India’s ESG Reporting Shift: What BRSR Core Means For Indian Businesses

Policy Update
Tanvi Nerurkar

Background

Environmental, Social, and Governance (ESG) reporting has evolved globally from voluntary updates to a core element of corporate governance. India has both followed and, at times, led this shift. The Securities and Exchange Board of India (SEBI), under its statutory authority, has progressively made ESG disclosure mandatory rather than aspirational.

SEBI initiated this process in 2012 by asking the top 100 listed companies to publish a Business Responsibility Report (BRR) in accordance with the National Voluntary Guidelines. Over the next ten years, the framework changed to meet investor needs, global sustainability goals, and the idea that climate risks are also financial risks.

In May 2021, SEBI replaced the BRR with the Business Responsibility and Sustainability Report (BRSR), based on the National Guidelines on Responsible Business Conduct (NGRBC), and made it mandatory for the top 1,000 listed companies from FY 2022–23 (Securities and Exchange Board of India [SEBI], 2021). Companies had to share both numbers and descriptions in their ESG data. But since these reports were self-declared and mostly unchecked, people worried about data accuracy and greenwashing. To fix this, SEBI launched the BRSR Core framework in July 2023, which focuses on independent checks of key ESG metrics (SEBI, 2023).

India’s regulatory ESG journey 2012-2027

This change follows a global trend. The European Union’s Corporate Sustainability Reporting Directive (CSRD) and the IFRS Sustainability Disclosure Standards, issued by the International Sustainability Standards Board (ISSB) in June 2023, have established verified ESG reporting as a global standard. India’s BRSR Core aligns with this trend while also adapting the rules to India’s economy and its goal to reach net-zero greenhouse gas emissions by 2070, as promised in its Nationally Determined Contributions to the Paris Agreement (United Nations Framework Convention on Climate Change [UNFCCC], 2021).

Functioning of the BRSR Core Framework

BRSR Core is a focused, performance-based part of the larger BRSR framework. Instead of reporting on everything, companies under BRSR Core must share a set of Key Performance Indicators (KPIs) chosen for their importance to Indian businesses and for international comparison.

Source: SEBI Circular, July 2023; ISF Industry Standards, December 2024

SEBI’s July 2023 circular introduced 49 KPIs, later updated, covering nine ESG areas: greenhouse gas emissions (Scope 1, 2, and 3 on a comply-or-explain basis), energy use and intensity, water use and discharge, waste management, workforce diversity and inclusion, health and safety, employee well-being, business ethics and governance, and supply chain sustainability (SEBI, 2023). At first, this was called ‘reasonable assurance,’ which was as strict as financial audits. In May 2024, an expert committee suggested changing ‘assurance’ to ‘assessment or assurance’ to lower costs and allow more professionals, not just chartered accountants, to conduct the checks. SEBI made this change official in March 2025 (Sarthak Law, 2025). The rollout schedule is as follows:

Expanding scope — each phase adds entities and tightens verification requirements

Financial Year	Coverage
FY 2023–24	Top 150 listed entities (voluntary, BRSR Core disclosures)
FY 2024–25	Top 250 listed entities (voluntary value chain disclosures)
FY 2025–26	Top 500 listed entities; mandatory reporting for top 250
FY 2026–27	Top 1,000 listed entities; mandatory value chain assessment

Source: SEBI (2023); Maheshwari & Co. (2025)

The framework also covers company value chains. SEBI first required the top 250 listed companies to report ESG data from suppliers and customers that account for at least 2% of total purchases or sales, covering up to 75% of the value chain. Due to challenges in implementing this, SEBI delayed mandatory value-chain ESG disclosures and made them voluntary for FY 2025–26. Mandatory checks for value chain partners will start in FY 2026–27 (Bilancia Consulting, 2025).

In December 2024, the Industry Standards Forum (ISF), comprising ASSOCHAM, FICCI, and CII, established Industry Standards for BRSR Core to ensure consistent reporting across sectors (India Briefing, 2025). SEBI’s March 2025 circular added green credit disclosures as a new leadership indicator under Principle 6 (environmental stewardship), requiring companies and their top 10 value chain partners to report green credits they generate or buy (Sarthak Law, 2025). More India-specific social KPIs were also added, such as job creation in smaller towns, business openness, and total wages paid to women employees. These updates help the framework match both local development goals and global sustainability standards.

Performance and Progress

Since the mandatory BRSR requirement started in FY 2022–23, India has built one of the largest mandatory sustainability reporting systems among emerging economies. SEBI data shows that 88% of the top-listed Indian companies now publish sustainability reports, up from less than 10% ten years ago (SCC Online, 2025). This puts India among the few places in the world that require assurance-backed ESG disclosures, along with the European Union and some developed economies.

The financial side of ESG compliance has grown as disclosure rules have increased. India’s green bond issuance went from USD 7.4 billion in 2022 to USD 15.8 billion in 2024, as SEBI expanded debt rules to cover all ESG-linked instruments (SCC Online, 2025). At the same time, 92% of major Indian institutional investors now consider ESG risk a key factor in all investment decisions, indicating a significant shift in how capital is allocated (SCC Online, 2025).

Board-level governance has also improved. The average percentage of women on boards in large-cap Nifty 500 companies increased from 14% in 2020 to over 18.5% in 2025. This shows how BRSR’s social KPIs are affecting corporate governance beyond just reporting (SCC Online, 2025). The mandatory assurance system is also improving data quality and consistency, as independent assessors now apply the same standards to ESG disclosures as they do to financial audits.

Globally, BRSR Core helps Indian companies work more closely with foreign investors and multinational supply chains. Because the framework aligns with the IFRS Sustainability Disclosure Standards and the Global Reporting Initiative (GRI), Indian companies can avoid duplicating work when reporting across countries, including under the EU’s CSRD. India was one of the first countries to require reasonable assurance for ESG disclosures, which has given its framework international credibility (TASConnect, 2025).

Impact on Indian Businesses

ESG as a Compliance Imperative
With BRSR Core, ESG reporting is no longer just about reputation. It is now a compliance requirement with financial, legal, and reputational impacts. Companies need strong, auditable systems to collect, check, and share ESG data. Responsibility for ESG now includes finance, legal, and board-level roles, much as it does for financial reporting. Regulators expect senior management to be responsible for ESG disclosures as a matter of course.

Supply Chain Cascade Effect

Supply Chain Accountability
BRSR Core’s value chain rules are pushing large listed companies to incorporate ESG criteria into how they select and manage suppliers. Partners who account for more than 2% of purchases or sales now have to provide ESG data for reporting and checks. This means thousands of unlisted suppliers and business partners, including many SMEs, are expected to provide ESG information even if SEBI does not directly regulate them. If they do not comply, they may be excluded from supply chains, as listed companies need reliable ESG data to meet regulatory requirements (Tinubu, 2025).

This trend also affects financing. Banks, private equity firms, venture capital funds, and family offices now often require ESG data from companies they invest in or lend to, as part of their regulatory duties. SMEs that cannot demonstrate basic ESG performance may find it hard to secure external funding on favourable terms (Tinubu, 2025).

Growth of ESG Services and Digital Infrastructure
This demand has led to more ESG consulting, technology platforms, and assurance services. Companies are buying ESG management software, automated data tools, and reporting platforms to create standard, auditable disclosures. The March 2025 change from ‘assurance’ to ‘assessment or assurance’ was intended to help by allowing more professionals to perform the work, demonstrating a practical approach by regulators (Bilancia Consulting, 2025).

Emerging issues & challenges

Compliance Burden on SMEs and MSMEs
The main challenge with BRSR Core is the extra burden it puts on small and medium enterprises (SMEs). Almost 47% of SMEs say ESG compliance costs are a big worry (SCC Online, 2025). Unlike large listed companies, SMEs often lack dedicated sustainability teams, digital reporting systems, and the technical skills for environmental measurement and governance. As listed companies ask for ESG data from their partners, many firms not directly regulated by SEBI now have to comply. If this is not addressed, it could create a two-tier economy in which large companies are ready for ESG, while supply chain partners are left behind.

Data Availability and Quality
ESG data is often spread out across different departments, supply systems, and locations. Collecting, standardising, and checking data on greenhouse gas emissions, waste, water use, and workforce diversity is technically hard. Scope 3 emissions, which cover indirect value-chain emissions, are especially difficult to track. The top 250 listed companies must report these on a comply-or-explain basis from FY 2024–25, but accurate reporting depends on detailed data from suppliers and logistics partners who may not have the right systems (HECS, 2025).

Assurance Capacity and Professionalisation
India does not yet have enough qualified professionals to assess or ensure sustainability disclosures at the scale required by BRSR Core. SEBI tried to fix this in 2025 by allowing more types of professionals, not just chartered accountants, to do these assessments. But without standard training, sector-specific knowledge, and recognised ESG assurance credentials, the quality of third-party assessments can vary, which may hurt the reliability and comparability of disclosures.

Regulatory Adaptation and Global Complexity
Multinational companies with Indian subsidiaries face extra challenges. They must follow BRSR Core’s reporting rules and also meet their parent company’s requirements under the EU’s CSRD. The CSRD was significantly revised in 2025, with the EU Omnibus Simplification Package proposing a cut of over 70% in required data points (BreathEESG, 2026). Dealing with different metrics, timelines, and assurance standards across countries makes compliance more difficult, especially for smaller Indian operations. Solving these problems needs teamwork across regulators, institutions, and companies.

While these challenges are significant, they are not insurmountable. Addressing them will require a combination of capacity building, technological innovation, regulatory harmonisation, and a shift in corporate mindset from compliance-driven reporting to strategic sustainability management. The following measures can help strengthen the effectiveness and inclusiveness of the BRSR Core framework.

Way Forward

Maximising BRSR Core’s effectiveness while managing implementation friction requires action across regulatory, institutional, and corporate dimensions.

Capacity Building Across the Value Chain
To ease BRSR Core implementation, government agencies, industry bodies, and large companies should support SMEs and suppliers through training, standardized reporting templates, and access to basic ESG monitoring tools. Such initiatives can improve data quality while reducing compliance challenges across supply chains.

Digitisation of ESG Data Infrastructure
Effective ESG reporting requires robust digital systems. Investing in ESG management platforms can automate data collection, maintain audit trails, and streamline assurance processes. Digitalization improves reporting accuracy and lowers compliance costs, particularly for resource-constrained suppliers.

Harmonisation with Global Frameworks
Continued alignment of BRSR Core with international standards such as IFRS Sustainability Disclosure Standards (IFRS S1 and S2) and GRI Standards can reduce reporting duplication, improve comparability, and enhance the credibility of Indian ESG disclosures in global markets.

Strategic Integration Beyond Compliance
BRSR Core is most valuable when companies see it as more than just a compliance task. It should be used as a strategic tool to spot risks, improve operations, and create long-term value. ESG insights on energy use, water risk, workforce safety, and supply chain sustainability can help guide business planning and investment choices. Companies that make sustainability part of their core business processes, rather than just an annual report, will be better prepared for future ESG rules in India

Conclusion

India’s BRSR Core framework marks a major turning point in corporate sustainability. By mandating assured, quantitative ESG disclosures from the top 1,000 listed companies and extending responsibility along value chains, SEBI has positioned India as a global leader in sustainability reporting. The framework integrates standard KPIs, phased assurance, India-specific social measures, and new green credit disclosures, balancing global standards with local needs. Notably, sustainability reporting rates have increased significantly, green bond issuance has doubled, institutional investor integration of ESG is nearly universal among major market participants, and board diversity is improving. These results indicate that mandatory assurance is enhancing data credibility and embedding ESG considerations at the highest levels of corporate governance.

Substantial challenges remain, and significant challenges persist, especially for SMEs and supply chain partners facing limited resources, fragmented data, and high compliance costs. These issues risk creating a compliance gap and undermining the framework’s objectives. Addressing them will require collaboration across the entire ecosystem, not just additional regulation. Ultimately, BRSR Core serves as a catalyst to align India’s corporate sector with national sustainability goals, attract long-term global investment, and demonstrate that economic growth and environmental responsibility can coexist.

References

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About the Contributor

Tanvi Nerurkar is currently working as a Research & Editorial Intern at IMPRI. She holds a Bachelor’s degree in Architecture from VESCOA, University of Mumbai and is presently pursuing a Master’s in Urban Management at CEPT University, where she explores cities through research-driven policy approaches, adaptive governance frameworks, and sustainable development initiatives. Her objective is to contribute implementation-oriented policy research that supports the efficient functioning of cities and creates meaningful value for society at large.