Business Responsibility and Sustainability Reporting (BRSR) is a mandatory disclosure framework introduced by SEBI for India’s top listed companies. It replaced the earlier Business Responsibility Report (BRR) in 2022 and requires companies to report quantitative environmental, social, and governance data — including Scope 1 and Scope 2 greenhouse gas emissions — using a standardised format.
Why BRSR Matters for Indian Manufacturers
BRSR is not optional for companies in SEBI’s top 1000 listed entities by market capitalisation. Non-compliance triggers regulatory scrutiny and can affect stock exchange standing. Beyond compliance, global buyers — particularly in the EU and US — now request BRSR data as part of supply chain due diligence, making it a commercial requirement as much as a regulatory one.
SEBI introduced BRSR Core in 2023, a verified subset of disclosures requiring third-party assurance. From FY 2024–25, this assurance requirement extends further down the listed company tier structure. The timeline is set and non-negotiable.
Key consequences of non-compliance:
- Stock exchange queries and potential trading restrictions
- Loss of supply chain contracts with EU-regulated buyers
- Disqualification from ESG-linked financing instruments
- Reputational risk with institutional investors applying ESG filters
What BRSR Requires
BRSR is structured across three sections:
Section A — General Disclosures Company overview, business activities, number of employees, supply chain description. Largely qualitative, but establishes the reporting boundary.
Section B — Management and Process Disclosures Policies, governance structures, and management approaches across ESG dimensions. Describes intent and systems.
Section C — Principle-wise Performance Disclosures Nine principles mapped to India’s National Guidelines on Responsible Business Conduct (NGRBC). This is where quantitative data lives — including energy consumption, water use, waste generation, and critically: greenhouse gas emissions.
Principle 6 (Environment) requires:
- Total Scope 1 emissions (in metric tonnes CO2 equivalent)
- Total Scope 2 emissions (in metric tonnes CO2 equivalent)
- Emission intensity per rupee of turnover
- Emission intensity per unit of physical output
- Reduction initiatives and targets
These figures must be calculated using a recognised methodology. SEBI does not prescribe a specific protocol, but GHG Protocol Corporate Standard and IPCC emission factors are the accepted basis for audit-ready reporting.
BRSR Core — What Changed in 2023
BRSR Core is a subset of 49 Key Performance Indicators (KPIs) within BRSR that require independent assurance — not just self-reporting. SEBI introduced this to address greenwashing concerns and align India with international standards like CSRD and ISSB.
For manufacturers, BRSR Core includes:
- GHG emissions (Scope 1 & 2) with third-party verification
- Energy intensity data
- Water consumption and discharge
- Waste generation and disposal
The assurance requirement means your GHG calculations must be traceable, auditable, and defensible to an independent verifier. Spreadsheet-based calculations without documented methodology will not pass BRSR Core assurance.
| Disclosure Category | BRSR Standard | BRSR Core (Assured) |
|---|---|---|
| Scope 1 emissions | Required | Required + assured |
| Scope 2 emissions | Required | Required + assured |
| Energy intensity | Required | Required + assured |
| Reduction targets | Optional | Required |
How Scope 1 & Scope 2 Fit into BRSR
Scope 1 emissions are direct emissions from sources your company owns or controls — boilers, furnaces, diesel generators, company vehicles, process emissions. For a textile manufacturer, this typically includes natural gas combustion in jet dyeing machines, coal or biomass in steam boilers, and diesel in backup generators.
Scope 2 emissions are indirect emissions from purchased electricity. In India, the emission factor varies by state grid. Using a national average is acceptable but state-specific factors (published by Central Electricity Authority) produce more accurate and defensible numbers.
Both must be reported in metric tonnes CO2 equivalent (tCO2e) using global warming potential (GWP) values from IPCC Assessment Reports.
How Sustaineve Handles BRSR
Sustaineve’s calculation engine is built on IPCC 2006 Guidelines with 2019 Refinements — the same basis accepted by BRSR assurance auditors. Every emission source is mapped to its IPCC category, every calculation is logged with the emission factor used, and the output is an audit-ready data set that maps directly to BRSR Principle 6 disclosures. No manual reconciliation between your accounting system and your BRSR report.
See how Sustaineve generates BRSR-ready reports →
Frequently Asked Questions
Who must file BRSR? All companies in SEBI’s top 1000 listed entities by market capitalisation must file BRSR. From FY 2023–24, the requirement extended to the top 1000. SEBI has signalled further expansion to lower tiers in subsequent years.
Is BRSR mandatory for unlisted companies? No — BRSR is currently mandatory only for listed companies. However, unlisted subsidiaries of listed companies may need to provide data for consolidated BRSR reporting. Voluntary BRSR adoption is increasingly requested by PE investors and export buyers.
What emission factor should I use for Scope 2 in India? The Central Electricity Authority (CEA) publishes annual CO2 baseline database reports with state-wise and national grid emission factors. The national grid factor for FY 2022–23 was approximately 0.716 tCO2e/MWh. State-specific factors are more accurate for location-based Scope 2 reporting.
Does BRSR require Scope 3 reporting? Currently no. BRSR Principle 6 requires Scope 1 and Scope 2. Value chain (Scope 3) disclosures are listed under BRSR Core as an aspirational disclosure, but are not mandatory for assurance currently.
What is the penalty for BRSR non-compliance? SEBI can issue show-cause notices, impose fines, and refer cases to enforcement. More practically, stock exchanges can flag non-compliant filings, which attracts investor scrutiny and can affect credit ratings.
Related Resources
- Download: BRSR Reporting Guide for Manufacturers — Step-by-step guide including sample Principle 6 disclosures
- Scope 1 Emissions — Definition and Calculation Guide
- GHG Protocol vs ISO 14064 — Which Applies to You
- BRSR Compliance Hub