabad businesses since 1986. Explore the full Risk Advisory practice for related services, or go straight to the Business Responsibility & Sustainability Reporting (BRSR) page for specifics.

Rates, thresholds and filing dates are set by the relevant authority and revised periodically. Treat anything numeric here as "ask PNPC for the current figure," not as a quoted fact.

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