BRSR Core vs. BRSR: Which ESG Disclosure Framework Applies to Your Business?

Background

SEBI's Business Responsibility and Sustainability Report (BRSR) replaced the erstwhile Business Responsibility Report (BRR) in FY2022–23. The framework covers 9 Principles aligned with India's National Guidelines on Responsible Business Conduct (NGRBC), requiring companies to disclose environmental, social, and governance performance across their own operations and value chain.

In 2023, SEBI introduced BRSR Core — a subset of high-impact KPIs with mandatory third-party assurance — creating a two-tier structure that companies must navigate carefully.

Who Must File What?

BRSR Core: The 9 KPI Categories

BRSR Core is structured around intensity metrics and absolute disclosures across:

• GHG emissions intensity (Scope 1 + 2 per rupee of turnover)
• Water intensity and recycling rates
• Energy intensity and renewable energy share
• Waste generation and diversion from landfill
• Diversity ratios (gender, differently-abled)
• Pay parity (male vs. female median wages)
• Supply chain due diligence coverage (%)
• CSR spend and community welfare outcomes
• Complaints and grievance redressal rates

Common Filing Mistakes to Avoid

• Confusing turnover-intensity metrics with absolute numbers — SEBI requires both for BRSR Core
• Excluding subsidiaries from Scope 2 calculations when they share utility connections
• Using calendar year rather than financial year (Apr–Mar) as the reporting period
• Assurance engagement started too late — allow minimum 10–12 weeks for a clean BRSR Core audit
• Omitting Scope 3 Category 11 (use of sold products) where it is material

Timeline: When Does BRSR Core Apply to You?

• FY2023–24: Top 150 listed companies — BRSR Core mandatory with assurance
• FY2024–25: Top 250 listed companies
• FY2025–26: Top 500 listed companies
• FY2026–27: Top 1,000 listed companies

Unlisted companies are not currently required to file BRSR, but voluntary adoption is growing among companies targeting ESG-linked financing or export market access.