SEBI BRSR — Business Responsibility and Sustainability Reporting Guide for Listed Companies

BRSR is anchored in SEBI circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 (May 2021) and successive amendments. It replaces the Business Responsibility Report (BRR) and is mandatory for the top 1,000 listed companies by market cap from FY 2022-23. Smaller listed and unlisted companies may file voluntarily. BRSR organises disclosures against the nine National Guidelines on Responsible Business Conduct (NGRBC) principles: P1 — Ethical conduct, transparency and accountability P2 — Sustainable and safe product / service lifecycle P3 — Employee wellbeing, including value-chain workers P4 — Respect for stakeholder interests (esp. vulnerable / marginalised) P5 — Human rights P6 — Environment — energy, emissions, water, waste P7 — Responsible policy advocacy P8 — Inclusive growth and equitable development P9 — Customer value — product quality, marketing, grievance redressal BRSR Core (added 2023): a sub-set of 9 KPIs across the BRSR principles that carry MANDATORY independent assurance. Initially applied to top 150 listed cos from FY 2023-24, expanding to top 250 (FY 2024-25), 500 (FY 2025-26) and 1,000 (FY 2026-27) — phased. BFSI-specific BRSR considerations: • Financed emissions (Scope 3 for banks) — increasingly material disclosure • Exposure to high-carbon sectors (thermal power, oil & gas, cement, steel) by loan book share • Climate risk in loan portfolio — physical vs transition risk concentration • Gender diversity at branch + senior leadership level • Priority-sector lending and MSME inclusion as social-pillar metrics

• One of the most granular global ESG frameworks — 1,000+ data points
• 9 NGRBC principles align with UN Guiding Principles on Business and Human Rights
• Mandatory independent assurance under BRSR Core eliminates self-graded greenwashing
• Quantitative format makes year-over-year and cross-company benchmarking feasible
• Phased rollout (top 150 → 1,000) gives smaller listcos time to build data systems

• Scope-3 financed-emissions methodology not specified — banks self-attest
• No materiality threshold — every principle must be addressed even if non-material
• Assurance providers under BRSR Core are not yet credential-accredited by SEBI
• Cross-listing comparability vs IFRS S1/S2 + CSRD still being mapped

• Reliance Industries — first Indian BRSR filing (FY 2022-23) became a market benchmark; ~280 pages
• ITC's BRSR FY 2023-24 disclosed Scope-3 financed-emissions for the first time, voluntarily
• TCS BRSR voluntarily assured by Big-4 auditor — driving valuation premium in ESG indices

• Issue a BFSI-specific BRSR sectoral supplement
• Cross-walk BRSR principles to IFRS S1 + S2 (ISSB) for global investor convenience
• Accreditation regime for BRSR Core assurance providers