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Environmental, Social and Governance (ESG) - Principles and Practice · Sustainability Audit, ESG Rating and Emerging Mandates from Government and Regulators

BRSR and BRSR Core Mandates under SEBI LODR

Updated 11 October 2026 · Fact-checked

BRSR is SEBI's mandatory sustainability report for the top 1,000 listed entities by market capitalisation under Regulation 34(2)(f) of LODR. BRSR Core is a smaller set of KPIs under nine ESG attributes, with reasonable assurance and value chain disclosure for larger entities. Solve questions by identifying the entity, the year and the indicator, then applying the phasing.

Understand BRSR and BRSR Core Mandates

The Business Responsibility and Sustainability Report (BRSR) is the ESG disclosure that SEBI requires listed companies to publish in their annual report. It replaced the older Business Responsibility Report (BRR). The legal source is Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. It applies to the top 1,000 listed entities by market capitalisation, in the format SEBI specifies from time to time. For FY 2021-22, filing the BRSR was voluntary, and listed entities could file the BRR instead. The BRSR became mandatory from FY 2022-23.

The BRSR is built on the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC) issued by the Ministry of Corporate Affairs. It has three sections. Section A gives general disclosures about the entity. Section B covers management and process disclosures, such as policies, governance and oversight. Section C gives principle-wise performance disclosures. Each principle has Essential Indicators, which every reporting entity must answer, and Leadership Indicators, which are voluntary.

The main criticism of the BRSR was that the data was not comparable and not verified. SEBI's answer is BRSR Core. It is a subset of key performance indicators (KPIs), grouped under nine ESG attributes, that must undergo reasonable assurance by an assurance provider. Reasonable assurance is a higher level of comfort than a limited review. Intensity is worked out as quantity ÷ (revenue from operations ÷ PPP conversion factor), where the factor is the World Bank purchasing power parity (PPP) rate for India. This makes figures comparable across companies of different sizes. It is used for GHG emissions, water, energy and waste.

The nine BRSR Core attributes are: GHG footprint, water footprint, energy footprint, embracing circularity (waste), enhancing employee wellbeing and safety, enabling gender diversity, enabling inclusive development, fairness in engaging with customers and suppliers, and openness of business.

SEBI has also extended BRSR Core to the value chain. Under the July 2023 circular, value chain disclosure applies to the top 250 listed entities from FY 2024-25. The report covers key upstream suppliers and downstream distributors, selected by a share-of-purchases and share-of-sales test. Assurance of value chain data was voluntary at the start. SEBI has since revised the framework, including through a 2025 circular, so always state the position by reference to the latest circular.

Key rules to remember

Legal source
Regulation 34(2)(f), SEBI LODR, 2015 → BRSR in the annual report of the top 1,000 listed entities by market capitalisation
Voluntary for FY 2021-22, when entities could still file the BRR. Mandatory from FY 2022-23. It replaced the BRR. Quote the regulation number in every answer.
Structure of BRSR
Section A (General) + Section B (Management and Process) + Section C (Principle-wise Performance, 9 NGRBC principles)
Under Section C, Essential Indicators are mandatory and Leadership Indicators are voluntary.
BRSR Core phasing (July 2023 circular)
Reasonable assurance: top 150 in FY 2023-24 → top 250 in FY 2024-25 → top 500 in FY 2025-26 → top 1,000 in FY 2026-27
Learn it as a ladder of 150, 250, 500, 1,000. SEBI has revised the framework since, including through a 2025 circular, so check the latest SEBI circular.
Nine BRSR Core attributes
GHG, water, energy, circularity, employee wellbeing and safety, gender diversity, inclusive development, fairness to customers and suppliers, openness of business
Remember the first three as footprints (GHG, water, energy). Circularity is the fourth environmental attribute. The last five are social and governance attributes.
Emission, water, energy and waste intensity
Intensity = total quantity ÷ (revenue from operations ÷ PPP conversion factor)
The factor is the World Bank PPP rate for India. Used for Scope 1 + Scope 2 GHG, water consumption, energy and waste. The PPP adjustment makes cross-company comparison fair.
Value chain coverage
Value chain disclosure applies to the top 250 listed entities from FY 2024-25 (July 2023 circular), covering their key upstream and downstream partners selected by a share of purchases and sales
Assurance of value chain data was voluntary at the start. SEBI later revised the framework, including by a 2025 circular. Quote the percentage thresholds only if you are sure of the current circular.

How to solve BRSR and BRSR Core Mandates questions

Most questions on this topic are applicability or comparison questions, either a short case or a theory question. Use the same method each time.

  1. 1Identify the entity: is it in the top 1,000 by market capitalisation, and which rank band does it fall into (150, 250, 500 or 1,000)?
  2. 2Fix the financial year, because BRSR Core assurance and value chain duties are phased by year.
  3. 3Name the source: Regulation 34(2)(f) of SEBI LODR, 2015, and the SEBI circular that set the BRSR Core and value chain framework.
  4. 4Say which part is relevant: full BRSR (Sections A, B and C), BRSR Core KPIs, or value chain disclosure and assurance.
  5. 5Apply the rule to the facts: mandatory or voluntary, reasonable assurance or none, Essential or Leadership indicator.
  6. 6If numbers are given, compute the intensity or percentage and state the unit clearly.
  7. 7Conclude in one line, then add a practical point such as where the report is filed, the role of the assurance provider, or the board's oversight.

Quickest way: Rank-year-attribute check

When to use it: Use it for short case questions where you need to decide quickly whether BRSR, BRSR Core assurance or value chain duties apply.

  1. Write the company's market capitalisation rank and the financial year in the margin.
  2. Check the BRSR Core ladder: 150, 250, 500, 1,000 for FY 2023-24 to FY 2026-27.
  3. If the rank is within 250 and the year is FY 2024-25 or later, add value chain disclosure. For earlier years, such as FY 2023-24, it does not apply.
  4. Match any KPI in the question to one of the nine attributes and name it.
  5. Write the conclusion with the regulation number and the words reasonable assurance.

Common mistakes in BRSR and BRSR Core Mandates

  • Treating BRSR and BRSR Core as the same thing.

    Both carry the BRSR name and appear in the same annual report section.

    Fix: State that BRSR is the full report on the nine NGRBC principles, while BRSR Core is a smaller KPI set under nine attributes that needs reasonable assurance.

  • Saying all BRSR content must be assured.

    Students assume that the word assurance applies to the whole report.

    Fix: Only the BRSR Core KPIs require reasonable assurance. Other parts of the BRSR are not covered by the mandatory assurance.

  • Confusing the nine NGRBC principles with the nine BRSR Core attributes.

    Both sets have nine items and overlapping themes.

    Fix: NGRBC principles structure Section C of the full BRSR. BRSR Core attributes group the assured KPIs. Keep two separate lists.

  • Quoting the phasing years or ranks from memory without linking them to the circular.

    SEBI has revised timelines, and students mix up the original and later positions.

    Fix: Learn the ladder of 150, 250, 500 and 1,000, name the SEBI circular, and add that timelines can be revised.

  • Calling Leadership Indicators mandatory.

    Students read the indicators as one list.

    Fix: Essential Indicators are mandatory for all reporting entities. Leadership Indicators are voluntary.

  • Forgetting the PPP adjustment when defining intensity.

    Students treat intensity as plain emissions per rupee of turnover.

    Fix: State that BRSR Core intensity uses revenue adjusted for purchasing power parity, so that entities can be compared.

Worked examples

Example 1

Kaveri Industries Ltd is ranked 420th by market capitalisation among listed entities. For FY 2025-26, the CFO asks whether the company must publish a BRSR and have its BRSR Core KPIs assured. Advise.

Show the solution
  1. Entity: rank 420 is within the top 1,000, so Regulation 34(2)(f) of SEBI LODR requires a BRSR in the annual report.
  2. Year: the question is about FY 2025-26.
  3. Phasing: under the July 2023 circular, reasonable assurance of BRSR Core applies to the top 500 in FY 2025-26. Rank 420 is within the top 500.
  4. Value chain: the company is outside the top 250, so the value chain disclosure framework does not apply to it at this stage.
  5. Practical point: the company should appoint an assurance provider, map the nine attribute KPIs, and prepare data trails before the year closes.

Answer: Kaveri Industries must publish a full BRSR and get its BRSR Core KPIs reasonably assured for FY 2025-26. It is outside the top 250, so value chain disclosure is not required of it. This is based on the phasing in SEBI's July 2023 circular, subject to any later revision.

Example 2

Meridian Steel Ltd reports Scope 1 and Scope 2 emissions of 90,000 tCO2e and revenue from operations of ₹4,500 crore. Compute the simple intensity per ₹ crore, and the BRSR Core intensity per ₹ crore of PPP-adjusted turnover. For illustration only, assume a PPP conversion factor of 20.

Show the solution
  1. Total Scope 1 + Scope 2 emissions = 90,000 tCO2e.
  2. Revenue = ₹4,500 crore.
  3. Simple intensity = 90,000 ÷ 4,500 = 20 tCO2e per ₹ crore.
  4. BRSR Core intensity = quantity ÷ (revenue ÷ PPP conversion factor). The factor is the World Bank PPP rate for India. The 20 used here is only an assumed figure for the exercise.
  5. PPP-adjusted turnover = ₹4,500 crore ÷ 20 = ₹225 crore.
  6. BRSR Core intensity = 90,000 ÷ 225 = 400 tCO2e per ₹ crore of PPP-adjusted turnover.
  7. The GHG figures belong to the attribute GHG footprint and fall within the BRSR Core assurance scope.

Answer: The simple intensity is 20 tCO2e per ₹ crore of revenue. On the assumed PPP factor of 20, the BRSR Core intensity is 400 tCO2e per ₹ crore of PPP-adjusted turnover. In an actual report, the company must use the World Bank PPP rate for India, and the GHG KPIs must be reasonably assured.

Exam tips

  • Open every answer with Regulation 34(2)(f) of SEBI LODR, 2015. It earns the provision mark quickly.
  • In case questions, state rank, year and conclusion in the first three lines. Examiners look for the phasing logic.
  • Write the nine attributes as a list when asked about BRSR Core. A clear list scores more than a paragraph.
  • Use the comparison format for BRSR versus BRSR Core: scope, assurance, indicators and who it applies to.
  • If you are unsure of a threshold in the value chain rules, describe the rule in words and say it is as per the latest SEBI circular.

Practice questions from Sustainability Audit, ESG Rating and Emerging Mandates from Government and Regulators

BRSR and BRSR Core Mandates: frequently asked questions

What is the difference between BRSR and BRSR Core?

BRSR is the full sustainability report on the nine NGRBC principles, with Essential and Leadership indicators. BRSR Core is a smaller set of KPIs under nine ESG attributes. It requires reasonable assurance and uses PPP-adjusted intensity so that companies can be compared.

Which companies must file BRSR?

The top 1,000 listed entities by market capitalisation must include a BRSR in their annual report under Regulation 34(2)(f) of SEBI LODR, 2015. For FY 2021-22 the BRSR was voluntary and entities could file the BRR instead. It became mandatory from FY 2022-23 and replaced the earlier Business Responsibility Report.

Does value chain disclosure apply to every BRSR company?

No. Under the July 2023 circular it applies to the top 250 from FY 2024-25. They disclose BRSR Core KPIs for key upstream and downstream partners. Assurance of value chain data was voluntary at the start. SEBI has since revised the framework, including by a 2025 circular, so check the latest circular.

Who gives assurance on BRSR Core?

An independent assurance provider gives reasonable assurance on the BRSR Core KPIs. The assurance report forms part of the company's BRSR disclosures. The board and the audit or ESG committee should oversee the process.