Overview
A BRSR question usually arrives from somewhere else. A listed customer sends a value-chain ESG questionnaire and quotes a deadline. A board asks whether the company should file voluntarily now that peers are doing it. Or a finance team inherits the BRSR mandate for the first time because market capitalisation crossed into the top 1,000 this year. In every case the reader wants the same thing first: is this actually brsr mandatory for us, or is someone downstream making it feel that way. The honest answer, most of the time, is that the statutory duty sits with a narrow band of listed India, and everything else is commercial pressure wearing a compliance label.
BRSR — the Business Responsibility and Sustainability Report — is SEBI’s ESG disclosure format, introduced by circular in May 2021 and mandatory from FY2022-23 for the top 1,000 listed entities by market capitalisation as on 31 March of the relevant year. It replaced the older, thinner Business Responsibility Report. Listed companies outside that top-1,000 band, including SME-platform listings, may file it voluntarily; SEBI itself has noted that more than 1,200 companies now publish BRSR against a 1,000-company mandate, which tells you the voluntary pool is real, not theoretical. The report sits inside the Annual Report and is built on the nine principles of the Ministry of Corporate Affairs’ National Guidelines on Responsible Business Conduct, each carrying mandatory Essential Indicators and voluntary Leadership Indicators across the report’s three sections.
A narrower slice, BRSR Core, adds independent third-party checking on a market-cap glide path: the top 150 from FY2023-24, top 250 from FY2024-25, top 500 from FY2025-26, and top 1,000 from FY2026-27. A March 2025 SEBI circular reshaped two things worth knowing if you last read about this in 2023: value-chain ESG reporting for the top 250’s upstream and downstream partners moved from comply-or-explain to fully voluntary, deferred to FY2025-26, and the checking requirement itself now allows either third-party assurance or a new assessment route under standards an Industry Standards Forum is developing. If your business supplies a listed company and gets asked for energy, water or emissions data as a value-chain partner, that is this mechanism reaching you — voluntary in SEBI’s rulebook, sometimes non-negotiable in the purchase order.
Our lane here matches our ESG compliance practice: we prepare, we never assure. BRSR assurance or assessment is an independent function that has to sit apart from whoever compiled the numbers, so where your company or a customer needs that sign-off we build the evidence pack and coordinate with the independent provider rather than issue any opinion ourselves. What we do directly is the harder, less glamorous part — pulling the data, drafting against the nine-principle format, and getting a filing-ready BRSR or a customer-ready value-chain response out the door on the actual statutory shape, not a guess at it.
Who it’s for
- Listed companies newly inside the top 1,000 by market capitalisation, filing BRSR for the first time
- Listed companies inside the BRSR Core assurance/assessment glide path (top 150 through top 1,000, phasing in through FY2026-27) preparing the KPI subset for independent checking
- Suppliers and customers of large listed companies asked to provide ESG data as a value-chain partner, without a BRSR filing duty of their own
- Listed companies outside the top 1,000 — including SME-platform (NSE Emerge / BSE SME) listings — considering voluntary BRSR filing
- Finance and company-secretarial teams that need the nine-principle disclosure drafted and XBRL-ready alongside the Annual Report cycle
Eligibility & requirements
- BRSR is mandatory only for the top 1,000 listed entities by market capitalisation as on 31 March of the relevant financial year; other listed entities, including SME-platform companies, may file it voluntarily
- The report is built on the nine NGRBC principles, each carrying mandatory Essential Indicators and voluntary Leadership Indicators, across Section A (general disclosures), Section B (management and process disclosures) and Section C (principle-wise performance)
- BRSR Core independent checking applies on a glide path by market cap — top 150 from FY2023-24, top 250 from FY2024-25, top 500 from FY2025-26, top 1,000 from FY2026-27 — originally as mandatory third-party assurance only; a March 2025 SEBI circular added assessment as an alternative route from FY2025-26 onward
- Value-chain ESG reporting for the top 250 listed entities’ value-chain partners — defined, since the March 2025 easing, as a partner individually at or above 2% of the customer’s purchases or sales — is currently voluntary, with voluntary assessment or assurance encouraged from FY2026-27
- BRSR must be filed as part of the Annual Report, submitted to the stock exchange in both PDF and XBRL on the same day as the Annual Report, with the XBRL filing reaching the exchange at least 21 clear days before the AGM
- BRSR is a separate statutory track from Form CSR-2 under Section 135 of the Companies Act, 2013 — one is a SEBI/LODR disclosure inside the Annual Report, the other an MCA e-form filed with the Registrar linked to Form AOC-4; a company can owe one, both, or neither
How CapEasy handles it
- We confirm your actual position first — market-cap ranking for mandatory BRSR, Core-assurance glide-path year, or value-chain-partner status — before assuming anything is required
- Data mapping against the nine NGRBC principles and the Section A/B/C format, identifying which Essential Indicators you can evidence today and where the gaps sit
- For BRSR Core attributes, we build the underlying KPI workbook per Annexure I’s measurement approach so the numbers are traceable, not estimated after the fact
- We draft the full disclosure — general, management-process and principle-wise sections — in the current SEBI format, distinguishing mandatory Essential Indicators from voluntary Leadership Indicators
- Where a value-chain questionnaire from a listed customer is the actual trigger, we scope the response to what they asked rather than building a full BRSR speculatively
- You review and sign off; where independent assurance or assessment is required, we hand the evidence pack to your chosen independent provider and support the engagement, not conduct it
- We package the filing-ready report and XBRL data ahead of your Annual Report and AGM timeline, so the exchange submission windows are not a last-minute scramble
Documents you’ll typically need
- Prior year’s Annual Report and, if applicable, prior BRSR filing for continuity
- Twelve months of energy, water and fuel consumption records for the environmental indicators
- Workforce data: headcount, gender split, contractor usage, training and safety records
- Existing policies covering the nine NGRBC principles — human rights, environment, anti-bribery, stakeholder engagement — however informal
- CSR, POSH and other governance-filing records where these overlap with BRSR disclosures
- For value-chain reporting: the customer’s specific questionnaire or data-request format, and your own purchase/sales data to confirm whether the 2% threshold applies to you
CapEasy is a private consultancy and is not affiliated with any government authority. We help you assess eligibility and prepare and file your application; eligibility and approval depend on your specifics and the relevant department’s discretion.
