| Date | What happened | Source |
|---|---|---|
| July 2011 | Ministry of Corporate Affairs issues the National Voluntary Guidelines (NVGs) on social, environmental and economic responsibilities of business | SEBI circular of 13 Aug 2012 |
| 13 August 2012 | Business Responsibility Report (BRR) made mandatory for the top 100 listed companies, through Clause 55 of the Listing Agreement | SEBI circular CIR/CFD/DIL/8/2012 |
| 4 November 2015 | SEBI prescribes the BRR format under the LODR Regulations | SEBI circular CIR/CFD/CMD/10/2015 |
| March 2019 | National Guidelines on Responsible Business Conduct (NGRBC) revise the NVGs | Ministry of Corporate Affairs |
| 5 and 10 May 2021 | LODR amended; BRSR format issued; voluntary for FY 2021-22, mandatory for the top 1,000 from FY 2022-23 | SEBI circular of 10 May 2021 |
| 12 July 2023 | BRSR Core introduced, with a timetable for independent checking | SEBI circular of 12 July 2023 (BRSR Core) |
| 28 March 2025 | "Assessment or assurance"; value chain made voluntary; green credits added | SEBI circular of 28 March 2025 |
| Term | What it is | Legal basis | Who it applies to |
|---|---|---|---|
| CSR | An obligation to spend at least 2% of average net profits of the previous three years on listed activities | Companies Act 2013, s135 | Companies with net worth of Rs 500 crore or more, turnover of Rs 1,000 crore or more, or net profit of Rs 5 crore or more in the previous year, listed or not |
| BRSR | A disclosure in a set format on environmental, social and governance performance | SEBI LODR Reg 34(2)(f) | The top 1,000 listed companies; others may file voluntarily |
| ESG | A general label used by investors for environmental, social and governance factors | No single legal definition | Used loosely; read what each user means by it |
| Year | Change | What it means for preparers | What it means for readers |
|---|---|---|---|
| 2023 | BRSR Core: 9 attributes with defined KPIs and a timetable for independent checking | Some figures must be checked by an outside provider | These figures are more reliable than the rest |
| 2025 | "Assurance" became "assessment or assurance"; the word "reasonable" dropped | Choice of provider widens beyond one profession | Look at Section A, point 15 to see which was obtained |
| 2025 | Value chain disclosures made voluntary and the threshold changed; green credits added as a voluntary leadership indicator | Less compulsory work on suppliers | Many companies will not report the value chain; check the coverage stated |
| Company | Facts | Answer |
|---|---|---|
| A | Listed; ranked 640 on average market capitalisation | Must file a BRSR. BRSR Core assessment or assurance applies from FY 2026-27, when the top 1,000 are covered. |
| B | Unlisted; turnover Rs 2,000 crore | No BRSR obligation under SEBI's rules. It owes CSR under s135, because its turnover exceeds Rs 1,000 crore. |
| C | Listed on an SME exchange | May file voluntarily; not obliged. |
| D | Listed; ranked 180 | Must file. Core assessment or assurance from FY 2024-25, when the top 250 are covered. |
| Section | Title in the format | What it holds |
|---|---|---|
| A | General disclosures | Who the company is: listing details, products, operations, employees, subsidiaries, CSR, and complaints and material issues |
| B | Management and process disclosures | Policies against each of the nine principles, who approved them, and who oversees them |
| C | Principle wise performance disclosure | The numbers and answers, principle by principle, split into essential and leadership indicators |
| Part | Heading in the format | Useful for |
|---|---|---|
| I | Details of the listed entity | Name, CIN, contact, reporting boundary (point 13), assessment or assurance provider (points 14 and 15) |
| II | Products/services | What the company makes and where it sells |
| III | Operations | Number of plants and offices, markets served |
| IV | Employees | Headcount by gender, permanent and other, differently abled, turnover rate |
| V | Holding, Subsidiary and Associate Companies | Which group entities take part in the company's business responsibility initiatives |
| VI | CSR Details | Whether s135 applies, turnover and net worth |
| VII | Transparency and Disclosures Compliances | Complaints from stakeholder groups and the material issues (question 26) |
| Principle statement | |
|---|---|
| P1 | Businesses should conduct and govern themselves with integrity, and in a manner that is Ethical, Transparent and Accountable |
| P2 | Businesses should provide goods and services in a manner that is sustainable and safe |
| P3 | Businesses should respect and promote the well-being of all employees, including those in their value chains |
| P4 | Businesses should respect the interests of and be responsive to all its stakeholders |
| P5 | Businesses should respect and promote human rights |
| Principle statement | |
|---|---|
| P6 | Businesses should respect and make efforts to protect and restore the environment |
| P7 | Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent |
| P8 | Businesses should promote inclusive growth and equitable development |
| P9 | Businesses should engage with and provide value to their consumers in a responsible manner |
| Figure | Principle | Type |
|---|---|---|
| Energy, water, Scope 1 and 2 emissions, waste | P6 | Essential |
| Scope 3 emissions; facilities in water-stressed areas; green credits | P6 | Leadership |
| Wellbeing spending; lost-time injury frequency rate; retirement benefits | P3 | Essential |
| Gross wages paid to women; complaints under the POSH Act | P5 | Essential |
| Inputs sourced from MSMEs and small producers; social impact assessments | P8 | Essential |
| Days of accounts payable; concentration of purchases and sales | P1 | Essential |
| Consumer complaints; data breaches | P9 | Essential |
| # | Attribute, as named in Annexure I of the 2023 circular |
|---|---|
| 1 | Green-house gas (GHG) footprint |
| 2 | Water footprint |
| 3 | Energy footprint |
| 4 | Embracing circularity: details related to waste management by the entity |
| 5 | Enhancing Employee Wellbeing and Safety |
| 6 | Enabling Gender Diversity in Business |
| 7 | Enabling Inclusive Development |
| 8 | Fairness in Engaging with Customers and Suppliers |
| 9 | Open-ness of business |
| Attribute | Key figures |
|---|---|
| 1. GHG footprint | Total Scope 1; total Scope 2; Scope 1 and 2 intensity per rupee of revenue adjusted for PPP, and per unit of output |
| 2. Water footprint | Water consumption and its intensity; water discharge by destination and level of treatment |
| 3. Energy footprint | Total energy consumed; share from renewable sources; energy intensity |
| 4. Circularity | Waste generated by category and its intensity; waste recovered; waste disposed |
| 5. Wellbeing and safety | Spending on employee and worker wellbeing as a share of revenue; safety incidents, including the lost-time injury frequency rate and fatalities |
| Attribute | Key figures |
|---|---|
| 6. Gender diversity | Gross wages paid to women as a share of total wages; complaints under the POSH Act |
| 7. Inclusive development | Inputs sourced from MSMEs and small producers and from within India; wages paid to people employed in smaller towns as a share of total wage cost |
| 8. Fairness with customers and suppliers | Customer data breaches as a share of all data breaches or cyber security events; number of days of accounts payable |
| 9. Open-ness of business | Concentration of purchases and sales with trading houses, dealers and related parties; loans, advances and investments with related parties |
| Financial year | Listed entities covered (by market capitalisation) |
|---|---|
| 2023-24 | Top 150 |
| 2024-25 | Top 250 |
| 2025-26 | Top 500 |
| 2026-27 | Top 1,000 |
| Scope | Definition in the GHG Protocol Corporate Standard (ch. 4) | Example for a factory |
|---|---|---|
| 1 | "Direct GHG emissions occur from sources that are owned or controlled by the company" | Diesel burnt in its own generators and boilers; LPG in its canteen |
| 2 | "Emissions from the generation of purchased electricity consumed by the company" | Grid electricity bought from the distribution company |
| 3 | "All other indirect emissions", from "sources not owned or controlled by the company" | Making the steel it buys; trucking its products; employees' commuting |
| Upstream | |
|---|---|
| 1 | Purchased goods and services |
| 2 | Capital goods |
| 3 | Fuel- and energy-related activities not in Scope 1 or 2 |
| 4 | Upstream transportation and distribution |
| 5 | Waste generated in operations |
| 6 | Business travel |
| 7 | Employee commuting |
| 8 | Upstream leased assets |
| Downstream | |
|---|---|
| 9 | Downstream transportation and distribution |
| 10 | Processing of sold products |
| 11 | Use of sold products |
| 12 | End-of-life treatment of sold products |
| 13 | Downstream leased assets |
| 14 | Franchises |
| 15 | Investments |
| Gas | IPCC AR5 GWP100 | IPCC AR6 GWP100 |
|---|---|---|
| Carbon dioxide (CO2) | 1 | 1 |
| Methane (CH4) | 28 (fossil 30) | 27.0 non-fossil; 29.8 fossil |
| Nitrous oxide (N2O) | 265 | 273 |
| Line | Renewable sources | Non-renewable sources |
|---|---|---|
| Electricity consumption | A | D |
| Fuel consumption | B | E |
| Other sources | C | F |
| Item in the format | Unit |
|---|---|
| Withdrawal by source: surface water, groundwater, third-party water, seawater or desalinated water, others | kilolitres |
| Total withdrawal and total consumption | kilolitres |
| Water intensity per rupee of turnover, and adjusted for PPP | kilolitres per rupee |
| Discharge by destination and level of treatment | kilolitres |
| Code | Category | Code | Category |
|---|---|---|---|
| A | Plastic waste | E | Battery waste |
| B | E-waste | F | Radioactive waste |
| C | Bio-medical waste | G | Other hazardous waste |
| D | Construction and demolition waste | H | Other non-hazardous waste |
| 2023 framework | Since 28 March 2025 | |
|---|---|---|
| Who is a value chain partner | Top upstream and downstream partners making up 75% of purchases or sales by value, together | Partners "individually comprising 2% or more" of purchases or sales by value |
| Limit | None beyond the 75% | The company "may limit disclosure ... to cover 75%" of purchases and sales |
| Disclosure | Comply or explain, top 250, from FY 2024-25 | Voluntary, top 250, from FY 2025-26 |
| Checking | Limited assurance, comply or explain, from FY 2025-26 | Assessment or assurance, voluntary, from FY 2026-27 |
| Item | Position in October 2026 | Source |
|---|---|---|
| Law | Regulation (EU) 2023/956 | EUR-Lex |
| Sectors | Cement, iron and steel, aluminium, fertilisers, electricity, hydrogen | Annex I |
| Transitional period | 1 October 2023 to 31 December 2025: reporting only | Reg 2023/956 |
| Definitive period | From 1 January 2026 | Reg 2023/956 |
| Small importers | Exempt up to 50 tonnes net mass a year per importer | Reg (EU) 2025/2083 |
| Certificates | Sold from 1 February 2027; first declaration and surrender by 30 September 2027 for 2026 imports | Reg 2023/956 as amended |
| Framework | Who sets it | Who must use it | Main audience |
|---|---|---|---|
| BRSR | SEBI | Top 1,000 Indian listed companies | Investors and other stakeholders |
| GRI | Global Reporting Initiative | Voluntary | Anyone affected by the company |
| IFRS S1 and S2 | ISSB | Where a jurisdiction adopts them | Investors |
| ESRS | European Union | Companies within the EU rules | Investors and stakeholders |
| CBAM data | European Union | Importers into the EU of covered goods | EU customs authorities |
| # | Statement | Problem |
|---|---|---|
| 1 | Scope 2 calculated with the CEA factor from a version published several years ago | The ISF note requires the latest applicable CEA factor |
| 2 | Energy table with grid electricity in kWh and fuels in GJ, added together | Units must be consistent; the format asks for Joules or multiples |
| 3 | LTIFR of 0.10, "per 200,000 hours worked" | The BRSR base is one million hours; on that base the rate is 0.50 |
| 4 | Gross wages to women: 14%, with the previous-year column blank | Both years are required for essential indicators |
| 5 | "Carbon neutral since 2024", with Scope 1 and 2 unchanged and offsets bought | A claim resting on offsets, without a reduction; disclose both separately |
| Item | Value | Item | Value |
|---|---|---|---|
| Revenue from operations | Rs 5,000 crore | Groundwater withdrawn | 300,000 kL |
| Grid electricity | 18,000 MWh | Municipal water bought | 120,000 kL |
| Own rooftop solar | 2,000 MWh | Water discharged | 80,000 kL |
| Diesel burnt | 210 t | Waste generated | 1,200 t |
| LPG burnt | 40 t | Hours worked | 12 million |
| Total gross wages | Rs 300 crore | Lost-time injuries | 6 |
| Wages paid to women | Rs 42 crore | Wellbeing spending | Rs 40 crore |
| Indicator | Calculation | Result |
|---|---|---|
| Scope 1 (combustion CO2) | 669.1 (diesel) + 119.4 (LPG) | 788.5 t |
| Scope 2 (location-based) | 18,000 MWh x 0.710 | 12,780 t |
| Scope 1 + 2 intensity | 13,568.5 / 5,000 | 2.71 t per Rs crore |
| Scope 1 + 2 per PPP revenue | 13,568.5 / 2,232.1 (at 22.4) | 6.08 t per million PPP $ |
| Total energy | 64,800 + 7,200 + 9,030 + 1,892 | 82,922 GJ |
| Renewable share | 7,200 / 82,922 | 8.7% |
| Water consumption | 420,000 – 80,000 | 340,000 kL |
| Waste recovered | (700 + 100) / 1,200 | 66.7% |
| Indicator | Calculation | Result |
|---|---|---|
| Wellbeing spending | 40 / 5,000 | 0.8% of revenue |
| LTIFR | 6 x 1,000,000 / 12,000,000 | 0.50 |
| Wages paid to women | 42 / 300 | 14.0% |
| Inputs from MSMEs and small producers | 600 / 2,500 | 24% |
| Days of accounts payable | 350 x 365 / 2,500 | 51.1 days |
| Item | Value | Source |
|---|---|---|
| BRSR mandatory | From FY 2022-23, top 1,000 | SEBI circular of 10 May 2021 |
| Ranking | Average market cap, 1 July to 31 December | LODR Reg 3(2) |
| Core checking | Top 150 (FY 2023-24) to top 1,000 (FY 2026-27) | SEBI circular of 12 July 2023 (BRSR Core) |
| Wording since 28 March 2025 | "Assessment or assurance" | SEBI circular of 28 March 2025 |
| Value chain partner | 2% or more individually; voluntary from FY 2025-26 | SEBI circular of 28 March 2025 |
| Grid factor | 0.710 t CO2/MWh (FY 2024-25) | CEA CO2 Baseline Database, Version 21.0, November 2025 |
| LTIFR base | Per one million hours worked | SEBI LODR Master Circular, updated 30 January 2026, Annexure 16 |
| GWP (AR6) | CH4 27.0 non-fossil, 29.8 fossil; N2O 273 | IPCC AR6 WG1 Table 7.15 |