ESG / BRSR — Environmental, Social & Governance Reporting
If your company is among the top 1000 listed companies by market capitalisation, BRSR disclosure is mandatory under SEBI's Listing Obligations and Disclosure Requirements (LODR). For unlisted companies, ESG reporting is increasingly required by export buyers (especially European), private equity investors, and large supply chain customers.
SEBI LODR
Mandatory for top 1000 listed companies
BRSR Core
Third-party assurance required from FY 2023-24
Nine principles
BRR/BRSR structured around 9 NVG principles
Your company is preparing its ESG or BRSR report and you need to understand what data is needed from your function. BRSR requires quantitative data on energy consumption, emissions, water usage, waste generated, workforce numbers, safety incidents, and training. Your job is to maintain accurate records within your function throughout the year — not scramble for data at reporting time.
Quantitative
BRSR needs numbers, not narratives
Verified
Data must be traceable to source records
Annual
Reported for the financial year in the Annual Report
Quick reference. SEBI BRSR (Business Responsibility and Sustainability Report) mandatory for top 1000 listed companies by market cap from FY 2022-23. BRSR Core (assured indicators) mandatory with reasonable assurance from FY 2023-24 for top 150, extended thereafter. Nine principles aligned to National Guidelines on Responsible Business Conduct (NGRBC). GRI, SASB, TCFD also used in voluntary reporting.
FY 2022-23
BRSR mandatory for top 1000
BRSR Core
Assured indicators from FY 2023-24
Nine principles
NGRBC-aligned
ESG (Environmental, Social, and Governance) reporting allows stakeholders to assess a company's non-financial performance. In India, SEBI introduced the Business Responsibility Report (BRR) in 2012 and replaced it with the more comprehensive Business Responsibility and Sustainability Report (BRSR) in 2021. BRSR aligns with international frameworks including GRI and TCFD.
2012
BRR introduced by SEBI
2021
BRSR introduced
2023
BRSR Core with assurance mandated
BRSR mandatory for top 1000 listed companies (SEBI)BRSR Core requires third-party assurance from FY 2023-24Unlisted companies increasingly required by buyers and investors
What’s on this page
01 —What it isUnderstanding ESG / BRSR
India's mandatory sustainability disclosure framework — and what it actually requires.
The BRSR (Business Responsibility and Sustainability Report) is SEBI's mandatory sustainability disclosure framework for listed companies. It replaced the earlier BRR (Business Responsibility Report) and requires significantly more detailed, quantitative disclosures across environmental, social, and governance dimensions.
BRSR is structured around nine principles derived from the National Guidelines on Responsible Business Conduct (NGRBC). Each principle has essential indicators (mandatory) and leadership indicators (voluntary for most, mandatory for BRSR Core companies).
BRSR Core is a subset of indicators for which third-party assurance is required. From FY 2023-24, the top 150 listed companies must obtain reasonable assurance on BRSR Core indicators. This is being progressively extended.
ESG and BRSR are not the same thing. BRSR is India's regulatory disclosure framework (SEBI). ESG is the broader global framework for non-financial performance assessment used by investors, rating agencies, and buyers. BRSR data feeds into ESG assessments, but satisfying BRSR does not automatically satisfy the specific ESG requirements of international buyers or rating agencies like MSCI or Sustainalytics.
👥 Illustrative case — details changed for confidentiality
The business
Listed mid-cap manufacturing company Mumbai · 2,400 employees, BSE and NSE listed
The trigger
SEBI made BRSR reporting mandatory for the top 1000 listed companies by market capitalisation from FY 2022-23. The company was in scope.
The challenge
Their sustainability data was scattered across HR, operations, finance, and facilities. Each team maintained separate spreadsheets. Consolidating the data for the BRSR took 6 weeks in the first year — and the final numbers were challenged by their auditor because the data trail was incomplete.
Where Clicarity came in
The company deployed Clicarity to track production and operational jobs across their facilities. Stage-wise data — energy and material consumption at each production step, wastage, and operator records — was available as a by-product of daily job tracking. When BRSR data collection began, operations data was available by facility, by period, with a verifiable data trail.
The result
BRSR prepared 3 weeks faster in Year 2. Auditor challenged no data points from production operations.
The operations data was already there because we were tracking our work. BRSR just needed it organised.
02 —Who needs itIs it right for you?
Do you actually need it? Honest answer.
✓ BRSR is mandatory
Top 1000 listed companies by market capitalisation (SEBI LODR mandatory)
Top 150 listed companies (BRSR Core with third-party assurance)
∼ ESG reporting strongly recommended
Unlisted companies in the supply chain of European buyers (EU CSRD impacts supply chains)
Companies raising private equity or seeking international investment
Exporters to markets with mandatory supply chain sustainability requirements
— Voluntary but watch developments
Small unlisted businesses with no export or institutional investor requirements
Note: Scope is expanding — check current SEBI LODR requirements
EU CSRD note: The EU Corporate Sustainability Reporting Directive impacts large Indian companies operating in the EU and their Indian suppliers. If your European buyer asks for sustainability data, the scope is likely driven by CSRD. Verify your specific obligations with your buyer and a qualified advisor.
03 —What it requiresWhat is checked
What BRSR requires — nine principles, quantitative data, and assurance.
1
Company details and governance disclosures
Basic information: number of employees, turnover, locations, subsidiaries, and governance structure including board composition, independence, and committee details.
2
Environmental data — Principle 6
Quantitative data on: energy consumption (renewable and non-renewable, in GJ), GHG emissions Scope 1 and Scope 2 (in tCO2e), water withdrawal and consumption (in KL), waste generated by type (in MT).
E.g. Total energy consumption for the year, split by source. Scope 1 direct emissions from owned assets. Scope 2 indirect emissions from purchased electricity.Most common gap: Data collected at head office level without facility-wise breakdown. BRSR Core requires facility-level data.
3
Social data — Principles 3, 4, 5
Workforce data: permanent and contract employees by gender, differently abled. Safety data: LTIFR, injury rates. Training hours by category. Community investment (CSR spend vs 2% mandate).
E.g. Number of permanent employees and contractual workers. Safety incident data including fatalities, LTI, and near-misses.
4
Value chain disclosures
From FY 2024-25, BRSR requires disclosures about the company's value chain — key suppliers and distributors — including sustainability performance data.
E.g. Percentage of value chain partners with sustainability assessments completed.Most common gap: Companies focus on own operations and underestimate the value chain disclosure requirements.
5
BRSR Core indicators with assurance
A specific subset of BRSR indicators requires third-party assurance. Assurance can be reasonable or limited, by a qualified assurance provider.
Most common gap: Assurance engagement starts too late. Assurance providers need adequate lead time and data evidence trails.
6
Complaints and grievance mechanisms
Disclosure of complaints received from stakeholders, how they were resolved, and the number pending.
E.g. Number of complaints from employees, customers, and communities received and resolved during the year.
What inspectors really check
SEBI does not conduct audits. Listed company BRSR disclosures are filed with the Annual Report and are publicly visible. The BRSR Core assurance provider reviews your data evidence trails — source records, calculation methodologies, and data governance. Gaps in data evidence are the most common assurance issue.
Gap analysis checklist — tick what you already have
Facility-wise energy consumption records for the full year
Electricity bills, fuel consumption records, renewable energy generation.
GHG Scope 1 and Scope 2 emissions calculated
Methodology documented. Emission factors from recognised sources.
Water withdrawal and consumption records
By source (municipal, groundwater, rainwater). Discharge data.
Waste generation records by category
Hazardous and non-hazardous. Disposal method and contractor details.
Workforce data — permanent, contractual, by gender
As of year-end. HR records.
Safety incident data — LTIFR, injuries, near-misses
Reported through formal safety system, not collected at year-end.
CSR spend vs 2% mandatory threshold
Board-approved CSR policy and spend report.
Value chain sustainability data collection initiated
At least for top suppliers by spend.
0 of 8 complete
04 —Official bodyWho certifies in India
Who issues this in India — and how to verify it.
BRSR is regulated by SEBI (Securities and Exchange Board of India). The framework is based on the National Guidelines on Responsible Business Conduct (NGRBC) published by the Ministry of Corporate Affairs.
For third-party assurance of BRSR Core, assurance is provided by qualified chartered accountants or sustainability assurance firms.
BRSR Core assurance providers must meet SEBI's competence requirements. Confirm your assurance provider's qualifications before engaging them. A quality consultant without assurance credentials is not sufficient for BRSR Core assurance.
SEBI — BRSR official circular and format
SEBI LODR and BRSR format. Download the current format here.
Based on sebi.gov.in. Actual timelines vary. Confirm with your CB.
ESG / BRSR Journey
Step 1
Identify your mandatory scope
Top 1000 by market cap: full BRSR. Top 150: BRSR Core with assurance. Check current SEBI LODR.
Step 2
Build data collection systems
Assign data owners for each BRSR indicator. Start collecting at facility level.
Step 3
Calculate GHG emissions
Scope 1 and 2 with documented methodology. For BRSR Core: verified by assurance provider.
Step 4
Prepare BRSR report
Use SEBI's prescribed format. All essential indicators mandatory. Leadership indicators where applicable.
Step 5
BRSR Core assurance
Engage qualified assurance provider. Allow adequate lead time for evidence review.
Filing
Annual Report
BRSR filed as part of Annual Report. BRSR Core assurance report included.
▶Where to begin: Use the checklist in Section 3 to assess your readiness before contacting any CB.
BRSR mandatory from
FY 2022-23
Top 1000 listed companies. Filed with Annual Report.
BRSR Core assurance
FY 2023-24 onwards
Top 150 first, then extended. Reasonable assurance required.
Value chain scope
FY 2024-25 onwards
Supplier and distributor sustainability data required.
GHG boundary
Scope 1 + Scope 2 minimum
Scope 3 encouraged but not mandatory for most.
Start data collection in Q1 of the financial year — not Q4. BRSR requires full-year quantitative data. Attempting to reconstruct energy, water, and waste data at year-end from invoices and estimates leads to data quality issues that assurance providers flag.
06 —Find certified companiesHow to verify
How to find and verify certified organisations.
All BRSR disclosures by listed companies are publicly available as part of their Annual Reports filed on BSE and NSE. To view a specific company's BRSR, access their Annual Report on the stock exchange filing.
How to verify: To confirm whether any organisation holds a current ESG / BRSR certification, use the official register. Verify the issuing CB's accreditation at nabcb.qci.org.in.
Download the current SEBI BRSR format and map your mandatory indicators
Go to sebi.gov.in and download the current BRSR format circular. Identify which indicators are essential (mandatory) vs leadership (voluntary). This is your disclosure checklist.
Assign data owners and start facility-level data collection immediately
Map every BRSR quantitative indicator to a data owner in your organisation. Energy data = facilities. Workforce data = HR. Safety data = EHS. Start collecting at facility level from the start of the financial year.
3
Engage a BRSR Core assurance provider early if in scope
If you are in the top 150, engage your assurance provider at the start of the year. They need to review data collection systems and evidence trails — not just the final numbers.
08 —How Clicarity fitsProcess tracking
Good records are the foundation. A process tracker builds them automatically.
Clicarity — Live Job Process Tracker & Bottleneck Identifier
Clicarity doesn't file your BRSR. It tracks your operations — and that tracking generates the production and resource data your ESG report needs.
BRSR requires quantitative data on energy consumption, material usage, waste generated, water consumed, and workforce metrics — reported by facility, verified, and filed with SEBI. In Clicarity, every production job captures stage-wise quantities: input, output, wastage, energy-consuming equipment used. When jobs split into product lines or facility sub-processes, each is tracked independently. When they rejoin, the aggregate data across all variants and sub-processes is preserved. That is your operations data for BRSR — generated as a by-product of daily work, not assembled during reporting season.
Stage-wise quantity tracking — input, output, wastage at every production step — is the foundation of your material consumption and waste generation data for BRSR.
Custom fields for energy-consuming equipment at relevant stages (machine number, cycle time, consumable used) support facility-level energy consumption data collection.
When production splits across product lines or shifts, each is tracked independently. Aggregate resource data by facility and period is available from the job records.
Clicarity shows operator records, shift data, and job completion history — supporting the workforce productivity and safety data points BRSR requires.
📄 Job tracked in Clicarity
#ESG-2026 — Annual BRSR report — FY 2025-26
Report initiated
✎Reporting entity
▼Reporting period
▼BRSR category
▼Assigned team
📅Board deadline
→
Data collection — Environment
#Energy consumed (GJ)
#GHG Scope 1 (tCO2e)
#GHG Scope 2 (tCO2e)
#Water consumed (KL)
▼Data verified by
→
Data collection — Social
#Total employees
#Women employees (%)
#Safety incidents
#Training hours
▼HR sign-off
→
Data collection — Governance
#Board independence (%)
✎Whistleblower policy ref.
▼CSR spend vs mandate
▼Legal compliance status
▼ Job splits — each component tracked independently
#ESG-2026-A
BRSR Core indicators
▼Assured by
✎Assurance report ref.
▼Board approved
#ESG-2026-B
BRSR Extended indicators
▼Completed by
▼CFO reviewed
▼Board noted
▲
Components rejoin as #ESG-2026 — complete record of every branch, every data point, every sign-off preserved.
Internal review
▼CFO sign-off
▼Sustainability head
▼Board committee
📅Review date
→
Third-party assurance
✎Assurance provider
▼Assurance level
📅Report date
✎Report ref.
→
Filing & publication
📅SEBI filing date
📅Annual report published
▼Website updated
▼Investor deck updated
Wastage tracked:▰ Scope 1 and Scope 2 GHG data verified before inclusion▰ BRSR Core indicators assured separately by third party▰ Filing date tracked against SEBI deadline
ⓘ Fields and stage names are fully customisable. This illustrates a typical listed company BRSR reporting process setup.
👥 Illustrative case — details changed for confidentiality
The business
Listed mid-cap manufacturing company Mumbai · 2,400 employees, BSE and NSE listed
The trigger
SEBI made BRSR reporting mandatory for the top 1000 listed companies by market capitalisation from FY 2022-23. The company was in scope.
The challenge
Their sustainability data was scattered across HR, operations, finance, and facilities. Each team maintained separate spreadsheets. Consolidating the data for the BRSR took 6 weeks in the first year — and the final numbers were challenged by their auditor because the data trail was incomplete.
Where Clicarity came in
The company deployed Clicarity to track production and operational jobs across their facilities. Stage-wise data — energy and material consumption at each production step, wastage, and operator records — was available as a by-product of daily job tracking. When BRSR data collection began, operations data was available by facility, by period, with a verifiable data trail.
The result
BRSR prepared 3 weeks faster in Year 2. Auditor challenged no data points from production operations.
The operations data was already there because we were tracking our work. BRSR just needed it organised.
Clicarity is a process tracking tool. It does not provide certification, consulting, or audit services.