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Sustainability Reporting Requirements in India

By 
Keslio Team
5
 minute read  
|  
March 19, 2024
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Historical Overview of Sustainability Reporting in India

As sustainability and ethical business conduct increasingly take center stage globally, India has been proactive in establishing regulations and guidelines around sustainability that reflect this shift.

In response to rising investor pressure for increased transparency and non-financial reporting, the Securities and Exchange Board of India (SEBI) mandated ESG reporting in India in 2012. This requirement, known as the Business Responsibility Report (BRR), was initially implemented for the top 100 listed companies by market capitalization. Then in 2013, Section 135 of the Companies Act was introduced, mandating companies to carry out Corporate Social Responsibility (CSR) initiatives, particularly targeting local communities, and outlined the governance, budgeting, and spending related to these initiatives.

Globally, the United Nations General Assembly adopted the 2030 Agenda for Sustainable Development in 2015, establishing seventeen Sustainable Development Goals (SDGs) along with indicators and review mechanisms for tracking progress. To harmonize the Indian National Voluntary Guidelines (NVGs) with these UN SDGs, a revision process was initiated in 2015. Also, in FY 2015-16, SEBI expanded the BRR requirement to include the top 500 listed companies by market capitalization.

Amid increasing global concerns about ESG reporting and sustainable development, the National Guidelines on Responsible Business Conduct (NGRBC) were introduced in 2019 as a revised version of the NVGs. Subsequently, expanded the BRR requirement to include the top 1000 listed companies by market capitalization.

However, to align the BRR with the NGRBC, SEBI introduced a new ESG reporting framework known as BRSR (Business Responsibility and Sustainability Reporting) in May 2021. Starting from FY 2022-23, it's mandatory for the top 1000 listed companies (by market capitalization) to report their sustainability performance in line with this new framework.

BRSR Overview

SEBI introduced the BRSR to align India's sustainability reporting with international standards. The structure of the BRSR is based on the nine principles stipulated in the NGRBC Guidelines. These principles encompass a wide range of sustainability matters, including business ethics, transparency, human rights, environmental safety, and fair labor practices. The NGRBC Guidelines have been influenced by leading international standards such as the UN Guiding Principles on Business and Human Rights, UN Sustainable Development Goals, Paris Agreement, and International Labour Organisation (ILO) Core Conventions. This alignment ensures that the BRSR is in sync with globally recognized ESG benchmarks, thereby promoting a holistic approach to sustainability reporting in India.

NGRBC Principles

The NGRBC Principles
Source: Deloitte - Business Responsibility and Sustainability Report

Here are some notable features of the BRSR:

  1. The BRSR fosters an increased emphasis on ESG factors, enabling businesses to redefine their purpose and increase their focus on sustainable practices.
  2. The guidelines allow companies to correlate their sustainability reports with globally recognized reporting standards such as GRI, SASB, TCFD. This helps companies avoid repetition if the information is already available in the annual report.
  3. The guidelines underscore the importance of adequate training and awareness sessions on topics like employee safety, corruption prevention, and workforce skill enhancement. Companies are required to detail these initiatives.
  4. BRSR requires companies to disclose information about Environmental or Social Impact Assessments in compliance with relevant laws.
  5. Although not mandatory, the guidelines encourage companies to report on 'Essential' and 'Leadership' indicators, promoting the Key Performance Indicators (KPIs) model.

The differences of the BRSR vs the BRR are outlined below.

BRSR vs BRR
Source: EY - BRSR reporting and the evolving ESG landscape in India

BRSR Disclosure Requirements

The reporting framework is primarily designed as an aid for corporations aiming to comply with the NGRBC. The framework is divided into three distinct parts:

Section A: General disclosures

This initial section is intended to gather fundamental data about the listed company, which includes information about their offerings, operations, workforce, transparency, legal obligations, subsidiaries, ownerships, and joint ventures, among other details.

Section B: Management and process disclosures

In this segment, companies are expected to disclose details about their policies and procedures that align with the principles of the NGRBC on subjects such as leadership, governance, and stakeholder interactions. If relevant, corporations are advised to share website links where these policies can be accessed. The data requested in this segment mainly involves queries related to supervision, governance, leadership challenges, and operational procedures.

Section C: Principle-wise performance disclosures

This final section requires companies to report on key performance indicators (KPIs) that align with the nine principles of responsible business conduct under the NGRBC. Additionally, corporations must report on two sets of metrics for each principle, which include:

Essential indicators (mandatory)

These are the metrics that the company is obliged to report, including environmental data such as energy usage, emissions, water consumption, and waste generation; training programs implemented; community projects initiated by the company, and the social impact generated by the company.

Leadership indicators (voluntary)

These metrics are not yet obligatory for the company to report. However, there is a wider expectation that companies would adhere to these indicators for enhanced transparency and increased accountability. This might involve reporting on third-party emissions and detailed breakdown of energy usage, health, and safety evaluation of partners in the value chain. The advanced indicators aim to provide a more comprehensive view of the company's operations from a sustainability perspective.

BRSR Reporting Format

Conclusion

The journey towards sustainability reporting for Indian businesses has often been marred by the difficulty of choosing the appropriate reporting framework. However, the introduction of the Business Responsibility and Sustainability Report (BRSR) brings an end to this predicament, offering a unified and transparent reporting model that companies must now embrace. The primary aim of BRSR is to guide companies in aligning their operations with the National Guidelines on Responsible Business Conduct (NGRBC), thereby promoting operational transparency and accountability.

In conclusion, the mandatory ESG reporting requirements in India, driven by the BRSR, signify an important step towards a more sustainable business landscape. This trend is likely to continue as the country strives to harmonize its business practices with international standards and meet the expectations of a global investor community that is increasingly focused on ESG considerations.

At Keslio, we are deeply passionate about sustainability, equipping us with the expertise and extensive network needed to guide clients through their sustainability journey effectively and efficiently. Our expertise is particularly valuable for companies looking to embed sustainability practices into their businesses and investors looking to integrate ESG and impact into investment portfolios. To learn more about how Keslio can assist your organization on its sustainability journey, please don't hesitate to get in touch with us.

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