BRSR for banks, NBFCs and insurers, where the people data is the hard part.
Social and governance disclosures come from HR, information security, finance and the secretarial team. Sustano gives each owner their KPIs, keeps the evidence with every answer, and lets the company secretary review and lock.
Why financial services BRSR is different
Listed banks, NBFCs and insurers in the top 1000 file BRSR like any other company (SEBI circular 2021/562). The difference is where the data comes from.
- The data owners are functions, not plants: HR, information security, customer service, finance and the secretarial team.
- Social and governance disclosures dominate, and much of the BRSR is narrative that needs evidence behind it.
- The company secretary signs off, but the working sits in email attachments from several departments.
Five BRSR Core attributes usually need the most work (SEBI, Format of BRSR Core; all nine):
| BRSR Core attribute | KPIs in Sustano | Example KPI |
|---|---|---|
| Employee well-being and safety | 5 | Spending on the well-being of employees and workers |
| Gender diversity | 2 | Gross wages paid to women as a share of total wages |
| Inclusive development | 2 | Job creation in smaller towns |
| Fairness with customers and suppliers | 2 | Instances of customer data breaches |
| Openness of business | 7 | Share of related-party transactions |
Named owners, evidenced answers, secretarial sign-off.
Each function owns its KPIs, and sees only those.
HR owns well-being spend and wages, information security owns data-breach counts, finance owns related-party figures. Every entry carries its evidence.
Data collectionThe full BRSR, narratives and tables.
Sections A, B and C across all nine principles. Figures in tables come from your approved data, and narrative answers point to the evidence behind them.
ReportingThe company secretary reviews and locks.
Each disclosure has an owner and a different reviewer, who approves and locks it or sends it back with a comment. The final report is generated only when every required disclosure is locked.
Approvals and audit trailA fictional NBFC gets its BRSR to sign-off
Illustrative: a fictional company. Names and figures are examples only.
- A fictional listed NBFC sets up its head office and regional offices, and gives each BRSR disclosure an owner.
- HR enters well-being spend and wages by gender with payroll summaries attached. Information security records the year’s customer data-breach count with the incident register.
- Finance fills in the related-party table from approved figures, so the table and the report always agree.
- The company secretary, as reviewer, returns one narrative with a comment, then approves and locks the rest.
- When every required disclosure is locked, the final report is generated for filing.
Frequently asked questions
Does Sustano calculate financed emissions?
No. Sustano covers the BRSR and BRSR Core disclosures about your own organisation, including GHG Scope 1 and 2. It does not calculate financed emissions or provide portfolio analytics.
Can narrative answers carry evidence?
Yes. A narrative answer can point to the documents that support it, and must do so where BRSR asks for evidence.
See a BRSR disclosure move from HR to a locked report.
Book a demo and we will walk through disclosure assignment, evidence and secretarial sign-off with an illustrative dataset.