India's BRSR: A Clear Guide to the Reporting Rules and Who They Affect

India has built one of the more detailed sustainability disclosure regimes outside Europe. At the centre of it is Business Responsibility and Sustainability Reporting, known as BRSR, a framework set by the Securities and Exchange Board of India (SEBI) that requires the country's largest listed companies to disclose how they manage their environmental, social and governance (ESG) impacts. 

Most of the obligation sits with those listed companies. Their suppliers can be drawn in too, including businesses based well outside India, though the rules governing that value chain reach were recently relaxed and remain a work in progress. Here is what BRSR is, the key dates, who it affects directly and indirectly, and why emissions data sits at the heart of it. 

What is BRSR?

BRSR is a structured ESG disclosure framework prescribed by SEBI for listed companies in India. SEBI introduced it in May 2021, and it became mandatory for the top 1,000 listed companies by market capitalisation from the financial year 2022–23, replacing the earlier and lighter-touch Business Responsibility Report (BRR).

The framework is built on the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), issued by India's Ministry of Corporate Affairs. Rather than leaving companies to report in their own narrative style, BRSR uses a SEBI-prescribed template, which makes disclosures more consistent and easier to compare across the market. The report forms part of a company's annual report and is filed with the stock exchanges in both PDF and machine-readable XBRL formats.

It is worth being clear on one point early. BRSR is a disclosure requirement tied to the listing rules, set out under SEBI's Listing Obligations and Disclosure Requirements (LODR) Regulations. It applies to listed companies in scope, not to every business operating in India.

What does a BRSR report include?

The framework is detailed but deliberately organised into three sections:

• General disclosures. Background on the organisation and its operations, including products and services, locations, workforce composition and value chain.
• Management and process disclosures. Governance structures, policies, risk management, stakeholder engagement and grievance mechanisms.
• Principle-wise performance disclosures. Performance reported against the nine NGRBC principles.

The nine principles span the full ESG spectrum:

1. Ethics, transparency and accountability
2. Sustainable and safe goods and services
3. Employee wellbeing
4. Stakeholder engagement
5. Human rights
6. Environmental responsibility
7. Responsible public policy engagement
8. Inclusive growth and equitable development
9. Consumer value and protection

Across these sections, BRSR contains around 140 indicators in total. These are split into essential indicators, which are mandatory and largely quantitative, and leadership indicators, which are voluntary and let companies show more advanced practice.

For emissions specifically, the distinction matters. Scope 1 and Scope 2 greenhouse gas emissions are essential indicators, so they are mandatory, reported under Principle 6 alongside energy, water and waste. Scope 3 emissions and supply chain disclosures sit among the leadership indicators, which are voluntary. In short, the BRSR format requires Scope 1 and 2, and encourages but does not compel Scope 3.

What is BRSR Core?

In 2023, SEBI introduced BRSR Core, a focused subset of the wider framework. Rather than adding new themes, BRSR Core concentrates on the key performance indicators considered most material and measurable across sectors, grouped under a set of ESG attributes. In practice these fall into three broad areas:

• Climate and environment: greenhouse gas emissions, energy and renewable energy use, water, waste and intensity metrics.
• Social and workforce: workforce composition, use of contract labour, diversity, health and safety, training, wages and access to social security.
• Governance and conduct: ethics, anti-bribery and corruption, grievance and whistleblowing mechanisms, human rights due diligence and supply chain screening.

The point of BRSR Core is credibility. Its indicators are subject to phased external assessment or reasonable assurance, beginning with the largest listed entities and expanding over time. This is what turns reported ESG data from a self-declared statement into figures a third party has checked.

One further detail matters for any business thinking about emissions data. SEBI's industry standards for BRSR Core explicitly allow a spend-based approach for estimating emissions, energy or water where a company only has annual spend data and no primary activity data. So BRSR Core does not mandate activity-based measurement. It sets out what must be reported and assessed, and accepts spend-based estimation where primary data is not available.

Key timelines

BRSR has evolved in steps since 2021, and the most significant recent change came in March 2025. The table below sets out the main milestones.

The March 2025 circular is the one to know. It made three notable changes:

• Assessment as an alternative to assurance. Companies can now obtain a third-party "assessment" of BRSR Core, carried out against standards developed by the Industry Standards Forum, instead of formal assurance.
• Value chain disclosure eased to voluntary. ESG disclosure for the value chain became voluntary rather than comply-or-explain, applying to the top 250 listed entities from FY 2025–26. SEBI also defined the value chain as the upstream and downstream partners that each account for 2% or more of a company's purchases or sales by value, with companies able to cap disclosure at 75% of purchases and sales.
• Voluntary green credit disclosures were introduced as a leadership indicator.

The direction of travel is the important signal here. SEBI eased the immediate pressure to give companies time to build the data systems, but the framework continues to point towards broader value chain coverage and deeper assurance over time.

Who does BRSR directly affect?

Directly, BRSR applies to the top 1,000 listed companies in India by market capitalisation, which together represent a large majority of India's market capitalisation by value. These companies must include BRSR disclosures in their annual reports, file them in the prescribed formats, and have them overseen at board level.

For these businesses, BRSR is part of their listing obligations. The largest among them also face external assessment or assurance of their BRSR Core data, which raises the bar from disclosure to verified disclosure.

How BRSR could affect the supply chain

This is where businesses far outside India's listed market could come in, including those that will never file a BRSR report themselves.

A listed company's Scope 3 emissions, and much of its wider ESG footprint, sit with its suppliers. As BRSR encourages Scope 3 reporting, listed companies may increasingly look to the businesses they buy from for that information.

It is important to be accurate about how far this currently goes. As of the March 2025 changes, value chain ESG disclosure is voluntary, not mandatory. It applies to the top 250 listed entities from FY 2025–26. And even where a company does engage its value chain, the definition is narrow: only the upstream and downstream partners that each account for 2% or more of its purchases or sales by value, with the option to cap disclosure at 75% of purchases and sales. So there is no blanket requirement today for a supplier to hand over emissions data.

In practice, the position for suppliers depends on the individual listed company. One that chooses to report Scope 3 emissions, or to disclose value chain data voluntarily, could need figures from the businesses it buys from, and may ask key suppliers for them. Where that happens, two groups outside India are most likely to feel it:

• Suppliers to Indian listed companies. A UK, US, Canadian or EU business that supplies a company in the BRSR top 1,000 may be asked for emissions and ESG data so that customer can build its Scope 3 picture or value chain disclosure. This is a commercial request rather than a legal duty on the supplier.
• Multinationals with Indian listed entities. A group with an Indian subsidiary inside the top 1,000 has a direct BRSR obligation for that entity, and will often want its reporting to line up with the parent's frameworks elsewhere.

Why carbon reporting sits at the centre

BRSR is broader than carbon. It covers human rights, labour, governance and consumer protection alongside the environment. But emissions data is one of the harder parts to produce well, and the mandatory Scope 1 and 2 figures are among the metrics most exposed to external assessment under BRSR Core.

A company cannot disclose a greenhouse gas figure it has not measured, and it cannot have that figure assessed unless the underlying method holds up. For a supplier being asked to contribute data into a customer's Scope 3 or value chain disclosure, the same logic applies: the more credible and well-structured your emissions data, the easier you make your customer's reporting, and the less friction there is in the relationship.

BRSR also aligns conceptually with frameworks businesses may already know, including the GHG Protocol for emissions accounting, and global standards such as GRI and the recommendations of the TCFD. A company that has built a solid emissions footprint for one purpose is rarely starting from scratch for the next.

How Seedling can help

Seedling combines carbon accounting software with one-to-one support from a dedicated expert, so a business can produce the data it needs and stand behind it. Here is how that maps to what BRSR-related requests tend to involve:

• A full-scope, GHG Protocol-aligned footprint. We measure Scope 1, 2 and 3 emissions, reviewed by our team, in a form that recognised frameworks expect. That covers the mandatory Scope 1 and 2 figures, and the Scope 3 data a customer may request.
• Supplier data, collected for you. If you need Scope 3 figures from your own suppliers, our supplier engagement tool sends a straightforward data request and pulls responses straight into your footprint, with no copying between tools.
• One footprint, many frameworks. A single, well-built footprint can support a BRSR value chain request, an SBTi target, a CSRD or SECR disclosure, an EcoVadis submission or a client RFP, without rebuilding it each time.
• Expert guidance throughout. Our team helps you collect the right data, interpret your results and build a credible reduction plan, so the process is manageable for teams without a dedicated sustainability function.

More than 500 businesses already trust Seedling to measure and reduce their emissions, with over 500,000 tonnes of CO2e measured on the platform. If a buyer's data request or a reporting requirement has put carbon data on your agenda, we can help you get it right.

FAQs

Is BRSR a law?

For the companies it applies to, yes. BRSR is a mandatory, legally enforceable requirement under SEBI's LODR Regulations, which carry the force of law. It is not a standalone statute affecting every business, only listed companies within the relevant thresholds. 

Who has to file a BRSR report?

The top 1,000 listed companies in India by market capitalisation. SEBI also encourages other listed companies to adopt BRSR voluntarily.

Does BRSR apply to my business if I'm based outside India?

Not directly, unless you have an Indian listed entity within the top 1,000. Indirectly, it could reach you if you supply a business that is in scope, since that company may request your emissions and ESG data for its own value chain disclosure.

Does BRSR require Scope 3 emissions reporting?

Not as a mandatory disclosure. In the full BRSR format, Scope 1 and Scope 2 emissions are essential (mandatory) indicators, while Scope 3 is a leadership (voluntary) indicator. The metrics assured under BRSR Core also centre on Scope 1 and 2. Scope 3 and supply chain emissions are encouraged, and enter mainly through the voluntary value chain disclosure provisions.

What is the difference between BRSR and BRSR Core?

BRSR is the full framework, with around 140 indicators across the nine NGRBC principles. BRSR Core is a focused subset of the most material, mostly quantitative indicators, such as emissions and workforce data, which are subject to phased external assessment or assurance for larger listed companies.

Does BRSR Core require activity-based carbon data?

No. SEBI's industry standards for BRSR Core allow a spend-based approach to estimate emissions, energy or water where a company only has annual spend data and no primary activity data. The framework sets out what must be reported and assessed, not a single measurement method.

What changed in March 2025?

SEBI eased the value chain rules to make them voluntary, gave companies the option of a third-party "assessment" as an alternative to assurance for BRSR Core, and introduced voluntary green credit disclosures.

Where can I read the official details?

The primary sources are SEBI's BRSR Core industry standards and the March 2025 circular on assurance, value chain and green credits.

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