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Flowchart showing steps of BRSR Reporting: board commitment, organizational boundary, governance structure, material topics, data collection, report preparation, gap analysis, and assurance.

What is the BRSR Framework?

Non-financial reporting and ESG disclosure has gained global prominence as companies increasingly acknowledge the environmental and climate-related impacts of their operations. In line with this trend, the Securities and Exchange Board of India (SEBI) introduced the Business Responsibility and Sustainability Reporting (BRSR) framework in May 2021. The mandate requires the top 1000 listed entities by market capitalization to disclose their sustainability performance, thereby strengthening transparency and accountability to stakeholders.

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The corporate sustainability reporting in India through the BRSR framework is anchored in the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), which provide its foundational structure. It consists of 108 indicators, categorized into 68 Essential Indicators and 40 Leadership Indicators. While Essential Indicators are mandatory, Leadership Indicators remain voluntary for companies seeking to demonstrate advanced sustainability practices.

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By establishing this framework, BRSR enhances corporate ESG disclosure on non-financial performance, particularly sustainability, in three keyways: it encourages companies to embed ESG considerations into their core operations, it provides stakeholders with consistent and comparable information for decision-making, and it fosters responsible investment practices that account for both financial and non-financial parameters.

What are the Steps of BRSR Reporting?

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Board Level Commitment for BRSR Reporting

Companies must establish a dedicated Board-level committee to oversee sustainability reporting and ensure effective BRSR implementation. In smaller organizations, this responsibility can also be assigned to the CSR Committee or the Risk Management Committee, provided they have the mandate to supervise sustainability-related disclosures.

Defining the Organisational Boundary for BRSR

The first step in BRSR reporting is to clearly define the reporting boundary—whether on a standalone or consolidated basis. Many entities begin with standalone reporting to build capability and later expand to consolidated reporting across group entities.

Establishing Governance Structure for Sustainability Reporting

Under the BRSR framework, companies are expected to implement a robust governance structure aligned with the National Guidelines on Responsible Business Conduct (NGRBC). This includes drafting and approving sustainability policies at the Board level, establishing internal procedures, and creating control mechanisms for monitoring, periodic review, and continuous improvement. 

See NGRBC-Policy Mapping for policy related guidance and templates.

Determining Material Topics in BRSR Framework

Organizations must identify material topics that reflect their most significant impacts and risks. This includes both:

  • Impact Materiality: How business operations affect the economy, environment, and people.

  • Financial Materiality: How sustainability and climate-related risks may impact the company’s financial performance.

A materiality assessment should be conducted and mapped visually to highlight priority areas for stakeholders and future reporting.

BRSR Data Collection and Aggregation Process

BRSR compliance requires comprehensive data management across the 108 indicators. Companies should establish a data collection strategy, either using existing ERP systems or specialized sustainability tools. A cross-functional team must oversee data gathering, validation, and prioritization of Essential Indicators, with a secondary review to ensure accuracy and audit readiness.

Developing the BRSR Report for SEBI Compliance

SEBI provides a standardized BRSR template for disclosures. Companies can populate this manually or use reporting tools to streamline preparation. Before submission, the BRSR report should undergo a second-level validation to confirm accuracy, completeness, and consistency with regulatory expectations. Companies need to file an XBRL format of BRSR with the Stock Exchanges. 

Identifying Gaps and Building Long-Term BRSR strategy

BRSR reporting is a progressive journey, not a one-time compliance task. Companies should benchmark their disclosures against peers to identify gaps and opportunities. Rather than overstating performance, organizations should adopt a long-term improvement strategy that embeds sustainable practices and demonstrates measurable progress each year.

BRSR Assurance and Third-Party Assessment

To enhance credibility, companies can opt for third-party assurance of their BRSR reports—either voluntarily or as part of regulatory compliance. SEBI permits two levels:

  • Limited Assurance: Confirms that no material misstatements exist.

  • Reasonable Assurance: Provides a stronger opinion that the disclosures are true, fair, and reliable.

From FY 2025-26, SEBI also permits BRSR Assessments as a cost-effective alternative, making data verification more accessible for companies.

Need expert support with BRSR reporting? Our consultants guide you through every stage — from framework setup to final assurance

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