Global and Indian Sustainability Reporting Frameworks
Sustainability reporting today is guided by multiple international and Indian frameworks. Understanding the differences between GRI, IFRS, ESRS and BRSR is critical for companies to meet regulatory expectations, attract investors, and build stakeholder trust. In India, SEBI’s BRSR is mandatory, while global frameworks like GRI, IFRS S1, and ESRS are also influencing Indian companies. We specialize in BRSR and GRI and also guide clients on how these align with global frameworks like ESRS and IFRS. Here is a quick guide to the most prevalent frameworks today:
SEBI-BRSR Framework
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Based on 9 NGRBC Principles aligned to UN Sustainable Development Goals.
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Mandatory for Top 1000 listed entities of India
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Includes value chain reporting of core KPIs from FY 2025-26
Business Responsibility and Sustainability Reporting (BRSR Framework)
The Business Responsibility and Sustainability Reporting (BRSR) framework represents a landmark shift in India’s approach to non-financial disclosures. Mandated by SEBI, BRSR replaces the earlier Business Responsibility Reporting (BRR) framework and aims to integrate Environment, Social, and Governance (ESG) factors into the core functioning of companies.
History of BRSR Reporting
Ministry of Corporate Affairs, recognizing the need for an evolved framework aligned with international developments, framed the National Guidelines on Responsible Business Conduct (NGRBC) in 2019 aligning with the UN SDGs.
Based on these NGRBC principles, SEBI introduced the Business Responsibility and Sustainability Reporting (BRSR) framework in 2021, making it mandatory for the top 1,000 listed companies. BRSR addressed key gaps in the earlier BRR framework by enhancing the accuracy, standardization, and granularity of sustainability disclosures. In 2023, SEBI introduced the BRSR Core, a subset of key KPIs requiring assurance for the listed companies and their major value chain partners.
Objectives of BRSR Reporting
The BRSR framework aims to:
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Promote the integration of ESG factors into everyday business operations.
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Provide investors and stakeholders with a transparent view of the company’s non-financial performance.
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Facilitate peer comparison within industries through standardized and consistent disclosures.
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Elevate Indian sustainability reporting standards to global benchmarks.
Three Versions of BRSR Reporting
To cater to different categories of companies, BRSR has three versions:
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BRSR Comprehensive
Mandatory for the top 1,000 listed entities, covering detailed disclosures across all 9 NGRBC principles.
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BRSR Core
A focused subset with 9 key KPIs, requiring assurance by an independent practitioner. The structure consists of key disclosures like GHG Emissions, POSH complaints, Cyber Attacks, openness of business etc.
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BRSR Lite
A voluntary version with simplified disclosures, designed for smaller listed or large unlisted companies initiating their sustainability journey.
Applicability of BRSR Reporting based on Market Capitalization
A critical determinant for BRSR applicability is a company’s market capitalization. As per SEBI’s 2024 amendment to the LODR Regulations:
Cut-off date for computing the top 1,000 and top 500 companies is 31st December and BRSR or BRSR Core compliance begins from the following financial year.
Examples:
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A new entrant in the top 1,000 on 31st Dec 2024 must file BRSR Comprehensive for FY 2025–26.
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A new entrant in the top 500 must also ensure assurance of BRSR Core KPIs.
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Companies that drop out of the top 1,000 must continue BRSR reporting for three subsequent years, regardless of future market cap.
Structure of BRSR Reporting
The BRSR Comprehensive format is structured into three sections:
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Section A: General Disclosures: Includes company name, contact information, listing status, and whether third-party assurance has been obtained.
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Section B: Management & Process Disclosures: Covers governance structures, ESG policies, roles, responsibilities, and processes.
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Section C: Principle-wise Performance: Requires quantitative and qualitative disclosures aligned with each of the 9 NGRBC principles.
Within Section C, there are two types of KPIs:
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Essential Indicators (Mandatory) – Relating to the company’s own ESG performance.
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Leadership Indicators (Voluntary) – Reflecting sustainability efforts across the value chain and company’s proactiveness.
Also read Steps of BRSR Reporting
Also see BRSR related videos
Global Reporting Initiative
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Most widely used global sustainability standard
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Focus on impact materiality
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Complements Indian BRSR reporting
Global Reporting Initiative (GRI):
Global Reporting Initiative Standards (GRI Standards) are the first and the most widely used standards by companies for sustainability reporting. The work on these standards started way back in 1997 and these standards continue to evolve even today to meet emerging global sustainability expectations. GRI has been developed in public interest by muti-stakeholder experts based on various international agreements of the United Nations (UN), International Labor Organization (ILO) and Organization for Economic Co-operation and Development (OECD). It also takes references from various national and international guidelines on specific topics. It is a global standard and any business that has to report its sustainability related information under any regulation is free to use or refer to the GRI Standards.
Structure of GRI Standards
GRI are a system of interrelated standards that specify the disclosure requirements and reporting principles that the companies must comply with to publicly disclose their significant impacts on economic, environment and people, including impact on their human rights. There are 3 categories of the standards:
Universal Standards
GRI - 1: Requirements and Principles of GRI Standards. It specifies the 8 principles which companies need to follow for reporting under the GRI Standards. It elaborates the 4 pillars of the GRI Standards viz.
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Impact,
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Stakeholder,
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material topics, and
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Due diligence
GRI - 2: General Disclosures about the company. The 30 disclosure points under this standard provide details about the company's activities, employees, policies management and stakeholder engagement practices.
GRI - 3: Guidance on Material Topics of the company. GRI gives a lot of thrust on materiality and determination of material topics. Material topics means topics that represent the most significant impacts of the business on economy, environment and people (e.g. GHG Emissions, Corruption). GRI 3: Material Topics provides step by step guidance on how to determine material topics. Companies need to document the process of determining material topics. It expects companies to continually and independently, keep assessing its actual and potential negative impacts and add new material topics.
Sector Standards: GRI 11 -onwards
Sector specific material topics. GRI identifies various sectors of companies and has separate sector specific standard for each of the sectors (e.g. oil and gas, coal, mining, etc.). Every sector standard lists the likely material topics for that sector. Companies need to report/disclose on each of the listed material topics, if it falls in the scope of the sector standard. For example, GRI 11 applies to companies with activities in Oil and Gas sector. It lists 22 topics (including GHG emissions, employment practices, local communities etc.) which are likely to be material to this sector.
Topic Standards
GRI 201- onwards - Economic topics
GRI 301 - onwards - Environmental topics
GRI 401- onwards - Social topics
Each of the topic standard gives an overview of the topic determined material by the company. Companies need to report their impact under the topic and also disclose how it manages such impacts. Every topic standard gives certain "requirements" which are mandatory to be disclosed. It also lists "recommendations" which are encouraged to be disclosed by the companies.
What to report in GRI Standards?
GRI standards requires the business to explain in depths as to how it manages each of its material topics. If a material topic has been identified, it has to describe
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the actual and potential, negative and positive impacts
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describe the activities or business relationships involved with the negative impacts
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describe its policies or commitments regarding the material topic
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describe actions taken to manage the topic and related impacts
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report information about the effectiveness of the actions taken and
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describe how stakeholders were engaged and kept informed of the actions taken.
GRI makes it mandatory to disclose all "requirements" of any Topic standard and encourages to also report "recommendations" of the standard. However, GRI stipulates 4 scenarios for non-disclosures:
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Not applicable
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Legal Prohibitions
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Confidentiality constraints and
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Information incomplete/unavailable.
Points (3) and (4) can be used as an exception only. Such a reason should accompany a explanation of the reasons.
Reporting Options in GRI Standards
GRI offers two distinct reporting options:
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“In Accordance With” GRI Standards
This is the most comprehensive level, requiring full compliance with the 9 criteria outlined in GRI 1: Foundation 2021. It ensures consistency, comparability, and completeness of disclosures.
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“With Reference To” GRI Standards
This more flexible option allows companies to select specific GRI Standards or parts of them, for reporting on particular topics. This is often used when an organization is starting out or reporting on select issues only.
GRI does not mandate companies to obtain external assurance when reporting in accordance with the GRI Standards but is encourages to do so to enhance the credibility of sustainability reporting.
Also read: Differences between BRSR and GRI Reporting
Integrated Reporting Framework
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Based on integrated thinking principles
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Business value is expressed in terms of 6 capitals
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Focuses primarily on providers of financial capital
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Used by many global companies
Integrated Reporting <IR>
The Integrated Reporting (<IR>) Framework, launched in 2013, marked a major shift in corporate reporting. It combines financial reporting with ESG performance, highlighting their interdependencies to provide a holistic view of an organization’s ability to create value. The framework promotes long-term thinking and broadens the understanding of what value truly means. It also serves as a catalyst for embedding integrated thinking within an entity’s strategy and operations.
The <IR> Framework is primarily designed for providers of financial capital, particularly investors with a long-term perspective. By aligning financial and non-financial information, it helps stakeholders assess how an entity’s strategy and performance contribute to sustainable value creation.
The Role of the Business Model and Capitals in Integrated Reporting
At the heart of the <IR> Framework lies the entity’s business model, which demonstrates how value is created over time. The framework recognizes six key “capitals”:
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Financial capital
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Manufactured capital
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Intellectual capital
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Human capital
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Social and relationship capital
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Natural capital
Sustainability is regarded as one of these capitals, integral to the overall value creation strategy. The framework emphasizes that sustainability-related risks and opportunities are critical to an entity’s ability to generate value for investors.
The “Apply and Explain” Approach of Integrated Reporting
The <IR> Framework is enabling rather than prescriptive. It encourages organizations to integrate external environmental awareness and principles of integrated thinking into decision-making and operations. Entities are expected to explain how they achieve performance targets across all capitals.
This “apply and explain” model gives organizations flexibility to interpret disclosure topics, assess materiality, and decide on report structure. As a result, the quality and depth of <IR> reports can vary significantly across entities.
A key principle of the framework is that each entity’s value creation model is unique. Management has the discretion to assess the external environment and adapt the business model accordingly. Indicators used for disclosure are expected to be relevant to the entity’s own circumstances and internal practices. This structural flexibility ensures that disclosures are tailored but also makes comparison between entities challenging.
Value Chain in Integrated Reporting
The <IR> Framework underlines that value created for the entity is linked to value created for others, including value chain partners. Entities are encouraged to assess and disclose the effects of their activities on capitals across their value chain. While such disclosures enhance report quality, the absence of specific guidelines means that inclusion of value chain information remains at the entity’s discretion.
Also read: Differences between <IR> and GRI Reporting
IFRS S1
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Companies disclose the financial impacts of the sustainability related risks and opportunities (financial materiality)
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Gradually being adopted in many countries
International Financial Reporting Standard (IFRS S1)
This reporting standard has been issued by the International Sustainability Standards Board (ISSB). Companies reporting under this standard disclose the sustainability related financial disclosures. This means reporting the financial impacts of the sustainability related risks and opportunities for users of the financial statements, particularly its investors (financial materiality). Sustainability related risks may affect the company's cash-flows, hinder access to finance or may adversely affect its cost of raising fresh capital. Disclosures under this standard should be useful for making investment decisions in the entity.
Material information under IFRS-S1
The standard defines material information as any information which on being omitted, obscured or misstated could influence the decision of the investors. All sustainability related information shall be connected to the financial statements of the entity. Information about a possible future event is material if the potential effects are significant and the likelihood of the event is apparent. Companies shall judge as to what is material information on every reporting date.
Disclosure topics for IFRS-S1
Companies shall identify disclosure topic i.e. a sustainability related risk or opportunity, for reporting based on the industry it belongs. The disclosure topics can be referenced from IFRS Sustainability Disclosure Standard or SASB Standards. For e.g. the disclosure topics for an appliance manufacturing company as per SASB standards are Product Safety and Product Life Cycle Environmental Impacts.
Disclosures under IFRS -S1
Companies reporting under IFRS-S1 shall make disclosures in the following aspects:
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Governance: Users of financial statements should be able to understand the policies and processes in place in the company to monitor and manage the sustainability related risks and opportunities.
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Strategy: Users of financial statements should be able to understand the effects of sustainability related risks and opportunities on the business model and value chain of the company.
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Risk Management: Users of financial statements should be able to understand the processes to identity, assess, prioritize and monitor sustainability related risks and opportunities as a part of overall risk management process of the company.
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Metrics and Targets: Users of financial statements should be able to understand the metrics used to measure the company's performance with respect to any targets set by the company (or set by regulation) in relation to sustainability related risks and opportunities.
CSRD-ESRS Framework
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Reporting the sustainability related risk and opportunities and also impact of their activities on the sustainable development (double materiality)
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Applicable to European entities of a certain size
European Sustainability Reporting Standards (ESRS)
This framework is applicable to European entities of a certain size to report the sustainability related risk and opportunities on their finances and also impact of their activities on the sustainable development (double materiality). The ESRS are a set of 12 standards covering a range of environmental, social, and governance topics.
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Cross cutting standards: ESRS 1 and ESRS 2
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Topical Standards:
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E1 to E5 - Environment related
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S1 to S4 - Social related
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G1 - Governance related
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Sector Specific Standards
Cross-cutting standards and topical standards are sector-agnostic, meaning that they apply to all companies. Topical and sector standards apply if the topics / impacts are material for the company.
Double materiality in ESRS
Double materiality is central to ESRS. Companies must assess materiality both from the impact side i.e. how the company’s operations affect environment, people, society and the financial side i.e. how sustainability matters affect the company financially, e.g. risks or opportunities associated with them. ESRS 1 requires that materiality assessments be conducted, documented, updated with both dimensions.
Reporting Areas in ESRS
ESRS is structured around 4 reporting areas:
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How governance structures oversee sustainability topics
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Impact of sustainability related risks and opportunities on the business model and strategy
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Process of identifying and assessing material impacts, risks and opportunities
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KPIs used to monitor sustainability performance.
Value Chain Reporting in ESRS
Companies must identify material sustainability matters that arise not just from their own operations, but also across the value chain. Companies must disclose the actual or potential environment and social impacts in value chain. They should also report how the value chain influences the company’s sustainability-related risks and opportunities. ESRS provides a grace period of 3 years for value chain disclosures. Companies can limit disclosures where data is unavailable during this period.