Business Responsibility and Sustainability Report (BRSR) and ESG - MMJC

  • Assess: Assessment of current level of compliance and benchmarking with Industry standards.
  • Implement: Support in implementation of ESG framework to equip and enable Company to comply with necessary requirements well in time
  • Report: Accurate reporting in line with regulatory requirement

1. What is BRSR Core?

BRSR Core is a sub-set of the BRSR, consisting of 40+ Key Performance Indicators (KPIs)/metrics under 9 ESG attributes — Greenhouse Gas footprint, Water footprint, Energy footprint, Embracing Circularity (Waste Management), Employee Wellbeing and Safety, Enabling Gender Diversity in Business, Enabling Inclusive Development, Fairness in Engaging with Customers and Suppliers, and Openness of Business — for which companies must obtain independent third-party verification.

BRSR Core was introduced by SEBI vide circular dated 12 July 2023 to provide for phased applicability of assurance for BRSR Core by listed companies. Since SEBI’s circular dated 28 March 2025, listed entities can choose between two routes to get their BRSR Core data independently verified: assurance and assessment. Assurance is carried out under standard assurance frameworks, following established assurance methodology and reporting standards. Assessment is carried out by a third party against standards developed by the Industry Standards Forum (a body formed by ASSOCHAM, CII and FICCI, in consultation with SEBI) and involves examining the processes a company has followed to arrive at its BRSR Core data.

2. Applicability of BRSR Core

Listed entities shall mandatorily undertake assessment or assurance of the BRSR Core, as per the following timelines specified:

Financial Year Applicability of BRSR Core to listed entities (by market capitalisation)
FY 2023-24 Top 150 listed entities
FY 2024-25 Top 250 listed entities
FY 2025-26 Top 500 listed entities
FY 2026-27 Top 1,000 listed entities

Compliance Timeline for Newly Covered Companies

Regulation 3 of SEBI (LODR) Regulations, 2015 provides that when a company enters the applicable market cap bracket for the first time, or re-enters that bracket after falling out of it, it doesn’t need to comply with BRSR Core immediately. It gets a short window to put in place the systems and processes required for assessment or assurance of the 9 KPIs covered under BRSR Core — three months from 31 December, or until the start of its next financial year, whichever is later. Only after this window does the company’s BRSR Core compliance obligation begin.

Example: If a company enters the applicable bracket as on 31 December 2025, it gets until 1 April 2026 to put its BRSR Core systems and processes in place — three months from 31 December 2025 coincides with the start of FY 2026-27 for a company following the April–March financial year. So, the company’s first mandatory BRSR Core compliance, covering assessment or assurance of the 9 KPIs, will be for FY 2026-27.

3. Assurance/Assessment Provider for BRSR Core

Who Can Be the Assurance/Assessment Provider for BRSR Core?

SEBI has laid down conditions on who can carry out the assessment or assurance of BRSR Core disclosures, to keep the process credible and independent.

  • Expertise: The company’s Board must ensure that the provider appointed for BRSR Core has the necessary expertise to carry out the assessment or assurance.
  • No conflict of interest: The company must also ensure there is no conflict of interest with the provider. For instance, the provider — or any of its associates — cannot be selling products or providing any non-audit or non-assessment/non-assurance services, including consulting, to the company or its group entities.

4. Value Chain and ESG Disclosures

What is “Value Chain”?

Value chain includes upstream and downstream partners that individually account for 2% or more of the company’s purchases or sales, by value. Companies may further limit their disclosures to those Significant Value Chain Partners who, together, comprise up to 75% of total purchases or sales.

Example:

Suppose Company A has 20 suppliers, and its total annual purchases are ₹100 crore.

Step 1 — Apply the 2% individual threshold:

Only suppliers whose purchases from Company A make up 2% or more of the ₹100 crore total (i.e., ₹2 crore or more each) qualify as Significant Value Chain Partners. Say 8 suppliers meet this test, individually ranging from ₹2 crore to ₹15 crore, while the remaining 12 suppliers each fall below ₹2 crore and are excluded.

Step 2 — Apply the 75% cumulative cap:

Ranking the 8 qualifying suppliers from largest to smallest, Company A adds up their purchase values until the running total reaches 75% of ₹100 crore, i.e., ₹75 crore. Suppose the top 6 of these 8 suppliers together already add up to ₹75 crore — Company A can stop there. It isn’t required to include the remaining 2 qualifying suppliers, even though they cross the 2% mark individually, because the 75% cap has already been met.

Result: Company A’s value chain, for BRSR Core purposes, consists of these 6 suppliers on the upstream side. The same two-step exercise (2% individual test, then 75% cumulative cap) is applied separately on the downstream (customer/sales) side to arrive at the value chain there.

ESG Disclosures for Value Chain

ESG disclosures for value chain refer to the reporting of BRSR Core KPIs not just for the listed company itself, but also for its significant upstream and downstream partners — the suppliers and customers identified using the 2% individual and 75% cumulative tests described above. In effect, it extends the same nine ESG attributes covered under BRSR Core beyond the company’s own operations to the value chain partners it does substantial business with.

  • Value chain disclosures are applicable to the top 250 entities (by market capitalisation), on a voluntary basis, from FY 2025-26.
  • Assessment or assurance of these value chain disclosures is applicable, also on a voluntary basis, from FY 2026-27.

Unlike the company-level BRSR Core requirement above, which is mandatory, value chain disclosure and its verification are currently entirely voluntary — a company may choose whether to report and verify this data at all.

5. Why is BRSR Core Important?

The full BRSR report is largely self-reported. BRSR Core exists to add independent, third-party verification to the specific ESG metrics that matter most — for the company itself and, where applicable, its significant suppliers and customers — so that investors, regulators and stakeholders aren’t relying purely on a company’s own word for its most material sustainability data.

6. FAQs

What is BRSR Core?

BRSR Core is a sub-set of the BRSR, consisting of 40+ Key Performance Indicators (KPIs)/metrics under 9 ESG attributes for which companies must obtain independent third-party verification.

When was BRSR Core introduced?

BRSR Core was introduced by SEBI vide circular dated 12 July 2023, which prescribed phased applicability of assurance by listed companies.

What is the difference between assurance and assessment for BRSR Core?

Assurance is carried out under standard assurance frameworks and established reporting methodology. Assessment is carried out by a third party against standards developed by the Industry Standards Forum and involves examining the processes behind the data. This means the provider reviews how the data was collected, recorded and consolidated — the systems and controls behind it — rather than independently re-verifying each reported number.

Which companies must comply with BRSR Core, and from when?

BRSR Core applies in phases by market capitalisation: top 150 listed entities from FY 2023-24, top 250 from FY 2024-25, top 500 from FY 2025-26, and top 1,000 from FY 2026-27.

If a company enters the applicable bracket partway through the year, when must it start complying?

Under Regulation 3 of the SEBI (LODR) Regulations, 2015, a company gets a short window before its BRSR Core obligation begins — three months from 31 December, or until the start of its next financial year, whichever is later. For example, a company entering the bracket as on 31 December 2025 gets until 1 April 2026 to set up its systems, making FY 2026-27 its first year of mandatory compliance.

Who can act as the assurance or assessment provider for BRSR Core?

The provider must have the necessary expertise, and there must be no conflict of interest — for instance, the provider or its associates cannot be selling products or providing non-audit/non-assessment/non-assurance services, including consulting, to the company or its group entities.

What is “value chain” under BRSR Core?

Value chain includes upstream and downstream partners that individually account for 2% or more of the company’s purchases or sales, by value. Companies may further limit disclosures to those Significant Value Chain Partners who, together, comprise up to 75% of total purchases or sales.

Is ESG disclosure for value chain mandatory?

No. Value chain disclosures are applicable to the top 250 entities (by market capitalisation), but on a voluntary basis, from FY 2025-26. Assessment or assurance of these disclosures is also voluntary, applicable from FY 2026-27.

How is value chain reporting different from the company-level BRSR Core requirement?

The company-level BRSR Core requirement is mandatory for entities within the applicable bracket. Value chain disclosure and its verification, by contrast, are currently entirely voluntary — a company may choose whether to report and verify this data at all.

Why is BRSR Core important?

The full BRSR report is largely self-reported. BRSR Core adds independent, third-party verification to the ESG metrics that matter most, so that investors, regulators and stakeholders aren’t relying purely on a company’s own word for its most material sustainability data.