Environmental, Social and Governance (ESG) - Principles and Practice · Board's Accountability on ESG

SEBI BRSR, BRSR Core and Board Accountability on ESG

Updated 11 October 2026 · Fact-checked

BRSR is the Business Responsibility and Sustainability Report that SEBI requires top listed companies to file under the LODR Regulations. It covers ESG data in three sections and nine principles. BRSR Core is a smaller set of key indicators that needs reasonable assurance. The board is accountable for the report's content and oversight.

Understand Regulatory Framework and Disclosure: SEBI BRSR

Boards in India are accountable for ESG performance in two ways. The Companies Act, 2013 sets duties for directors and the Board's Report. SEBI's LODR Regulations, 2015 require listed companies to report on ESG through the annual report. This topic is about the second route.

The disclosure format is the Business Responsibility and Sustainability Report (BRSR). It replaced the earlier Business Responsibility Report (BRR). The BRR was largely narrative. The BRSR asks for measurable data, so investors can compare companies and track year-on-year change.

The BRSR has three sections. Section A is general disclosures: company details, products and services, operations, employees, holding and subsidiary companies, CSR details, and transparency and grievance data. Section B covers management and process disclosures: policies, governance, leadership and oversight. Section C covers principle-wise performance, split into Essential and Leadership indicators across nine principles drawn from the National Guidelines on Responsible Business Conduct (NGRBC).

Board accountability is built into Section B. The report carries a statement by the director responsible for the BRSR, and discloses the highest authority responsible for implementing the policies. It also discloses whether the board or a committee reviews the NGRBC principles, and how often. The board cannot treat the report as only an operations or sustainability team task.

BRSR Core is a subset of key performance indicators (KPIs) taken from the BRSR, grouped under attributes such as greenhouse gas footprint, water, energy, waste, employee and worker wellbeing, gender diversity, inclusive development, fairness in business, and openness of business. These KPIs require reasonable assurance from an independent assurance provider. Applicability is phased by market capitalisation and the listed entity must also consider value chain disclosures under SEBI's circulars. Always check the latest SEBI circular for the current thresholds and dates.

Key rules to remember

Source of the requirement: SEBI (LODR) Regulations, 2015, Regulation 34(2)(f) → BRSR in the annual report; BRSR is a part of the annual report of the listed entity. It applies to the top 1,000 listed entities by market capitalisation. Confirm the current cut-off in the latest SEBI circular.
Structure of BRSR: Section A (General) + Section B (Management and Process) + Section C (Principle-wise Performance); Section C has Essential Indicators, which are mandatory, and Leadership Indicators, which are voluntary.
Number of principles: 9 principles of NGRBC; Principle 1 is ethics, transparency and accountability. The remaining eight cover goods and services, employee wellbeing, stakeholders, human rights, environment, public policy, inclusive growth and consumer value.
BRSR Core: BRSR Core = selected KPIs from BRSR + reasonable assurance; It is a subset, not a separate report. Assurance is by an independent assurance provider.
BRSR vs BRR: BRR = narrative, voluntary-style format; BRSR = quantitative, structured, comparable; BRSR replaced BRR. Use this contrast for any difference question.
Board accountability disclosures: Director's statement + highest authority for policy implementation + committee or board review of NGRBC; These are in Section B. Quote them in answers on board responsibility.

How to solve Regulatory Framework and Disclosure: SEBI BRSR questions

Use the same structure for any question on the BRSR framework or board accountability. It follows the provision, analysis, conclusion pattern.

1Identify what is asked: framework description, difference between formats, applicability, or board responsibility in a given case.
2State the legal source first: SEBI LODR Regulations, 2015 and the requirement to include the BRSR in the annual report. Add the Companies Act link if the question is about directors' duties.
3Describe the relevant part of the format: Section A, B or C, or BRSR Core, with the exact items involved.
4Apply the facts: check the company's listing status, market capitalisation and whether the disclosure is Essential or Leadership.
5Link to board accountability: the director's statement, the authority responsible, and board or committee review.
6Add the practical compliance point: data collection, internal controls, assurance for Core indicators, and timing with the annual report.
7Conclude in one or two lines that answer the exact question, and flag that thresholds should be checked against the latest SEBI circular.

Quickest way: Three-block answer: Source, Content, Accountability

When to use it: Use when you have limited time and the question asks you to explain or discuss BRSR or board responsibility.

Source block: LODR Regulation 34(2)(f), top 1,000 listed entities, part of the annual report.
Content block: Sections A, B, C, nine NGRBC principles, Essential and Leadership indicators, BRSR Core with reasonable assurance.
Accountability block: director's statement, highest authority, board or committee review, and the board's duty to ensure accurate data.
Finish with a one-line conclusion and, if a comparison is asked, add the BRSR versus BRR contrast.

Common mistakes in Regulatory Framework and Disclosure: SEBI BRSR

Treating BRSR Core as a separate report from BRSR.
The names sound like two documents.
Fix: Write that BRSR Core is a subset of KPIs within the BRSR that needs reasonable assurance.
Saying the BRSR has only Essential indicators or that all indicators are mandatory.
Students skip the Essential and Leadership split in Section C.
Fix: State that Essential indicators are mandatory and Leadership indicators are voluntary.
Describing BRR as if it were still the current format.
Older notes and textbooks still talk about BRR.
Fix: Say that BRSR replaced BRR and mention the shift from narrative to quantitative disclosure.
Giving no board-level detail when asked about board accountability.
Students describe the format but not who is answerable.
Fix: Always mention the director's statement, the highest authority for implementation and board or committee review in Section B.
Quoting thresholds and dates from memory as fixed.
SEBI revises applicability and assurance timelines through circulars.
Fix: Quote the principle of phased applicability and say that figures should be confirmed against the latest SEBI circular.
Confusing the nine NGRBC principles with the three BRSR sections.
Both are lists used in the same report.
Fix: Remember that sections are A, B, C and the nine principles sit within Sections B and C.

Worked examples

Example 1

Explain the structure of the Business Responsibility and Sustainability Report under SEBI LODR and state how it brings in board accountability.

Show the solution

Source: Regulation 34(2)(f) of SEBI LODR, 2015 requires the top listed entities by market capitalisation to include a BRSR in the annual report.
Structure: Section A has general disclosures about the entity. Section B has management and process disclosures. Section C has principle-wise performance against nine NGRBC principles.
Section C splits indicators into Essential, which are mandatory, and Leadership, which are voluntary.
Board accountability: Section B requires a statement by the director responsible for the BRSR, the highest authority for policy implementation, and disclosure of whether the board or a committee reviews the principles and how often.
Conclusion: the BRSR is a structured, data-based report, and the board is answerable for its content and oversight.

Answer: The BRSR is part of the annual report under Regulation 34(2)(f) of LODR. It has Sections A, B and C across nine NGRBC principles, with Essential and Leadership indicators. Section B places accountability on the board through the director's statement, the responsible authority and review disclosures.

Example 2

Aarav Textiles Ltd, a listed company, has so far filed a narrative Business Responsibility Report. Its Company Secretary asks how the BRSR differs and what extra work BRSR Core will need. Advise.

Show the solution

Provision: BRSR replaced BRR as the prescribed ESG disclosure format under LODR.
Difference: BRR was largely narrative. BRSR asks for quantitative, comparable data and has a fixed structure of Sections A, B and C.
Facts: the company must check if it falls within the applicable market capitalisation class and the current phase-in dates in the latest SEBI circular.
BRSR Core: the company must report the Core KPIs, such as greenhouse gas footprint, water, energy and waste, employee wellbeing and fairness in business, and get reasonable assurance from an independent assurance provider.
Practical points: set up data collection, internal controls and an owner for each KPI. The board or committee should review the data before approval of the annual report.
Conclusion: Aarav Textiles should move to BRSR, build assurance-ready processes for Core, and have the board oversee the process.

Answer: BRSR replaces the narrative BRR with structured quantitative disclosure. If applicable, Aarav Textiles must also report BRSR Core KPIs with reasonable assurance, set up reliable data processes, and ensure board-level review. Confirm thresholds and dates in the latest SEBI circular.

Exam tips

Open with the source: SEBI LODR, Regulation 34(2)(f), and the annual report link.
For comparison questions, use a two-column logic in plain text: format, nature of data, structure, assurance, status.
Quote at least one board-level disclosure from Section B in any accountability answer.
Do not quote cut-offs or dates with false certainty. Say they are phased and tell the examiner to confirm with the latest SEBI circular.
In case-based questions, end with a clear action list for the board and the Company Secretary.

Practice questions from Board's Accountability on ESG

Regulatory Framework and Disclosure: SEBI BRSR: frequently asked questions

What is the difference between BRSR and BRR?

BRR was a largely narrative report on the NGRBC principles. BRSR is structured and quantitative, with Sections A, B and C and measurable indicators. BRSR replaced BRR as the prescribed format.

What is BRSR Core?

BRSR Core is a subset of key indicators drawn from the BRSR. It covers areas such as emissions, water, energy, waste, employee wellbeing and fairness in business. These indicators need reasonable assurance from an independent provider.

Who is responsible for the BRSR in a company?

The board is accountable for it. Section B requires a statement by the director responsible, and disclosure of the highest authority for implementing the policies and whether the board or a committee reviews them.

Are Leadership indicators in the BRSR mandatory?

No. Essential indicators are mandatory for applicable entities. Leadership indicators are voluntary and show a higher level of ESG practice.