Key TakeawaySEBI's BRSR framework is now mandatory for the top 1,000 listed companies. This brief walks through the key disclosure requirements, assurance expectations and where most companies are currently falling short.
SEBI's Business Responsibility and Sustainability Report (BRSR) became mandatory for the top 1,000 listed companies (by market capitalisation) from FY 2022–23. For FY 2024–25, the BRSR Core — a subset of specified metrics subject to reasonable assurance — was introduced. This means that for the first time, a statutory or independent auditor must express a conclusion on ESG disclosures, not just the company's management.
The nine BRSR Core attributes subject to assurance include greenhouse gas emissions intensity (Scope 1 and 2), water intensity, waste generated and disposed, and gender diversity at board and workforce levels. The assurance standard applicable is ISAE 3000 (Revised) for sustainability information — a standard that most statutory auditors are not yet fully conversant with.
What we see at APRA when reviewing BRSR drafts: companies that have strong HSE (Health, Safety, Environment) functions tend to have better Scope 1 data quality. The problem areas are Scope 2 (purchased electricity), supply chain emissions (Scope 3, not yet mandated for assurance but asked for in the report), and the social indicators — particularly fair wage disclosure and contract worker health and safety.
Our practical recommendation: don't treat BRSR as a compliance exercise managed by the company secretary. It requires cross-functional ownership — finance, HR, operations, procurement and the board sustainability committee. The audit committee should review the BRSR with the same rigour it applies to the financial statements. The statutory auditor expressing assurance on the Core attributes will be asking hard questions about data collection methodology and trail — companies should be ready.
What this means for your business
This briefing is based on current regulatory positions as of 18 April 2026. Laws and regulatory positions change frequently. Before acting on any information in this publication, we strongly recommend consulting with a qualified partner who can assess your specific facts and circumstances. Contact our ESG & Reporting team at info@aprafirm.com or 0124-4477824/825.