Is BRSR Enough? Why Indian Companies Should Think Bigger on Sustainability Reporting

The BRSR framework has brought helpful structure to sustainability reporting in India. As expectations around ESG reporting continue to grow, companies have an opportunity to go beyond BRSR — not to follow trends, but to demonstrate deeper commitment and build greater transparency. Here’s why taking that extra step matters.

Laying the Groundwork: How BRSR Is Shaping Sustainability Disclosures

The Business Responsibility and Sustainability Reporting (BRSR) framework has quickly become a defining feature of sustainability reporting in India. Rooted in the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), BRSR serves as a structured disclosure mechanism for the top 1000 listed companies and is an important regulatory development under SEBI's LODR requirements. For companies not currently reporting under any global framework, BRSR serves as the primary mechanism for disclosing sustainability performance.

The rise in BRSR adoption is encouraging. In FY 2024–25, more than 1200 companies reported under the framework — a 4% increase over the previous year and 14% higher than in 2022–23. Clearly, sustainability reporting is gaining momentum in the Indian corporate sector.

The framework’s scope is wide-ranging, covering environmental parameters like energy and emissions, social aspects such as employee well-being and human rights, and governance indicators including board diversity and ethical conduct. In many ways, BRSR provides a strong baseline and a much-needed regulatory nudge to mainstream ESG practices in Indian businesses.

That said, sustainability reporting is a rapidly evolving space. With the introduction of new global standards in 2025, particularly on climate change adaptation and biodiversity, the landscape is shifting. This presents a timely opportunity for Indian companies to reflect on how they can voluntarily build on their BRSR disclosures to enhance the depth, transparency, and impact of their sustainability communications.

The rise in BRSR adoption is encouraging. In FY 2024–25, more than 1200 companies reported under the framework — a 4% increase over the previous year and 14% higher than in 2022–23. Clearly, sustainability reporting is gaining momentum in the Indian corporate sector.

Recognizing the Strength of BRSR

Before exploring areas for further enhancement, it's worth acknowledging the many strengths of BRSR.

One of its most significant advantages is that it’s statutorily mandated — making it one of the few sustainability frameworks globally that is embedded in regulation. This gives it teeth and ensures accountability at the highest levels.

Another noteworthy aspect is that BRSR is sector-agnostic, allowing all reporting companies to respond to the same set of indicators under the nine NGRBC principles. This structure ensures a minimum common ground, encouraging uniformity and comparability across industries.

Additionally, BRSR aligns conceptually with the UN Sustainable Development Goals (SDGs) and makes thoughtful references to international frameworks like the Global Reporting Initiative (GRI). This alignment enables companies to fulfil both domestic and (to some extent) global reporting expectations through a single format.

The combination of qualitative disclosures and quantitative performance indicators, including voluntary disclosures on the sustainability performance of value chain partners, gives companies space to communicate both initiatives and impact.

Moreover, the introduction of assurance/assessment requirements under the BRSR Core reflects the growing focus on data integrity and credibility.

Opportunities for Enhanced Reporting

There’s no denying that the BRSR framework provides a comprehensive view of sustainability issues. However, in some critical areas, the framework leaves room for deeper and more strategic disclosures. Consider this example: Company A reports that it has implemented five initiatives over the past year, resulting in a 5% reduction in its GHG emissions. Meanwhile, Company B has publicly committed to a 10% emissions reduction over the next five years. Alongside this, it discloses its innovation-driven efforts and product stewardship strategies aimed at de-carbonizing both its operations and value chain. It also shares emissions data across all categories for the past five years, showing a consistent downward trend.

While Company A’s actions are certainly positive, the absence of a long-term vision or forward-looking plan limits the clarity of its sustainability journey. There’s no indication of whether these reductions will continue or how they fit into a broader strategy. In contrast, Company B’s approach reflects a more mature understanding of climate responsibility. Its disclosures provide stakeholders with both context and confidence — showcasing intent, action, and measurable progress over time.

This kind of strategic depth and continuity in reporting can elevate a company from being “also performing" to being seen as a “actively participating”. Ultimately, all sustainability actions should be integrated into the company's overarching business strategy to ensure long-term impact and credibility.

As sustainability frameworks continue to evolve globally, Indian companies have the opportunity to voluntarily enhance their disclosures while remaining fully compliant with BRSR. This is not about responding to external reporting prescriptions or adopting additional disclosures simply because global standards expect them. Rather, it is about addressing the most material sustainability issues that influence long-term business performance, stakeholder trust, and value creation. In this context, the following section outlines four key areas where companies may consider strengthening their reporting to reflect the true breadth and maturity of their sustainability performance.

This kind of strategic depth and continuity in reporting can elevate a company from being “also performing" to being seen as a “actively participating”. Ultimately, all sustainability actions should be integrated into the company's overarching business strategy to ensure long-term impact and credibility.

Climate Change: Disclosing Strategy, Not Just Activities

The 2015 Paris Agreement established a goal to limit average global temperature rises to well below 2°C above pre-industrial levels and to pursue efforts to limit the increase to 1.5°C and achieve net-zero GHG emissions globally by mid-century to limit the risk of irreversible climate impacts. Physical impacts such as extreme weather events, resource scarcity, and operational disruptions in the value chains are increasingly common. Alongside these are transition risks, including evolving regulations, technological shifts, and changing consumer expectations. For businesses, this translates into financial risk, reputational exposure, and growing scrutiny from investors and stakeholders. Climate resilience and transition planning should now be central to long-term corporate strategy irrespective of the location, sector or size.

Global standards have progressively sharpened their focus on climate change. Global Frameworks like the Global Reporting Initiative (GRI) and the European Sustainability Reporting Standards (ESRS E1) require companies to disclose climate-related risks and opportunities, scenario analysis, transition plans, and short-, medium-, and long-term emission reduction targets. The ISSB's IFRS S2 also integrates climate disclosures with financial reporting, highlighting the materiality of climate on business outcomes. Emissions across Scope 1, 2, and 3, net-zero commitments, and alignment with global climate goals are now standard expectations for many international companies.

Under BRSR, disclosures related to the adaptation and mitigation of climate-related risks are required only if the company identifies them as material. Even when such risks are deemed material, the framework does not prescribe a structured approach for reporting past performance, progress against targets, or forward-looking strategies for climate transition—either within the company or across its value chain. In the absence of defined prompts or formats, companies may be less inclined to provide detailed and consistent climate-related disclosures.

What Companies Can Voluntarily Report Further:

To align with global best practices, Indian companies can begin by disclosing their long-term climate transition plans, including emission reduction targets, progress on meeting the targets, and how climate risks are integrated into their enterprise risk management frameworks. Companies may also choose to report their Scope 3 emissions inventories, adaptation strategies for the value chain. Such disclosures not only enhance transparency but also demonstrate climate maturity to global stakeholders.

In the absence of defined prompts or formats, companies may be less inclined to provide detailed and consistent climate-related disclosures

Biodiversity: From Presence to Performance

Biodiversity plays a foundational role in maintaining ecosystem services — including water purification, climate regulation, soil fertility, and food security. The degradation of natural ecosystems due to unsustainable industrial activity has direct and indirect consequences on business operations, particularly for sectors like agriculture, mining, infrastructure, and manufacturing. Loss of biodiversity also contributes to climate change by weakening carbon sinks like forests, wetlands, and oceans and destabilizes many of the natural life-support systems. Therefore, biodiversity demands particular attention from companies operating in or near ecologically sensitive areas.

Reporting beyond BRSR

Global frameworks have recently introduced dedicated biodiversity disclosures. The Taskforce on Nature-related Financial Disclosures (TNFD) and the ESRS E4 (Biodiversity and Ecosystems) now require companies to identify and assess their nature-related risks, dependencies, and impacts. Disclosures include site-specific data, land-use change, restoration commitments, and measurable conservation outcomes. Companies are expected to align their goals with international frameworks like the Kunming-Montreal Global Biodiversity Framework, including the 2030 targets and the 2050 vision of “Living in harmony with nature.”

Under Principle 6 of BRSR, companies are asked to disclose operations near protected or sensitive areas, conduct of Environmental Impact Assessments (EIA), and compliance with environmental clearance conditions. There is also a narrative prompt to describe whether operations adversely affect such ecosystems and any restoration efforts undertaken. However, these disclosures remain largely qualitative. There is no requirement to report on measurable biodiversity outcomes, specific commitments to halt biodiversity loss, or the use of scientific methods to track changes over time.

What Companies Can Voluntarily Report Further:

To enhance biodiversity-related disclosures, companies can begin identifying key dependencies and impacts on natural ecosystems, especially in areas of high ecological sensitivity. They can disclose the outcomes of baseline biodiversity assessments, set restoration or conservation targets, and publish time-bound commitments aligned with the Global Biodiversity Framework. Companies may also choose to map biodiversity risks in their value chain and share progress on nature-positive initiatives, contributing to global goals while strengthening their sustainability profiles.

 There is no requirement to report on measurable biodiversity outcomes, specific commitments to halt biodiversity loss, or the use of scientific methods to track changes over time.

Sector-Specific ESG Context: Adding Relevance and Clarity

While overarching ESG principles apply across industries, many material sustainability risks and opportunities are sector specific.  International standards like SASB (Sustainability Accounting Standards Board) and GRI Sector Standards emphasize the importance   of sector-specific disclosures. These frameworks guide companies to report on topics that are financially and operationally material to their specific industry. Sector-focused reporting adds precision, comparability, and relevance, helping investors and stakeholders better evaluate ESG performance within the appropriate business context.  

BRSR has been designed as a sector-agnostic framework to provide a baseline of disclosures across all industries. While this approach ensures consistency, it does not specifically address unique ESG issues faced by different sectors unless voluntarily disclosed by the company. Although the leadership indicators allow space for deeper disclosure, there is no formal requirement for companies to tailor their sustainability reporting based on their industry context. Consider a company operating in the chemical manufacturing sector. This industry is characterized by a highly complex and diverse value chain. Scope 3 emissions in the sector are particularly significant—especially those arising from the use of sold products (Category 11) and upstream emissions linked to raw material inputs (Category 1). Moreover, chemical processes themselves tend to be carbon-intensive and challenging to decarbonize. That said, the sector also presents significant opportunities to reduce Scope 3 emissions by adopting bio-based or recycled feedstocks, partnering with customers to lower emissions during product use, and developing low-carbon product formulations.  Since Scope 3 emissions disclosure under BRSR is voluntary, companies may not be sufficiently encouraged to take a leadership role in climate strategy through innovation, collaboration, and product transformation—areas that hold significant potential for reducing these emissions.

Including such sector-relevant information not only strengthens transparency but also gives stakeholders a clearer view of how companies are managing sustainability issues most material to their industry.

What Companies Can Voluntarily Report Further:

Companies can enhance the relevance of their BRSR reports by incorporating sector-specific ESG metrics aligned with frameworks like SASB, GRI, or other global standards. Take the chemical industry, for instance—it faces distinct challenges such as accidental spills, leaks, and transportation risks involving hazardous substances. These events, though infrequent, can have serious and lasting environmental and public health impacts. However, areas like emergency preparedness, quantitative spill reporting, and hazardous material transport risk management are not explicitly required under BRSR’s framework. Including such sector-relevant information not only strengthens transparency but also gives stakeholders a clearer view of how companies are managing sustainability issues most material to their industry.

Sustainability Targets & KPIs: Turning intent into accountability

Targets, KPIs and performance are the cornerstone of sustainability reporting. Well-defined sustainability targets offer strategic direction and signal ambition, while key performance indicators (KPIs) translate these goals into quantifiable metrics. Together, they enable consistency and comparability over time, across sectors, and among peers, effectively bridging the gap between high-level commitments and on-the-ground actions. Transparent performance reporting also reinforces accountability, helping build credibility and trust with investors, regulators, customers, and broader stakeholder communities.

Global frameworks like GRI 3, ESRS 1, and ISSB require that for every material topic, companies disclose their management approach, performance indicators, baselines, targets, and progress to date. Targets are expected to be specific, time-bound, and where possible, science-based. Companies must also explain how targets are embedded into governance and business strategy, and how progress is monitored internally and externally.

BRSR allows companies to disclose their sustainability targets and performance under each of the nine NGRBC principles. In the current structure, companies can use the Section B table format to list their commitments and corresponding performance. However, the space provided for these disclosures is relatively limited, and there is no explicit requirement to elaborate on the rationale behind the targets, the KPIs used, or progress over time. As a result, the critical role of targets and performance tracking in driving meaningful sustainability action may not be adequately reflected. While the framework offers flexibility in how this information is presented, the level of detail and clarity varies significantly across companies.

However, the space provided for these disclosures is relatively limited, and there is no explicit requirement to elaborate on the rationale behind the targets, the KPIs used, or progress over time.

What Companies Can Voluntarily Report Further:

To build confidence and demonstrate progress, companies can complement BRSR with detailed reporting of sustainability KPIs, historical performance data, and forward-looking targets aligned with global or national climate goals. This can be presented in a separate ESG report or an annex to the BRSR. Clear articulation of target-setting methodologies, progress monitoring mechanisms, and external assurance (where applicable) can significantly improve the credibility and impact of sustainability disclosures.

A Constructive Way Forward: Voluntary Disclosures & ESG Reports

BRSR provides a strong and standardized foundation. But it’s not a ceiling. As sustainability reporting grows more mature, Indian companies have the flexibility and space to voluntarily add to their disclosures, ensuring their reports reflect the full scope and maturity of their sustainability performance.

One practical approach is to develop a comprehensive ESG or sustainability report and then reference relevant sections within the BRSR format. This doesn’t mean companies need to formally adopt global standards but rather incorporate their key reporting elements to the extent possible within existing disclosures. It offers a streamlined and efficient way to meet both domestic regulatory requirements and the growing expectations of international investors, rating agencies, and other stakeholders.

By preparing a single, well-structured report that reflects global good practices and mapping it thoughtfully to BRSR, companies can present a unified ESG narrative. This method supports efficiency while positioning Indian businesses to engage confidently with global peers — and lead the way in credible, transparent sustainability communication.

By preparing a single, well-structured report that reflects global good practices and mapping it thoughtfully to BRSR, companies can present a unified ESG narrative.

Final Reflections

As sustainability continues to move from the periphery to the core of corporate strategy, reporting needs to keep pace. BRSR has laid the groundwork, offering Indian companies a reliable and standardized format. But for those seeking to lead, there's value in going a step further. By voluntarily adopting global best practices, enhancing transparency, and embedding sector-specific strategies, companies can showcase not just compliance, but commitment. And in today’s ESG-driven economy, that distinction matters.

Just as global frameworks have grown to include new focus areas, BRSR too has the potential to evolve over time. In fact, by observing how Indian companies are voluntarily expanding their disclosures, policymakers may gather valuable insights to inform future updates to the BRSR itself.

This is a shared journey — and companies can play an active role in shaping the future of sustainability reporting in India.