Sign in Subscribe
SEBI BRSR

BRSR Core at the Halfway Mark: What is Working and What Isn't

India's BRSR Core framework is at its halfway point. What is working, and what isn't? This analysis examines assurance progress among the top companies and four unresolved challenges with value-chain disclosure under SEBI's Master Circular dated 30 January 2026

Nachiketa Das

Nachiketa Das

— 4 min read
Share

India's BRSR Core framework is at its halfway point. SEBI's phased glide path mandates assurance or assessment for the top 500 listed entities by market capitalisation from FY 2025-26 — the current reporting period — before extending to the top 1,000 from FY 2026-27. BRSR Core disclosures for the value chain were to follow a parallel path before SEBI's circular dated 28 March 2025 shifted them to a voluntary construct, with these changes since consolidated into the Master Circular dated 30 January 2026. With the mandate about to double in scope, this is a useful moment to take stock of how far BRSR Core has really come.

The interesting story so far is not that the top 150 complied with mandatory disclosure and assurance or assessment — they were obligated to. What is more telling is how far beyond the regulatory floor they went. A review of 94 NIFTY 100 listed entities for FY 2024-25 found that 57 obtained voluntary third-party assurance over sustainability or ESG information beyond BRSR Core disclosures. For BRSR Core itself, every one of the 94 opted for reasonable assurance — none chose the lighter-touch assessment route introduced in March 2025.

For a meaningful share of India's boardrooms, assurance is more than compliance. It is a credibility signal — to global institutional investors, to MNC customers bracing for CSRD-aligned supply chain mandates, and to rating agencies.

Yet the same study reveals how fragile this progress is. Nearly half (45 of the 94) restated their FY 2023-24 comparative BRSR figures in FY 2024-25. The reasons are instructive: 18 revised for changes in methodology, classification, or measurement convention; 16 to align with SEBI guidance on BRSR Core issued in December 2024; 6 for organisational boundary changes from mergers or standalone-to-consolidated shifts; 5 provided no explanation.

Reporting systems, even at the top of the market, are still catching up to an evolving framework.

Now extend this picture to value chain disclosures, and the difficulties compound considerably.

SEBI has made BRSR Core disclosures for the value chain applicable to the top 250 listed entities on a voluntary basis from FY 2025-26, with assessment or assurance also voluntary from FY 2026-27. The scope has been narrowed to value chain partners individually comprising 2% or more of purchases or sales by value, capped at 75% of the total. The deferral and reduction in scope were pragmatic — most MSME value chain partners were not ready, and reliable data was not accessible. But the framework sidesteps four methodological problems that time alone will not resolve.

  1. Attribution: A listed entity must report BRSR Core KPIs for its value chain "to the extent attributable to their business" with each partner. If an FMCG entity sources palm oil from a supplier that serves fifteen buyers, how should it apportion the supplier's GHG emissions, water withdrawal, or waste generation? Revenue share? Volume share? Physical throughput? The framework is silent. Without a prescribed methodology, two listed entities sourcing from the same supplier can legitimately report very different numbers — defeating the purpose of standardisation.
  2. Ratio-based KPIs: Several BRSR Core indicators are ratios — gross wages paid to women as a percentage of total wages, job creation in smaller towns, spending on employee wellbeing. These are meaningful for a single reporting entity. But for a value chain partner, two questions arise. First, how should the listed entity attribute the ratio? If a supplier's overall female wage ratio is 28% but the manufacturing line attributable to the listed entity has a different workforce composition, the entity-level ratio may not reflect the actual footprint, while product-line attribution is practically impossible. Second, how should the listed entity consolidate ratios across partners? If Partner A reports 20%, Partner B reports 50%, and Partner C reports 12%, a simple average masks the underlying wage bill sizes — a credible consolidation requires weighting by total wages paid, which in turn requires data that partners may not be willing to share. The Master Circular is silent on both questions.
  3. Disclosure format: The Master Circular permits value chain reporting "segregated for upstream and downstream partners or on an aggregate basis." But aggregate reporting — weighted averages across multiple partners — masks significant variation. A listed entity whose top five partners are low-emission IT firms and whose sixth is a coal-dependent chemical manufacturer will report an aggregate intensity that obscures material risk. Partner-wise disclosure raises confidentiality concerns. SEBI has not specified whether weighted-average, consolidated-total, or partner-wise formats are preferred.
  4. Reporting period alignment: A listed entity's annual report is tied to regulatory filing timelines. But value chain partners — particularly global partners and private MSMEs — often operate on different fiscal years and data maturity cycles. How does a listed entity integrate value chain disclosures on its own timeline when supplier-specific data for the current period may simply not be available? The Master Circular addresses this only partially: for the first year of reporting, previous-year value chain data is voluntary. But the logic is arguably inverted. Previous-year supplier data is the data most likely to be available — entities have had time to close their books. Current-year data is harder to obtain within the listed entity's reporting window. The relaxation should have moved the other way.

These are not theoretical objections. They are the questions sustainability teams preparing BRSR reports are confronting right now, without adequate guidance.

India's BRSR framework is among the more ambitious ESG disclosure regimes globally, and its focus on extending accountability beyond the reporting boundary is exactly right. Most of a listed entity's environmental and social impact sits in its value chain. But ambition without methodological clarity produces disclosures that look comprehensive and mean very little. The listed entities that will differentiate themselves are not those that file first, but those that develop internally consistent attribution methodologies, disclose their assumptions transparently, and build data systems that can withstand assurance scrutiny when it becomes mandatory.

The question is no longer whether India's listed entities will report on their value chains. It is whether what they report will be worth comparing.

References

Read more