TL;DR: BRSR stands for Business Responsibility and Sustainability Report, a SEBI-mandated disclosure filed as part of the annual report by the top 1,000 listed entities by market capitalisation, reporting performance against the nine principles of the National Guidelines on Responsible Business Conduct. Two dates matter right now. FY 2026-27, the year currently running, is when BRSR Core assessment or assurance reaches the full top 1,000. It is also when value chain disclosures become subject to assessment or assurance. If your company is unlisted, that second date is the one to read twice, because it is how unlisted companies get pulled into BRSR through their listed customers.
What Is BRSR?
BRSR is the Business Responsibility and Sustainability Report, a structured sustainability disclosure that SEBI requires listed entities to publish as part of their annual report under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
It replaced the older Business Responsibility Report and went further, moving from narrative description to structured, quantified disclosure. It was voluntary for FY 2021-22 and became mandatory for the top 1,000 listed entities from FY 2022-23.
The content is organised around the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), issued by the Ministry of Corporate Affairs in 2019. Those principles cover ethics and transparency, sustainable and safe goods and services, employee wellbeing, stakeholder responsiveness, human rights, environmental protection, responsible public policy engagement, inclusive growth and equitable development, and responsible consumer engagement.
The important thing to understand about BRSR is what kind of document it is. It is not a sustainability brochure that sits alongside the annual report. It is a disclosure inside the annual report, increasingly subject to third-party verification, and it feeds ESG ratings, lender assessments and investor screening. Treat it as a marketing artefact and you will produce numbers you cannot defend when someone tests them.
Who Does BRSR Apply To? Applicability and the Glide Path
Three layers of applicability, and they do not start at the same time.
Layer one: the BRSR report itself. Mandatory for the top 1,000 listed entities by market capitalisation, from FY 2022-23. Entities outside the top 1,000 may file voluntarily, and SEBI has encouraged that.
Layer two: BRSR Core assessment or assurance. BRSR Core is a subset of the full report, consisting of key performance indicators grouped under nine ESG attributes, introduced by SEBI’s circular of 12 July 2023. Unlike the narrative sections, these are quantified metrics designed to be verified. Mandatory assessment or assurance follows a phased glide path:
| Financial year | BRSR Core assessment or assurance applies to |
|---|---|
| FY 2023-24 | Top 150 listed entities |
| FY 2024-25 | Top 250 listed entities |
| FY 2025-26 | Top 500 listed entities |
| FY 2026-27 | Top 1,000 listed entities |
Note where we are. FY 2026-27 is the year currently running. If your entity sits between 500 and 1,000 by market capitalisation, this is your first year in scope, and the data you are generating right now is the data that will be assessed.
Layer three: value chain. Covered in its own section below, because it is the layer that reaches beyond listed companies.
Applicability is determined by market capitalisation as at 31 March of the relevant year, which means a company can move into scope without doing anything other than performing well.
The BRSR Format: Three Sections, Nine Principles
The format is prescribed, which is helpful, because it removes any argument about structure.
Section A: General Disclosures. Entity details, CIN, listing status, products and services, operations, employee and worker numbers with gender and disability breakdowns, holding and subsidiary details, CSR details, transparency and complaints data.
Section B: Management and Process Disclosures. How the company embeds the nine NGRBC principles: policies, governance and oversight structures, board responsibility for sustainability, and review processes. This section tests whether sustainability sits in the governance architecture or in a slide deck.
Section C: Principle-wise Performance Disclosures. The substantive section, organised principle by principle. Each principle carries two tiers:
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Essential indicators, which are mandatory
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Leadership indicators, which are voluntary and signal maturity beyond the baseline
The leadership tier is where SEBI adds new expectations before making them compulsory, so it is worth watching. The March 2025 amendments, for instance, added a leadership indicator under Principle 6 requiring disclosure of green credits generated or procured by the entity and its top ten value chain partners.
BRSR Core and the Assessment-or-Assurance Change
BRSR Core covers nine ESG attributes: greenhouse gas emissions, water, waste, energy, gender diversity and wages, inclusive development, fairness in engaging with customers and suppliers, openness of business, and job creation in small towns. Several of these are deliberately India-specific rather than lifted from global frameworks, which is one of the more thoughtful features of the design.
In March 2025, SEBI made a change that matters more than its wording suggests. Following the recommendations of the Expert Committee for Facilitating Ease of Doing Business and a board decision of 18 December 2024, SEBI’s circular of 28 March 2025 replaced the term “assurance” with “assessment or assurance” throughout the BRSR Core framework, with assessment to be carried out by third parties against standards developed by the Industry Standards Forum in consultation with SEBI.
The committee’s stated reasoning was that the term “assurance” had produced unintended consequences, additional financial burden and practical difficulty for industry. In substance, this gives listed entities a second, less onerous route to third-party verification.
Do not mistake flexibility for relief. Whether you choose assessment or assurance, a third party will test your numbers against evidence. The practical requirement is unchanged: every reported figure needs a source document, a calculation note, a named owner, an approval and an audit trail. Energy needs bills and meter records. Emissions need calculation sheets and documented emission factors. Water needs meter readings. That evidence takes four quarters to build and cannot be assembled in the last month before the assessor arrives.
This is a data and process problem before it is a sustainability problem, which is why it belongs in the same conversation as your record-to-report discipline rather than in a separate ESG silo.
The Part Most Guides Skip: You May Be in Someone Else’s Value Chain
Here is the section that matters most to readers who just concluded that BRSR does not apply to them.
SEBI requires listed entities to disclose ESG information about their value chain, meaning their upstream and downstream partners. Following the December 2024 board decision and the March 2025 circular, the current position is:
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Scope: partners individually accounting for 2% or more of the listed entity’s purchases or sales by value, with disclosure permitted to be capped at 75% of total purchases and sales
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Disclosure: voluntary from FY 2025-26, replacing the earlier comply-or-explain approach
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Assessment or assurance: applies from FY 2026-27, the year now running
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First-year relief: prior-year comparative data is not required in the first year of reporting
Read that as a supplier or customer rather than as a listed entity, and the implication is direct. If you are an unlisted mid-market company, a family business or a GCC, and you account for 2% or more of a large listed customer’s purchases, their disclosure obligation becomes your data request. And from FY 2026-27, the data you hand over sits inside a disclosure subject to third-party assessment or assurance.
This is why unlisted companies are receiving ESG questionnaires they did not expect and cannot easily answer. The questionnaire is not a courtesy. It is a regulatory obligation flowing down a supply chain, and the companies that respond with credible, evidenced data will keep those relationships more easily than the ones that respond with estimates.
For GCCs of foreign parents there is a parallel pressure from the other direction, since the India entity’s data feeds group-level sustainability reporting under the parent’s own regime. Two reporting frameworks, one dataset, and usually nobody in the India entity who owns it.
The practical conclusion for an unlisted company: you do not need to file a BRSR, but you increasingly need to be able to answer one. Those are different projects, and the second is much cheaper if you start before the request arrives.
Step-by-Step: How to Comply
1. Establish which layer you are in. Top 1,000 listed and filing a full BRSR? In the glide path for BRSR Core assessment this year? Or unlisted and sitting inside a listed customer’s value chain at 2% or more? The answer determines everything that follows, and it is worth confirming rather than assuming, because market-capitalisation rank moves.
2. Assign ownership before you assign work. BRSR fails most often because it is handed to whoever has capacity rather than to someone with authority. It touches finance, HR, operations, procurement, legal and facilities. Someone senior has to own the whole, or you will get nine principles owned by nobody.
3. Map every required data point to a source system and a named owner. Not a function, a person. This is the single highest-leverage step and it is the one most often skipped in favour of starting the drafting.
4. Run a gap assessment against evidence, not against intent. For each metric ask what document would prove this number to a third party. Where that document does not exist, you have found the actual work.
5. Fix the collection process, not the spreadsheet. If data is assembled manually each year, it will not survive assessment and it will consume your team every year forever. Build it into the process that already runs.
6. Complete a dry run one full quarter before the deadline. Assess your own numbers as an assessor would. The purpose is to find the weak data link while there is still time to fix it.
7. Take the disclosure to the board. BRSR is a board-level disclosure carrying board-level responsibility. It belongs on the agenda alongside the other items in your governance calendar, not in a management review that the board sees afterwards.
8. If you are unlisted, build the answer set anyway. Assemble the data your largest listed customers will ask for, on their timetable rather than yours. This is a commercial exercise disguised as a compliance one.
Frequently asked questions
- What is the full form of BRSR?
- BRSR stands for Business Responsibility and Sustainability Report. It is a sustainability disclosure mandated by SEBI under the LODR Regulations, 2015, filed as part of the annual report, reporting an entity’s performance against the nine principles of the National Guidelines on Responsible Business Conduct issued by the Ministry of Corporate Affairs in 2019. It replaced the earlier Business Responsibility Report and moved sustainability disclosure from narrative to structured, quantified reporting.
- Who is required to file BRSR in India?
- The top 1,000 listed entities by market capitalisation, mandatory from FY 2022-23. Entities outside the top 1,000 may file voluntarily and SEBI has encouraged this. Applicability is assessed on market capitalisation as at 31 March of the relevant financial year, so a company can enter scope through share price movement alone. Unlisted companies have no filing obligation, but may be drawn into a listed entity’s value chain disclosure if they account for 2% or more of that entity’s purchases or sales.
- What is BRSR Core and when does assurance apply?
- BRSR Core is a subset of the BRSR consisting of key performance indicators under nine ESG attributes, introduced by SEBI’s circular of 12 July 2023, designed to be verifiable by a third party. Mandatory assessment or assurance follows a glide path: top 150 entities from FY 2023-24, top 250 from FY 2024-25, top 500 from FY 2025-26 and the top 1,000 from FY 2026-27. Since March 2025, entities may undertake either “assessment” or “assurance”, with assessment performed against Industry Standards Forum standards.
- What is the BRSR format?
- Three sections. Section A covers general disclosures: entity details, products, operations, employee and worker numbers, holding and subsidiary structure, CSR and complaints. Section B covers management and process disclosures, setting out policies, governance and board oversight for each of the nine NGRBC principles. Section C covers principle-wise performance, with mandatory essential indicators and voluntary leadership indicators under each principle. The report is filed as part of the annual report.
- Does BRSR apply to unlisted or private companies?
- Not directly. There is no filing obligation for unlisted companies. But from FY 2025-26 listed entities disclose ESG information about value chain partners individually accounting for 2% or more of purchases or sales, and from FY 2026-27 those disclosures are subject to assessment or assurance. In practice, unlisted suppliers and customers of large listed companies are receiving ESG data requests they must be able to answer credibly, even though they file nothing themselves.
- What changed in the BRSR framework in 2025?
- SEBI’s circular of 28 March 2025, following a board decision of 18 December 2024, made four material changes: the term “assurance” was replaced with “assessment or assurance” throughout; value chain ESG disclosures were deferred by one year and made voluntary from FY 2025-26 rather than comply-or-explain; the value chain threshold was set at partners individually contributing 2% or more of purchases or sales, with disclosure capped at 75% of the total; and a new leadership indicator under Principle 6 was added covering green credits generated or procured by the entity and its top ten value chain partners.
What This Comes Down To
Governance is not a side hustle, and BRSR is a governance disclosure wearing a sustainability label. The companies that struggle with it are not the ones with poor environmental performance. They are the ones that cannot evidence the performance they have, because nobody owned the data until the deadline arrived.
There is a second, quieter point for anyone reading this from an unlisted company. The instinct on reading “top 1,000 listed entities” is relief. That instinct is roughly two years out of date. The regulatory perimeter is widening through the value chain rather than through the applicability threshold, and it is widening now.
Great execution is thinking at the macro level and executing at the micro level. The nine principles and the glide path are the macro. The meter reading filed with a date on it, the emission factor documented so it can be reproduced next year, the named owner for each data point, the dry run a quarter early: that is the micro. Both, or neither.
How Astravise Services Works on This
Astravise Services approaches BRSR as a data, process and governance problem rather than a reporting exercise, because that is what it is once a third party starts testing the numbers. Our Strategic CFO advisory begins with an independent diagnostic of where the required data actually lives and what would be needed to evidence it, which is a materially different starting point from drafting the report and discovering the gaps later.
For organisations building or running an India capability centre, ESG and sustainability reporting is increasingly a function the centre owns, alongside finance and analytics. We design that scope through GCC Advisory and build the underlying process discipline through Agile Shared Services, so the reporting runs on a process rather than on an annual scramble.
Talk to us about a BRSR readiness diagnostic, whether you file one or answer someone else’s.