Last updated: May 25, 2026. India sustainability reporting is mainly shaped by SEBI's Business Responsibility and Sustainability Reporting framework, or BRSR. For the top 1000 listed companies by market capitalization, BRSR is mandatory from FY 2022-23. The newer BRSR Core layer adds a smaller set of high-scrutiny ESG metrics that must be supported by third-party assessment or assurance as the phased regime expands.
Short answer: ESG reporting is mandatory in India for the top 1000 listed companies through BRSR. BRSR is built around the National Guidelines on Responsible Business Conduct, known as the NGRBC. BRSR Core applies in phases to the top listed companies and focuses on a smaller group of metrics including GHG emissions, water, energy, waste, employee and wage data, inclusive development, customer and supplier fairness, and openness of business. SEBI has also revised the framework so BRSR Core uses the current language of assessment or assurance, and value-chain ESG disclosure is voluntary for the top 250 listed companies from FY 2025-26.
Who needs to report sustainability information in India?
The main mandatory sustainability reporting requirement applies to India's top 1000 listed companies by market capitalization. SEBI introduced BRSR in 2021, made it voluntary for FY 2021-22, and made it mandatory for the top 1000 listed companies from FY 2022-23.
Other companies may still need ESG data even if they are not directly in the top 1000 listed-company group. Common triggers include IPO preparation, investor due diligence, lender requests, customer or supplier sustainability questionnaires, parent-company reporting, ESG ratings, or voluntary sustainability reporting.
For a private company, supplier, or portfolio company, the practical question is often not only "Is BRSR legally mandatory for us?" It is also whether a listed customer, investor, bank, or group company is asking for data that follows the BRSR or BRSR Core structure.
What BRSR requires
BRSR is India's listed-company sustainability disclosure format. It replaced the earlier Business Responsibility Report approach and is designed to make ESG disclosures more standardized, quantitative, and comparable across companies and sectors.
The framework has three main sections:
- Section A: General disclosures. Basic information about the listed entity, its products and services, operations, employees and workers, holding and subsidiary structure, CSR applicability, transparency, and complaints or grievance mechanisms.
- Section B: Management and process disclosures. Governance, policies, procedures, and oversight connected to the nine NGRBC principles.
- Section C: Principle-wise performance disclosures. Quantitative and qualitative performance data mapped to each NGRBC principle, split into essential and leadership indicators.
BRSR should not be treated as a communications exercise at the end of the reporting cycle. It normally requires coordinated inputs from finance, company secretarial, HR, EHS, operations, procurement, legal, investor relations, CSR, risk, and business-unit teams.
NGRBC 9 principles
BRSR is anchored in the nine principles of the National Guidelines on Responsible Business Conduct. In practical terms, those principles ask companies to report how they:
- conduct and govern themselves with ethics, transparency, and accountability;
- provide goods and services in a sustainable and safe manner;
- respect and promote the wellbeing of employees and workers, including value-chain workers;
- respect stakeholder interests and respond to stakeholder concerns;
- respect and promote human rights;
- respect, protect, and restore the environment;
- engage in responsible and transparent public policy advocacy;
- promote inclusive growth and equitable development; and
- engage with consumers responsibly.
These principles matter for search and for compliance because many India ESG reporting questions are really BRSR questions in disguise. A company may search for NGRBC 9 principles, BRSR principles, ESG reporting in India, or sustainability reporting requirements in India, but the underlying work usually comes back to mapping policies, data, evidence, and performance metrics against this structure.
Essential and leadership indicators
Under BRSR, essential indicators are mandatory. They include core information on topics such as energy, water, emissions, waste, employee and worker data, training, health and safety, human rights, consumer complaints, community impact, and governance processes.
Leadership indicators are voluntary, but they are still useful for companies that want stronger investor-facing disclosure or are preparing for more advanced reporting. They can include deeper information on value-chain impacts, product lifecycle issues, biodiversity, additional GHG metrics, responsible sourcing, and more granular management practices.
Companies that already prepare reports using GRI, TCFD, ISSB, SASB, Integrated Reporting, or other frameworks should still map those disclosures back to the BRSR format. Cross-referencing can reduce duplication, but it does not remove the need to answer the BRSR questions clearly.
BRSR Core and assessment or assurance
BRSR Core is a focused subset of BRSR introduced by SEBI in 2023. It is designed to improve the credibility and comparability of the most decision-useful ESG data. Instead of covering the full BRSR, BRSR Core focuses on nine ESG attributes and a set of KPIs that need stronger evidence, controls, and third-party review.
The key BRSR Core attributes are:
- GHG footprint;
- water footprint;
- energy footprint;
- embracing circularity, including 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.
SEBI's 2023 BRSR Core circular used an assurance framework. Subsequent SEBI changes, including the March 28, 2025 circular, introduced the current flexibility for assessment or assurance for BRSR Core and ESG disclosures for value chain. This distinction matters because companies should not assume every BRSR Core engagement is still framed only as reasonable assurance in the older language. The provider, standard, independence rules, and evidence file should be confirmed against the latest SEBI circulars and the Industry Standards on Reporting of BRSR Core.
BRSR Core applicability timeline
The BRSR Core assessment or assurance requirement applies in phases based on market capitalization. The phased coverage is:
- FY 2023-24: top 150 listed companies;
- FY 2024-25: top 250 listed companies;
- FY 2025-26: top 500 listed companies; and
- FY 2026-27: top 1000 listed companies.
This means the compliance workload expands significantly as the top 1000 listed-company group comes into scope. Companies outside the first wave should use the runway to improve ESG data ownership, methodology documentation, calculation controls, and evidence retention before their first assessment or assurance cycle.
Value-chain ESG disclosures
Value-chain reporting is one of the biggest practical changes for companies and suppliers. SEBI's 2023 BRSR Core circular introduced value-chain ESG disclosure for the top 250 listed entities. The March 28, 2025 update revised the timeline and approach.
Under the current revised position, ESG disclosures for the value chain apply to the top 250 listed entities on a voluntary basis from FY 2025-26. Assessment or assurance of those value-chain disclosures applies on a voluntary basis from FY 2026-27.
SEBI's current value-chain framing focuses on upstream and downstream partners that individually account for 2% or more of the listed entity's purchases or sales by value. A listed entity may limit disclosure to cover 75% of total purchases and 75% of total sales by value, and should disclose the percentage of purchases and sales covered when it provides value-chain ESG disclosures.
This is important for suppliers. A supplier may not be directly subject to BRSR, but it may still receive data requests from a listed customer that is preparing BRSR Core or value-chain ESG disclosure. Those requests can cover emissions, energy, water, waste, wages, health and safety, diversity, human rights, customer fairness, and governance information.
Green credits
SEBI's March 28, 2025 update also added a leadership indicator under Principle 6 for green credits. Companies are asked to disclose how many green credits have been generated or procured by the listed entity and by the top ten value-chain partners by purchase and sales value.
This does not replace emissions accounting or BRSR Core. It is an additional disclosure item in the environmental section and should be handled carefully so that green credits are not confused with operational GHG reductions, renewable electricity accounting, or carbon offsets.
What companies should prepare
Companies preparing for BRSR, BRSR Core, or India ESG reporting should start with a reporting map and evidence file. A practical preparation list includes:
- confirming whether the entity is in the top 1000 listed-company BRSR group and whether BRSR Core applies for the relevant financial year;
- mapping existing policies, procedures, and data owners to the nine NGRBC principles;
- preparing a BRSR Section A, Section B, and Section C responsibility matrix;
- calculating Scope 1 and Scope 2 GHG emissions and screening relevant Scope 3 data where needed;
- collecting energy, water, waste, safety, employee, worker, wage, human rights, grievance, and consumer data;
- documenting calculation methods, emission factors, boundaries, exclusions, assumptions, and data-quality controls;
- checking BRSR Core applicability and preparing an assessment or assurance evidence file;
- identifying whether value-chain disclosures or customer data requests apply; and
- reviewing whether green-credit disclosure is relevant under Principle 6 leadership indicators.
Common reporting mistakes
The first mistake is treating BRSR as a generic ESG story. BRSR is a structured disclosure format. A polished sustainability narrative will not help if the company cannot answer the required indicators with evidence.
The second mistake is relying on old BRSR Core language. Many summaries still describe the value-chain timeline and assurance wording as it stood in 2023. Companies should check the March 2025 update and the latest SEBI master circular before locking the project scope.
The third mistake is waiting until the annual report drafting stage. BRSR and BRSR Core depend on operational data that is often held across multiple teams and systems. The evidence file should be built during the year, not reconstructed at the end.
The fourth mistake is ignoring suppliers and customers. Even where value-chain reporting is voluntary, large listed companies and investors may still request supplier ESG data because they are building internal readiness, responding to stakeholders, or preparing future disclosures.
How Keslio can help
Keslio helps companies turn India sustainability reporting requirements into a practical reporting workplan, data request, and evidence-backed disclosure. Depending on the trigger, we can support:
- BRSR and BRSR Core readiness reviews;
- NGRBC principle mapping and gap checks;
- GHG emissions calculations for Scope 1, Scope 2, and relevant Scope 3 categories;
- BRSR data request checklists and evidence trackers;
- BRSR Core assessment or assurance readiness files;
- supplier and value-chain data collection support;
- sustainability reporting and communications for annual reports or standalone reporting; and
- supplier request support where the ESG trigger comes from a customer, buyer, or investor rather than direct SEBI applicability.
This guide is not legal advice. If your company is determining legal applicability, filing obligations, or formal SEBI interpretation, legal counsel or company secretarial advisers should confirm the obligation while Keslio supports the ESG data, calculations, reporting, and evidence workstream.
Sources and further reading
- SEBI circular on Business Responsibility and Sustainability Reporting by listed entities
- SEBI BRSR Core framework for assurance and ESG disclosures for value chain
- SEBI Industry Standards on Reporting of BRSR Core
- SEBI March 2025 circular on assessment or assurance, value-chain ESG disclosures, and green credits
- SEBI January 2026 LODR master circular
- Ministry of Corporate Affairs release on the National Guidelines on Responsible Business Conduct
