BRSR Reporting: SEBI's mandatory sustainability disclosure for India's largest listed companies.

The Business Responsibility and Sustainability Report is a standardised sustainability disclosure that SEBI requires specified listed entities to include in their annual report. It is structured around the nine principles of the National Guidelines on Responsible Business Conduct and combines narrative policy disclosures with quantitative performance data on environmental, social and governance parameters.

SEBI made the BRSR mandatory for the top listed entities by market capitalisation, effective from financial year 2022-23, replacing the earlier Business Responsibility Report. The applicability threshold and the phasing of associated requirements have been revised by successive SEBI circulars, so an entity near the boundary should confirm its current position against the latest circular rather than assume.

BRSR Core is a defined subset of key performance indicators drawn from the BRSR, with specified attributes intended to make them comparable and verifiable. Its distinguishing feature is assurance: the BRSR as a whole is a disclosure, while BRSR Core carries an assurance requirement phased by market-capitalisation rank. In practical terms, Core is the part where your data has to survive an external examination.

SEBI requires the assurance provider to have the necessary expertise and, critically, to be free of conflict, it must not be providing audit or non-audit services to the entity or its group that would compromise independence. This rules out simply extending the statutory auditor's engagement, and it is a point boards should settle early rather than at year end.

BRSR is mandatory, prescribed in format, filed with a regulator and structured on the NGRBC principles. GRI is voluntary, internationally recognised, impact-focused and organised by material topics. They draw on much of the same underlying data, and BRSR permits cross-referencing to other frameworks where the disclosure has already been made: so a company reporting under both should build one data set, not two.

They come from the National Guidelines on Responsible Business Conduct, 2019, and cover ethics and transparency, sustainable and safe goods and services, employee wellbeing, stakeholder responsiveness, human rights, environmental protection, responsible public policy engagement, inclusive growth and equitable development, and responsible consumer engagement. Section C of the BRSR reports performance principle by principle.

Well before the financial year closes, not after. The disclosures require data that many organisations do not routinely collect (Scope 1 and 2 emissions, water withdrawal by source, waste by category and disposal route, complaint and grievance statistics) and retrofitting a year of that at reporting time produces figures that will not withstand assurance. The first year is a systems build; subsequent years are a reporting exercise.