In our last article, we have covered ESG journey in India along with applicability and overview of BRSR. Since the BRSR season is almost here, in this article we have tried compiling all crucial steps to guide the company on preparation part of the BRSR reporting for FY 2025-26.
The Securities and Exchange Board of India (SEBI) introduced the Business Responsibility and Sustainability Reporting (BRSR) for to be submitted by top 1,000 listed entities in India based on market capitalization from Financial Year 2022-23. This report forms part of the company’s annual report, also to be submitted to the stock exchanges where company is listed.
SEBI has given the format for BRSR along with detailed guidelines for BRSR reporting.
Let’s have a look at the BRSR format first.
- Format of BRSR is divided into three sections
- Section A is about General Disclosures of the company
Brief description of the company, market served, details on operation, finance, product / service, employees, CSR activities, assurance provider etc.
- Section B is about Management and Process related disclosures by the company
Details of the company’s operations & cover the structures, policies and management processes relating to National Guidelines on Responsible Business Conduct (NGRBC) principles concerning governance, leadership & stakeholders’ engagement. In case the business entity chooses not to adopt or report on any of the principles the same should be stated along with the reasons.
- Section C is about Principle-wise Performance Disclosures based on 9 principles of National Guidelines on Responsible Business Conduct
Businesses are required to report on how well businesses are performing against 9 principles of National Guidelines on Responsible Business Conduct (NGRBC), showing their commitments to responsible business through action and results.
- Ethics & transparency
2. Sustainable goods & services
3. Employee well-being
4. Stakeholder engagement
5. Human rights
6. Environment
7. Public & regulatory policy
8. Inclusive growth & CSR
9. Customer value
The questions in the report are divided into two categories- Essential & Leadership.
Essential indicators are mandatory to disclose & Leadership indicators can be voluntarily disclosed by the company.
- Steps for the preparation of BRSR:-
- In-depth understanding of the BRSR format
Read each question of each section along with guidance notes provided by SEBI.
Understand each principle of National Guidelines on Responsible Business Conduct and what information is required. BRSR consists of quantitative + qualitative data and ESG metrics (energy, water consumption, waste management, emissions, diversity, human rights, life cycle assessment, Environmental impact etc.)
- Decide the reporting boundaries
Decide whether report will be made on standalone basis i.e. only for the entity or on a consolidated basis i.e. for the entity and all the entities which form a part of its consolidated financial statements, taken together.
- Train the internal team for BRSR
Provide a training to the Board of Directors, department Heads- HR, Operations & Marketing Head, CFO, Finance Head, IT Head, EHS Head, Procurement Head, CSR Head, various branches and Plant in-charge at various location/s on BRSR and information requirements in detail.
You may hire any agency experts to provide an in-depth training on BRSR preparation and BRSR Assurance readiness.
Create a cross-functional team consisting of Company Secretary, CFO, Sustainability/ESG team, HR, Operations / Plant heads, EHS, Finance, Procurement / SCM, IT who will be providing the on-time data for BRSR preparation.
Identify Board committee (CSR / ESG / Risk) with defined roles & responsibilities for BRSR and Approval of BRSR policy framework.
- Materiality assessment & Gap Assessment
Identify material issues i.e. key issues for a business in terms of risk and opportunity pertaining to environmental and social matters. This is a crucial task to identify & provide a disclosure in the report. Perform a gap analysis for any Policy not aligned to NGRBC principles.
- Map BRSR Requirements with Internal Data
Create a BRSR mapping sheet with
Question—- Name of the department for required information—- Department owner— Supportive Document
For Examples:
Data related to Energy & emissions to be collected from EHS / Plant
Data related to Diversity, employee details & wages to be collected from HR
- Data collection & collation
Make a document with questions and information required clearly from each department, factory, branches, it will ease the understanding of the department Heads.
Although providing information for questions given under leadership indicators is voluntary to company, make sure that information collected is backed by the validated supportive documents for each of the principles.
Make sure for Consistency with Annual Report, Consistency with CSR disclosures and Same numbers across all public documents.
- Set up a system to receive timely information from Value Chain Partners
Identify value chain partners- top upstream and downstream partners individually comprising 2% or more of the purchases and sales. Conduct training and awareness sessions for value chain partners.
Collect data on complaints/Grievances on any of the principles of NGRBC received during the year, assessment of Health & safety practices, working conditions, sexual harassment, discrimination at workplace, environmental impacts.
- Validate the data and internal checks
Tally the numbers received for quantitative disclosure and information received from each department, plants, branches with calculations sheet and other supportive documents. It’s a crucial step to validate the data and information received rather than just copy pasting to make BRSR ready for checks by assurance provider.
- Draft the response received
Draft the structured response for each of the questions given in BRSR for Essential and leadership indicators.
- Assurance Readiness-
Understand about BRSR Core. Provide a brief about the company and business line to assurance provider.
Hold an introductory meeting of respected Board members, department heads, branches and factories personnel with an assurance provider.
Keep all supportive documents- hardcopies, emails in structured manner for purpose of efficient Assurance process.
- Common Mistakes to Avoid-
- Mismatching data with Annual Report, Annual Return and CSR Report
- Lack of checking on applicability or Incorrect “Not Applicable” responses
- Copy-pasting ESG content
- Keeping no evidence for quantitative information
Link for latest BRSR Format & Guidance note for BRSR by SEBI given in Master Circular for compliance with the provisions of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 by listed entities, Last updated on January 30, 2026https://www.sebi.gov.in/legal/master-circulars/jan-2026/master-circular-for-compliance-with-the-provisions-of-the-securities-and-exchange-board-of-india-listing-obligations-and-disclosure-requirements-regulations-2015-by-listed-entities_99432.html
