Overview of SEBI
Introduced: May 2021 (BRSR); July 2023 (BRSR Core)
Effective from: FY 2022-23 (BRSR); FY 2023-24 onward (BRSR Core)
Last modified: April 2024 (clarifications on assessment requirements)
Region(s): India
About
India’s Securities and Exchange Board (SEBI) has instituted one of the most detailed ESG disclosure regimes in the Global South, replacing the Business Responsibility Report (BRR) with the SEBI Business Responsibility & Sustainability Report (BRSR).
BRSR mandates comprehensive ESG data reporting from India’s top 1,000 listed companies. In 2023, SEBI introduced the BRSR Core, a refined subset of 49 Key Performance Indicators (KPIs) focused on measurable climate and social metrics—including absolute and intensity-based GHG emissions, renewable energy share, water use, and gender diversity.
The BRSR Core also establishes a glide path for mandatory third-party assessment, beginning with India’s 150 largest companies and expanding to cover the top 1,000 listed firms by FY 2026-27. The objective: improve ESG data credibility, inform investor decision-making, and support India’s commitments to net-zero by 2070.
Criteria for compliance
Compliance is based on a phased rollout according to company market capitalization:
- In FY 2022-23: All top 1,000 listed companies must file the BRSR (no assessment required)
- In FY 2023-24: The top 150 companies are required to report BRSR Core disclosures with assessment
- In FY 2024-25: Applies to the top 250 companies
- In FY 2025-26: Expands to the top 500 companies
- In FY 2026-27: All top 1,000 companies must file BRSR Core with assessment
Disclosure requirements
All companies must include BRSR disclosures in their annual report (Form MGT-7) and file in XBRL format with SEBI.
BRSR (Base Framework)
Covers general ESG performance, including environmental data (energy, emissions, water, waste), workforce and community impact, board and management policies, and business conduct.
BRSR Core
- Scope 1, 2, and 3 GHG emissions (absolute and intensity-based)
- Energy usage and renewable energy mix
- Water usage and waste management
- Social indicators such as workforce size, gender ratio, inclusivity efforts, and training
- Climate risk narrative aligned with TCFD (voluntary for now)
- Partial supply chain emissions disclosure for top 250 companies under a “comply or explain” basis
Key obligations
- Disclose BRSR or BRSR Core data annually, embedded in the company’s annual report
- Submit machine-readable (XBRL) filings to exchanges
- Ensure board-level approval
- For top 250 companies, disclose relevant value-chain emissions or explain omissions
Third-party assessment
Companies subject to the BRSR Core must obtain an assessment on the 49 KPIs, performed by either their statutory auditor or an SEBI-accredited assessment provider. SEBI is currently reviewing whether to require an assessment for upstream/downstream emissions data in future BRSR Core iterations, post–2026.
Penalties for non-compliance
Breaches of SEBI’s ESG disclosure rules are treated as violations of India’s Listing Obligations and Disclosure Requirements (LODR), and may result in:
- Fines up to ₹25,000 per day of noncompliance
- Suspension of trading
- Debarment of directors
- Legal liability for material misstatements or omissions in ESG filings