BRSR stands for Business Responsibility and Sustainability Report. SEBI mandates it. If your company is in the top 1,000 listed entities by market capitalisation, you file one every year as part of your annual report.
That is the short version. The rest of this is what people actually need once they get past the acronym.
Who mandates it and who has to file
The Securities and Exchange Board of India introduced BRSR in May 2021, replacing the older Business Responsibility Report. The first mandatory filings landed for FY 2022-23, covering the top 1,000 listed companies by market cap.
Everyone else can file voluntarily, and a fair number do. Usually because a customer asked, or because they are eyeing a listing, or because their PE investor put it in the term sheet.
The framework itself sits on the National Guidelines on Responsible Business Conduct, which is where the nine principles come from. So BRSR is really SEBI turning a set of voluntary national guidelines into a disclosure obligation with a filing deadline attached.
How the format is structured
Three sections. That is it, though each one goes deep.
Section A: General Disclosures. Corporate identity, what you make and where, employee and worker numbers broken down by gender and by permanent versus contractual, holding and subsidiary structure, CSR spend, and your grievance redressal mechanisms. Mostly factual. Mostly pulled from data you already have somewhere in HR and finance.
Section B: Management and Process Disclosures. This is where you declare, principle by principle, whether you have a policy, whether the board approved it, whether it is publicly available, and who is accountable. Twenty-four questions covering policy coverage, governance oversight, and review frequency. If your ESG policies are thin or informal, this section exposes it immediately. We deal with this constantly through our ESG policies and procedures work, and the fix is almost always the same: formalise what you already do, then close the two or three genuine gaps.
Section C: Principle-wise Performance Disclosure. The heavy one. Quantitative and qualitative data against each of the nine principles, split into essential indicators (mandatory) and leadership indicators (voluntary, but investors read them).
The nine principles, and what each one actually asks for
Principle 1: Integrity and ethics. Anti-corruption policy, training coverage, conflict of interest disclosures, disciplinary actions taken. Fines and penalties for the year.
Principle 2: Sustainable and safe goods and services. R&D and capex directed at environmental and social improvements, sustainable sourcing percentage, product life cycle data, recycled input materials, and reclaimed packaging. This is where LCA data gets pulled in, which is why more companies are commissioning life cycle assessments than were five years ago.
Principle 3: Employee wellbeing. Health insurance, accident insurance, maternity and paternity benefits, day care, retirement benefits, accessibility, complaints on working conditions, health and safety incidents, and turnover rates. Broken out by permanent and non-permanent workers, which is where a lot of companies discover their contractor data is a mess.
Principle 4: Stakeholder responsiveness. Who your stakeholders are, how you identified them, how often you engage, and what came out of it. This is the principle most closely tied to your materiality process. If you have run a proper double materiality assessment, this section writes itself. If you have not, it reads as generic.
Principle 5: Human rights. Training coverage, minimum wage compliance, median remuneration by gender and category, complaints on sexual harassment and discrimination, and human rights due diligence in the value chain.
Principle 6: Environment. The biggest section by volume. Energy consumption and intensity, water withdrawal and discharge, air emissions, Scope 1 and Scope 2 greenhouse gas emissions and intensity, waste generation and disposal, and compliance with environmental law. Leadership indicators add Scope 3, biodiversity, and value chain environmental data. SEBI’s March 2025 circular also added green credit disclosures here.
Scope 3 is where most filers struggle. We wrote a separate guide on the fifteen Scope 3 categories and which ones matter because it deserves more room than a bullet.
Principle 7: Policy advocacy. Trade and industry associations you belong to, and any public policy positions you have taken. Short section. Often overlooked, then filled in badly at the last minute.
Principle 8: Inclusive growth. Social impact assessments, rehabilitation and resettlement, CSR projects in aspirational districts, procurement from marginalised groups, and intellectual property benefits shared with traditional knowledge holders.
Principle 9: Consumer responsibility. Product labelling, consumer complaints, product recalls, data privacy, and cyber security. Manufacturing companies tend to underweight this one because it feels like a services issue. It isn’t.
Essential versus leadership indicators
Essential indicators are mandatory. Leave them blank and you have a filing deficiency.
Leadership indicators are optional. But here is the thing worth knowing: ESG rating agencies weight them heavily. If your MSCI or Sustainalytics score is lagging peers who look operationally similar, the difference is often that they filled in leadership indicators and you did not. We worked through exactly this with a listed industrial client on an ESG ranking improvement project, and a meaningful part of the gap was disclosure completeness rather than actual performance.
Rating agencies also feed into credit assessment in some cases, though the link is narrower than most boards assume. We unpacked that in ESG in credit ratings: when it actually moves your rating.
BRSR Core and assurance
BRSR Core is a subset of BRSR: nine attributes with defined KPIs that require reasonable assurance from an independent assurance provider. It started with the top 250 companies and expands down the list over time, and value chain disclosure obligations phase in alongside it.
This is the part that changes the internal workload most, because assured data has to be traceable back to source. A number you can defend to an auditor is a different animal from a number you put in a report. Full detail is in BRSR Core compliance: what the top 1,000 must know about value chain reporting.
Mistakes we see repeatedly
Treating it as a reporting exercise that starts in April. The data collection has to run through the year or the numbers do not reconcile.
Leaving it with the CSR team. BRSR needs HR, finance, EHS, procurement and the company secretary. CSR alone cannot answer half of Section C.
Copying last year’s narrative and updating the numbers. Rating agencies and analysts notice. So do the auditors once assurance kicks in.
Disclosing Scope 1 and 2 with no methodology note. An emissions number without a stated boundary, emission factor source and base year is not really a disclosure.
Ignoring the contractor workforce data. Principle 3 asks for it explicitly, and it is usually the single hardest data set to assemble.
Questions we get asked
What is the full form of BRSR? Business Responsibility and Sustainability Report.
Which regulatory authority mandates BRSR in India? SEBI, the Securities and Exchange Board of India, through its Listing Obligations and Disclosure Requirements regulations.
How many principles are covered under BRSR? Nine, drawn from the National Guidelines on Responsible Business Conduct.
Is BRSR mandatory for unlisted companies? No. It applies to the top 1,000 listed entities by market capitalisation. Unlisted companies file voluntarily, and many now do because customers, lenders or investors ask for it.
What is the difference between BRSR and BRSR Core? BRSR is the full report. BRSR Core is a defined subset of KPIs that must be independently assured. Every company filing BRSR Core is also filing BRSR.
Where does BRSR get filed? It forms part of the annual report and is filed with the stock exchanges. NSE and BSE both host the filings.
Bilancia Consulting is an Ahmedabad based sustainability and ESG advisory firm. We support Indian companies on sustainability reporting and disclosure, ESG and compliance, and BRSR Core assurance readiness. If you are preparing your first BRSR or tightening up for assurance, a short call is usually enough to identify where the gaps are.
Call +91-9510144494 or email general@bilanciaconsulting.co.in