SEBI's BRSR and BRSR Core: what the circulars require

India’s listed-company sustainability disclosure runs through a single instrument: the Business Responsibility and Sustainability Report (BRSR), filed under Regulation 34(2)(f) of SEBI’s LODR Regulations as part of the annual report. Four SEBI circulars built it: one creating the report, one adding a core subject to external checking and extending the report into the value chain, one standardising how that core is reported, and one adding the option of assessment in place of assurance.

What it is

SEBI introduced the BRSR by circular of May 10, 2021, after Regulation 34(2)(f) of the LODR Regulations was amended by gazette notification SEBI/LAD-NRO/GN/2021/22 dated May 05, 2021.¹ The report seeks disclosures against the nine principles of the National Guidelines on Responsible Business Conduct; within each principle, essential indicators are reported on a mandatory basis and leadership indicators on a voluntary basis.¹ Entities that already report under GRI, SASB, TCFD or Integrated Reporting may cross-reference those disclosures rather than restate them.¹

A second layer sits inside the report. SEBI’s circular of July 12, 2023 introduced the BRSR Core, described as a sub-set of the BRSR consisting of key performance indicators under 9 ESG attributes, and required the top 1000 listed entities by market capitalization to disclose in the updated BRSR format as part of their annual reports from FY 2023-2024; the underlying amendment to the LODR Regulations was notified as SEBI/LAD-NRO/GN/2023/131 dated June 14, 2023.² The BRSR Core is the part subject to assessment or assurance.³

Who it binds

The obligation rests on the listed entity, and the population is defined by market capitalization rank. BRSR filing became mandatory for the top 1000 listed companies with effect from the financial year 2022-2023, replacing the earlier Business Responsibility Report; it was voluntary for the financial year 2021-22.¹ Assessment or assurance of the BRSR Core reaches a narrower group first and widens each year.³

Value chain reaches further, but through the same filer: the disclosure — and, where applicable, its assessment or assurance — is the listed entity’s, covering partners identified by their share of that entity’s purchases and sales.³ The green credits indicator works the same way, asking the listed entity to report credits generated or procured by itself and by its top ten value chain partners by value of purchases and sales.³

Dates

Filing has been mandatory from FY 2022-2023 for the top 1000, following the voluntary year FY 2021-22.¹ The updated BRSR format applied to the same top 1000 from FY 2023-2024.²

The assessment-or-assurance glide path set by the circular of March 28, 2025 runs FY 2023-24 top 150, FY 2024-25 top 250, FY 2025-26 top 500, and FY 2026-27 top 1000 listed entities by market capitalization.³ That circular records a decision of the SEBI Board taken on December 18, 2024 and a corresponding LODR amendment notified in the Gazette on March 28, 2025; it is issued under sections 11(1) and 11A of the SEBI Act read with Regulation 101 of the LODR Regulations and applies from the date of its issuance, except otherwise mentioned specifically.³

Two further dates matter for the reporting mechanics. The industry standards on BRSR Core reporting apply for FY 2024-25 and onwards.⁴ The green credits leadership indicator applies for BRSR disclosures for FY 2024-25 onwards.³ Value chain ESG disclosures apply to the top 250 listed entities on a voluntary basis from FY 2025-26, and their assessment or assurance is voluntary from FY 2026-27.³

Thresholds

Three thresholds do the work. The first is the reporting population: the top 1000 listed companies by market capitalization.¹ The second is the assessment tier for that financial year — 150, 250, 500 or 1000 entities by the same ranking.³

The third is the value chain test. The March 28, 2025 circular defines the value chain as the top upstream and downstream partners individually comprising 2% or more of the listed entity’s purchases and sales by value respectively, while allowing the entity to limit disclosure to cover 75% of its purchases and sales by value.³ Where an entity discloses value chain information, it also discloses the percentage of its total sales and purchases that the disclosure covers; previous-year numbers are voluntary in the first year of reporting.³

Verification standard

The BRSR Core is the assured or assessed object, not the whole report.² The July 12, 2023 circular originally required reasonable assurance of the BRSR Core;² the March 28, 2025 circular replaced that single route with an option, so listed entities shall mandatorily undertake assessment or assurance as per the glide path.³

“Assessment” has a defined meaning: third-party assessment undertaken as per the standards developed by the Industry Standards Forum in consultation with SEBI.³ Those standards were formulated by the Forum — ASSOCHAM, CII and FICCI, under the aegis of the stock exchanges — for BRSR Core under Regulation 34(2)(f) read with Chapter IV-B of the LODR master circular SEBI/HO/CFD/PoD2/CIR/P/0155 of November 11, 2024, and listed entities are directed to follow them.⁴

Independence is handled at board level. The board of the listed entity shall ensure that the assessment or assurance provider has the necessary expertise and that there is no conflict of interest — for instance, that the provider does not supply non-audit, non-assessment or non-assurance services, including consulting, to the entity or its group.³

What an organisation on ESGOS can do

An Indian listed entity, or a supplier that sits in one’s value chain, can find its listing in the directory and claim it from its profile page, or get listed and attach the evidence a BRSR reader would ask for: the BRSR Core assessment or assurance report for the relevant financial year, the assessment or assurance provider’s name, and the reported share of purchases and sales that any value chain disclosure covers. Suppliers that expect to be counted inside a customer’s 2% value chain can record the same metrics ahead of being asked. The verifiers directory lists accredited verification bodies drawn from national accreditation registers, by standard.

Footnotes

1. Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 — Business responsibility and sustainability reporting by listed entities, Securities and Exchange Board of India. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

2. Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 — BRSR Core: framework for assurance and ESG disclosures for value chain, Securities and Exchange Board of India. ↩ ↩² ↩³ ↩⁴

3. Circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42 — Measures to facilitate ease of doing business with respect to framework for assurance or assessment, ESG disclosures for value chain, and introduction of voluntary disclosure on green credits, Securities and Exchange Board of India. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³ ↩¹⁴

4. Circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2024/177 — Industry Standards on Reporting of BRSR Core, Securities and Exchange Board of India. ↩ ↩²