India is at a pivotal moment in its sustainability journey. The introduction of the Business Responsibility and Sustainability Report (BRSR) represents a major regulatory shift, bringing environmental, social, and governance (ESG) disclosures into the mainstream of corporate accountability. Originally stemming from voluntary guidelines issued by the Ministry of Corporate Affairs in 2009, refined into the Business Responsibility Report (BRR) in 2012, the BRSR has now evolved into a mandatory reporting framework for the top 1,000 listed companies in India as of fiscal year 2023 [1].

Unlike its predecessors, the BRSR emphasizes quantitative disclosures, alignment with international standards, and enhanced scrutiny of value chain impacts. With recent amendments by the Securities and Exchange Board of India (SEBI), the framework continues to evolve, introducing new elements such as value chain reporting, green credit programs, and industry-specific standards. Together, these changes underscore India’s ambition to align corporate accountability with global sustainability frameworks while tailoring disclosures to its domestic priorities [2].

This article explores the structure of the BRSR, recent regulatory updates, its connection to international frameworks, and the strategic implications for Indian businesses.

Structure of the BRSR

The BRSR framework is built on three categories of disclosure [3]:

1. General Disclosures – Basic company information, such as reporting boundaries, employee counts, diversity and inclusion metrics, and customer engagement mechanisms.
2. Management and Process Disclosures – Statements and evidence showing how companies embed the National Guidelines on Responsible Business Conduct (NGRBC) into governance structures, policies, and oversight.
3. Principle-wise Performance Disclosures – Data-driven reporting aligned with the NGRBC’s nine principles, covering topics such as ethical governance, sustainable product design, employee well-being, stakeholder inclusivity, human rights, environmental stewardship, policy engagement, equitable development, and consumer responsibility.

Each of these nine principles contains essential indicators (mandatory metrics such as energy use, emissions, and labor policies) and leadership indicators (voluntary, aspirational metrics such as Scope 3 emissions reporting, biodiversity protection, and supply chain transparency) [1].

As of June 2023, the BRSR included 140 questions, 98 essential and 42 leadership, marking a significant expansion in scope and depth compared to the earlier BRR [1].

Alignment with Global Standards

A critical feature of the BRSR is its interoperability with globally recognized ESG frameworks, including the グローバル・リポーティング・イニシアティブ（GRI）, Sustainability Accounting Standards Board (SASB), and Task Force on Climate-related Financial Disclosures (TCFD) [1]. This interoperability helps Indian companies better align with international reporting requirements and investor expectations, while also facilitating comparability across jurisdictions.

SEBI and the GRI have jointly issued guidance to link the BRSR framework with GRI Standards, further harmonizing disclosures and reducing duplication [4]. Such linkages are especially important for multinational corporations and global investors, ensuring that Indian disclosures are not seen as an outlier but as part of a broader movement toward transparency.

Key Updates: SEBI’s Amendments

In recent years, SEBI has introduced a series of amendments to strengthen the BRSR framework and address implementation challenges. These include:

• BRSR Core – A standardized set of key performance indicators (KPIs) applicable to all sectors, designed to ensure comparability and consistency [2].
• Value Chain Disclosures – Extended reporting obligations requiring companies to disclose ESG data from upstream and downstream partners representing at least 2% of purchases or sales, covering up to 75% of total value chain activities. While initially set for FY 2024–25, SEBI has deferred enforcement to FY 2025–26, recognizing the complexity of gathering such data [5][6].
• Assessment or Assurance – SEBI replaced the term “assurance” with “assessment or assurance” to reduce compliance burdens, while still promoting independent validation of BRSR Core disclosures. This requirement will phase in from FY 2024–25 for listed entities and FY 2026–27 for value chain partners [2][6].
• Green Credit Program – Added as a leadership indicator under Principle 6 (environmental stewardship). Companies and their top ten value chain partners can earn credits for activities such as afforestation on degraded lands and river catchment restoration, aligning corporate reporting with India’s broader climate and biodiversity goals [7].

These amendments strike a balance between regulatory ambition and business pragmatism, ensuring companies have time to adapt while steadily raising expectations for disclosure quality.

Comparison of Key Elements: Original BRSR vs. BRSR Core Updates

Element	Original BRSR (2021–23)	BRSR Core Updates (2023–25)
Applicability	Top 1,000 listed companies	Top 1,000 companies; value chain partners phased in from FY 2025–26
スコープ	General, management, and principle-wise disclosures	Streamlined “Core” KPIs with sector-neutral standards
Indicators	98 essential, 42 leadership	Industry Standards clarify methods for intensity ratios, water, waste, gender, safety
バリューチェーン	Not mandatory	Mandatory from FY 2025–26, covering 75% of purchases/sales (≥2% threshold per partner)
保証	“Assurance” (undefined)	“Assessment or assurance” with industry standards from FY 2024–25
Environmental Additions	Basic environmental KPIs	Green credit program under Principle 6; spend-based environmental footprint estimates allowed

This evolution reflects SEBI’s efforts to streamline, standardize, and expand the scope of corporate sustainability disclosures while embedding India-specific priorities like inclusive growth and biodiversity.

Strategic Implications for Companies

For Indian corporates, compliance with BRSR is not just about regulatory alignment but also about building resilience and competitive advantage. Key strategic implications include:

1. Data Infrastructure Investments – Companies must invest in systems to capture granular ESG data across diverse business units and geographies. Digital tools, such as IBM’s Envizi, can support multi-framework compliance and automate data capture [3].
2. Value Chain Engagement – Since value chain disclosures will soon be mandatory, companies should begin engaging suppliers and distributors now, building capacity for accurate data sharing and reporting. This mirrors the challenges faced by European companies under the コーポレート・サステナビリティ・レポーティング指令（CSRD）.
3. Balancing Essential and Leadership Indicators – While essential indicators ensure compliance, leadership indicators present opportunities for differentiation. Companies that go beyond compliance, reporting Scope 3 emissions, disclosing biodiversity impacts, and generating green credits, will strengthen credibility and investor trust.
4. Risk Management and Reputation – Transparent BRSR reporting enhances resilience against regulatory, reputational, and market risks. It also strengthens access to green finance, as investors increasingly demand robust ESG disclosures [2].
5. Future-proofing – By aligning early with both SEBI and global standards, companies can stay ahead of likely future mandates, including potential global recognition of Scope 4 emissions.

最終的な感想

The evolution of India’s BRSR framework demonstrates the country’s commitment to embedding sustainability into corporate governance. From its origins as voluntary guidelines to its current role as a mandatory and expanding disclosure regime, the BRSR is redefining corporate accountability in India.

Recent updates, including BRSR Core, value chain reporting, assurance reforms, and the green credit program, are not just compliance requirements but opportunities for businesses to enhance competitiveness, attract investors, and drive innovation.

As the ESG landscape continues to globalize, Indian companies that proactively embrace the BRSR will not only meet regulatory requirements but also position themselves as leaders in sustainable value creation.

参考文献

[1] https://www.sebi.gov.in/sebi_data/commondocs/may-2021/Business%20responsibility%20and%20sustainability%20reporting%20by%20listed%20entitiesAnnexure1_p.PDF
[2] https://assets.kpmg.com/content/dam/kpmgsites/in/pdf/2025/01/firstnotes-sebi-introduces-certain-key-changes-in-brsr-reporting.pdf.coredownload.inline.pdf
[3] https://www.ibm.com/think/topics/brsr
[4] https://www.globalreporting.org/media/ioqnxtmx/sebi_brsb_gri_linkage_doc.pdf
[5] https://www.india-briefing.com/news/brsr-reporting-in-india-key-changes-to-esg-disclosures-introduced-by-sebi-36261.html/
[6] https://economictimes.indiatimes.com/markets/stocks/news/sebi-defers-esg-disclosure-deadline-under-brsr-framework-by-one-year-till-fy26/articleshow/116475801.cms?from=mdr
[7] https://www.business-standard.com/markets/news/sebi-includes-green-credit-program-under-brsr-framework-125032801374_1.html