How to Navigate BRSR Reporting Requirements for Corporates in India

In recent years, the concept of sustainability has become increasingly prominent in the corporate world, with companies around the globe recognizing the importance of incorporating environmental, social, and governance (ESG) factors into their business practices. In India, one of the key mechanisms for companies to communicate their sustainability performance is through Business Responsibility and Sustainability Reporting (BRSR).

The BRSR Evolution in India

In 2009, the Ministry of Corporate Affairs (MCA) took the first step towards promoting Corporate Social Responsibility (CSR) in India by issuing the 'Voluntary Guidelines on Corporate Social Responsibility,’ marking the beginning of a new era in which businesses were encouraged to take responsibility for their social, environmental, and economic impacts.

Two years later, in June 2011, India endorsed the United Nations Guiding Principles on Business and Human Rights (UNGPs), demonstrating a commitment to aligning business practices with human rights standards. The MCA furthered its commitment to CSR by releasing the 'National Voluntary Guidelines on Social, Environmental, and Economic Responsibilities of Business, 2011' (NVGs). These guidelines were developed through extensive consultations with various stakeholders, including businesses, academia, civil society organizations, and the government. They also included a Business Responsibility Reporting framework, encouraging companies to go beyond regulatory financial compliance and report on their social and environmental impacts.

In 2012, the Securities and Exchange Board of India (SEBI) mandated the top 100 listed companies by market capitalization to file Business Responsibility Reports (SEBI-BRRs/BRR) through the Listing Agreement. This move aimed to encourage companies to engage more meaningfully with their stakeholders and promote transparency.

The requirement for filing BRRs was extended to the top 500 listed companies by market capitalization from the financial year 2015. In March 2019, the updated NVGs were released as the ‘National Guidelines for Responsible Business Conduct’ (NGRBCs), further emphasizing the importance of responsible business practices. In 2019, SEBI extended the BRR requirement to the top 1000 listed companies by market capitalization, from the financial year 2019-20, showing a continued commitment to promoting corporate social responsibility and transparency in business practices. 

In May 2021, SEBI introduced Business Responsibility and Sustainability Reporting (BRSR), a significant evolution of the Business Responsibility Reporting (BRR) framework. The BRSR requires the top 1,000 listed entities (by market capitalization) to include BRSR as a part of their Annual Report filed with SEBI from the financial year 2022-23 onwards.

Additionally, in 2023, SEBI mandated reasonable assurance for BRSR Core, further emphasizing the importance of transparency and accountability in corporate reporting. This requirement signals a move towards more rigorous reporting standards, ensuring that businesses adhere to responsible and sustainable practices and providing stakeholders with greater confidence in the information disclosed.

BRSR Reporting Guidelines:

SEBI has outlined a set of guidelines for BRSR reporting, including the following key aspects:

• Scope and Coverage: The scope of BRSR reporting includes various sustainability-related parameters such as environmental, social, and governance (ESG) factors. Companies are required to provide information on their policies, initiatives, and performance in these areas.
• Reporting Framework: SEBI has recommended the use of a standardized reporting framework, such as the Global Reporting Initiative (GRI) Standards or the Sustainability Accounting Standards Board (SASB) Standards, to ensure consistency and comparability in reporting.
• Reporting Period: Companies are required to report on their sustainability performance for the previous financial year, with the reporting period ending on March 31st.
• Reporting Format: SEBI has prescribed a specific format for BRSR reporting, which includes various sections such as vision and mission, governance structure, stakeholder engagement, business ethics, and environmental performance, among others.
• Assurance: Companies are required to obtain independent assurance on their BRSR Core reports from a qualified third-party auditor to enhance credibility and reliability.

What Needs to be Included in a BRSR Report?

SEBI has a published guidance document that details everything required to be included in the report, these include:

1. General Disclosures

2. Management & Process Disclosures

3. Principle Wise Performance Disclosure

General Disclosures

These are introductory sections that provide essential information about the company's business model, sector, and geographical presence. They may also include a statement from the company's leadership about its commitment to sustainability and responsible business practices.

Management & Process Disclosures 

These sections detail the company's governance structure, including the composition of its board of directors and the presence of dedicated committees for sustainability and CSR. They also cover the company's risk management processes, including how environmental and social risks are identified, assessed, and managed. In addition, this section may discuss the company's approach to stakeholder engagement and how it addresses the concerns of various stakeholders, including employees, customers, suppliers, and communities.

Principle-Wise Performance Disclosure

This is the heart of the BRSR report, where companies provide detailed information on their performance against specific principles or indicators. These principles are typically aligned with international standards, such as the United Nations' Sustainable Development Goals (SDGs) or the Global Reporting Initiative (GRI) framework. They may cover a wide range of topics, including environmental impact, employee welfare, human rights, diversity and inclusion, supply chain management, and community engagement. For each principle, companies are expected to provide quantitative and qualitative data, along with narrative explanations, to demonstrate their performance.

Understanding the 9 principles of BRSR 

The BRSR reporting framework is based on nine principles that businesses can follow to include responsible and sustainable practices in their operations. These principles act as a guide, helping companies integrate sustainability into their reporting effectively.

Principle 1: Businesses should conduct and govern themselves with integrity, and in a manner that is Ethical, Transparent and Accountable.

This principle underscores the importance of ethical decision-making, transparent communication, and accountability for actions and outcomes. It urges companies to develop robust corporate governance frameworks, adopt anti-corruption measures, disclose financial data openly, and engage in ethical lobbying practices. This approach enables companies to build trust with stakeholders, appeal to responsible investors, and reduce the likelihood of ethical controversies. 

Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe

This principle advocates for reducing environmental impact and ensuring product safety at every stage of a product's life cycle, from material sourcing to disposal. It promotes the adoption of resource-efficient production methods, investment in renewable energy, waste reduction, sustainable packaging, and rigorous product testing. These actions help companies reduce their environmental footprint, cut operational expenses, and safeguard consumers and the environment.

Principle 3:  Businesses should respect and promote the well-being of all employees, including those in their value chains

This principle advocates for the equitable and responsible treatment of all employees, prioritizing their physical and mental health, safety, and career growth. It advocates for providing fair compensation and benefits, fostering a secure and inclusive workplace, offering opportunities for training and advancement, and upholding employees' rights to association and collective bargaining. These practices can enhance employee satisfaction and productivity, lower turnover rates, and attract and retain high-caliber talent.

Principle 4: Businesses should respect the interests of and be responsive to all its stakeholders

This principle underscores the importance of recognizing and engaging with all stakeholders, especially those who may be vulnerable or marginalized and addressing their needs and concerns. It promotes establishing transparent communication channels, conducting regular consults with stakeholders, involving them in decision-making processes, and proactively seeking inclusive solutions to their issues. By doing so, companies can cultivate trust and collaboration with stakeholders, reduce social conflicts, and bolster their social license to operate.

Principle 5: Businesses should respect and promote human rights

This principle prioritizes the protection and respect of human rights across all business activities and supply chains. It promotes conducting thorough human rights assessments, implementing anti-discrimination policies, guaranteeing fair labor standards throughout the supply chain, and proactively addressing any potential human rights violations. These efforts foster ethical and responsible business practices, reduce legal liabilities, and contribute to a more equitable and sustainable global community.

Principle 6: Businesses should respect and make efforts to protect and restore the environment

This principle underscores the importance of reducing environmental impact, conserving natural resources, and undertaking efforts to repair environmental harm. It encourages businesses to decrease their carbon footprint and greenhouse gas emissions, conserve water and other resources, reduce pollution, safeguard biodiversity, and promote initiatives for environmental restoration. These actions contribute to environmental sustainability, reduce environmental risks, and improve brand reputation.

Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent

This principle promotes responsible involvement in public policy and regulatory processes, striving for outcomes that align with the interests of both business and society. It urges organizations to engage transparently in policy discussions, refrain from lobbying efforts that harm the public interest, prioritize sustainable solutions, and adhere to democratic processes. These actions foster positive relationships with policymakers and regulators, facilitate sustainable policy development, and prevent reputational harm 

Principle 8: Businesses should promote inclusive growth and equitable development

This principle advocates for businesses to support the social and economic growth of the communities they are involved in, promoting fair access to opportunities and benefits. It advises organizations to invest in local communities, generate employment, assist in infrastructure development, encourage access to education and healthcare, and engage in partnerships for inclusive development. These actions enhance social welfare, reduce social disparities, and bolster business resilience by fostering robust community ties.

Principle 9: Businesses should engage with and provide value to their consumers in a responsible manner

This principle underscores the importance of honest and ethical marketing practices, fostering trust and delivering value to customers through transparent communication and ethical product offerings. It advises organizations to steer clear of deceptive advertising, offer accurate and pertinent product information, address customer inquiries promptly and efficiently, and prioritize customer safety and satisfaction. These actions bolster customer loyalty, decrease consumer complaints, and elevate the brand reputation as a reliable and ethical business. 

Despite the existing reporting framework's emphasis on transparency between businesses, investors, and end consumers, companies are still struggling with the challenges of monitoring and quantifying scope 3 emissions in particular. 

The Benefits of BRSR Reporting:

Although the top 1,000 listed companies by market capital must file their BRSR reports, this shouldn’t be an exercise for legal compliance purposes. There are several reasons to file BRSR:

• Enhanced business value: The process of completing ESG reporting presents an opportunity to identify new business prospects or alter market positioning. There is a growing consumer demand for sustainable products and services, and companies that can make credible sustainability claims have the potential to outperform their rivals.
• Increased access to capital investment: Investors in India and worldwide are demanding better sustainability performance as part of their investment decision-making process. This includes evaluating not only environmental performance but also other ESG metrics like diversity and inclusion, as well as transparency in leadership. Companies that can demonstrate strong ESG programs are more likely to attract more investment in the future.
• Lowered risk: ESG reporting allows companies to identify and mitigate risks proactively. Companies with robust ESG programs are often referred to as “future-proof” because they can significantly reduce risk not only within their own operations but also within their supply chain, among subsidiaries, or within their own investment portfolio.
• Enhanced corporate governance: The impact of business operations on the community is significant, and more and more people are demanding tangible evidence of a company’s sustainability claims. A well-documented ESG program serves as that proof, following internationally accredited methodologies.
• Attracting talent: Nowadays, new employees, particularly specialists and subject-matter experts, seek more than just a paycheck. They want to know that their efforts are not only benefiting the company but also the community and the world at large. Meaningful, sustainable work is what motivates this generation of talent, and being able to demonstrate the impact is key to retaining them over the long term.

How To Prepare An Accurate BRSR Report? 

India's ambitious carbon reduction goals, combined with expected economic growth over the next decade, require businesses to meet BRSR requirements and ensure their data can be verified by stakeholders and lenders. This demands detailed data collection and the use of internationally-recognized methodologies, which can be time-consuming and taxing on staff who may not have previously handled this work. Implementing streamlined platforms for data collection and analysis is essential. 

Platforms like StepChange can help ESG teams gather the necessary information and produce compliant reports according to BRSR, SABS, GRI, IR, and international standards and frameworks with ease, saving the organization time, resources and money. These tools ensure emissions estimates are always up-to-date and can be effortlessly updated at any time. If your organization is tackling the challenges of meeting BRSR requirements, StepChange offers support for your ESG reporting initiatives. Schedule a meeting with one of our experts today.

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