For sustainability, finance and secretarial teams at Indian listed companies preparing their first, or first full, BRSR Core cycle. Every regulatory statement links to its SEBI or NSE circular. Where the circulars leave the detail to SEBI's format or to your assessor, we say so. The practical advice is ours, and is marked "What to do".
FY2026-27 at a glance
- Top 1000 are in. The BRSR Core glide path reaches the top 1000 listed entities by market capitalisation in FY2026-27 (SEBI circular 2023/122).
- Assessment or assurance. Since 28 March 2025, BRSR Core needs assessment or assurance. Assessment follows standards of the Industry Standards Forum (ISF), in consultation with SEBI. The glide path did not change (SEBI circular 2025/42).
- Independent providers only. The provider and its associates may not sell the company or its group products or other services, including consulting (SEBI circular 2023/122; 2025/42).
- Value chain stays voluntary. Voluntary disclosure for the top 250 from FY2025-26; voluntary assessment or assurance from FY2026-27 (SEBI circular 2025/42).
- Two formats, one day. BRSR is filed in PDF and XBRL, on the same day as the annual report (NSE circular NSE/CML/2024/11).
Who is covered: the glide path
BRSR Core is a subset of BRSR: KPIs under nine ESG attributes, introduced on 12 July 2023 (SEBI circular 2023/122). The circular phased the independent check in by size:
| Financial year | Listed entities covered |
|---|---|
| FY2023-24 | Top 150 listed entities by market capitalisation |
| FY2024-25 | Top 250 |
| FY2025-26 | Top 500 |
| FY2026-27 | Top 1000 |
Applicability is measured on market capitalisation as on 31 March. Once BRSR applies, it continues to apply even if the company later falls below the threshold (LODR Regulation 3(2)), and companies outside the top 1000 may file voluntarily (NSE circular NSE/CML/2024/11).
What to do: check your position on the basis the exchange uses, record the check and its date, and repeat it each year. If you are near the boundary, prepare as if you are in: the data work is the same.
Assessment or assurance
A company may obtain either an assessment or assurance. Where applicable, the reasonable assurance certificate is attached to the BRSR filing (NSE circular NSE/CML/2024/11). The independence rule applies to both routes (SEBI circular 2025/42, para 4.2). BRSR Core explained sets out the two routes and the rule in full.
What to do: decide the route early, because it determines who you engage and when. Ask your provider which standards they will apply, and get their independence confirmed in writing. Either way, the practical test is the same: can someone independent follow each Core value back to its source and arrive at the same figure?
Value-chain disclosures
Value-chain partners are those that individually account for 2% or more of purchases or sales, and the disclosure may be limited to 75% coverage (SEBI circular 2025/42). Both the disclosure and its assessment or assurance stay voluntary in FY2026-27.
What to do: even if you do not disclose this year, rank your suppliers and customers by share of purchases and sales and mark those at 2% or more. That list tells you how many partners a future disclosure would involve and how long collecting their data would take. Our value-chain page sets out a four-step plan.
Filing: PDF and XBRL
BRSR goes to the exchange in both PDF and XBRL on the same day as the annual report (NSE circular NSE/CML/2024/11). The BRSR and BRSR Core formats are Annexures 16 and 17A of SEBI's LODR master circular.
What to do: treat the XBRL filing as a second output of the same approved data, not a separate project. Every figure in the XBRL should be the same locked value that appears in the PDF. Build your timetable back from the day your annual report is published, and leave time for the assessment or assurance report to be ready before then.
Data requirements, attribute by attribute
The KPI definitions, units and intensity bases are set by SEBI's BRSR Core format (Annexure I to the July 2023 circular, now Annexure 17A). Always work from the current format. What follows describes, in general terms, the data each attribute draws on and where teams get stuck. KPI counts are as modelled in Sustano's BRSR Core pack. For any intensity per rupee of turnover adjusted for purchasing power parity, also record the turnover figure and the PPP conversion basis, with their source.
Greenhouse gas (GHG) emissions (3 KPIs)
What it covers: Your greenhouse gas emissions and the related intensity ratios.
Data to gather:
- Fuel consumed by facility and month, for stationary and mobile combustion, from purchase and consumption records.
- Process and fugitive sources where they apply, for example refrigerant top-up logs.
- Purchased electricity, steam or heat by facility and month, from bills or meter readings.
- The emission factors, net calorific values and GWP set applied, each with source and version.
Watch for: Record which grid factor version you used and whether Scope 2 is location-based or market-based. See our post on Scope 2 in India and CEA versions.
Water (3 KPIs)
What it covers: How much water you draw, use and discharge, and the related intensity.
Data to gather:
- Meter readings by source and facility, with municipal, tanker and other bills where water is bought.
- Discharge records, including where water goes and how it is treated.
- Estimation notes for any facility without meters, with the method written down.
Watch for: Units drift between kilolitres, cubic metres and litres across plants. Convert once, in one place, and keep the original reading.
Energy (3 KPIs)
What it covers: The energy you consume, by source, and the related intensity.
Data to gather:
- Electricity from the grid and from other sources, by facility and month.
- Fuel quantities, converted to energy with net calorific values.
- The source of each NCV: a default such as IPCC 2006, or a laboratory certificate or supplier declaration.
Watch for: Energy and GHG share their inputs. Use the same fuel records for both, so the two attributes reconcile.
Waste and circularity (5 KPIs)
What it covers: The waste you generate, by category, and how it is recovered or disposed of.
Data to gather:
- Waste manifests and disposal records by category and facility.
- Receipts from recyclers and disposal facilities.
- Any conversion from volume or count to weight, with the basis recorded.
Watch for: Waste data is transaction-style: many small records. Keep each manifest as a row with its document, rather than a monthly total typed by hand.
Employee well-being and safety (5 KPIs)
What it covers: Spending on employee well-being and the safety record of your workforce.
Data to gather:
- Well-being spend from finance, with the cost heads included.
- Injury and incident registers from the safety function, by facility.
- Hours worked from HR or payroll, for safety rates such as LTIFR.
Watch for: Numerator and denominator come from different teams. Agree the period and headcount basis before year-end.
Gender diversity (2 KPIs)
What it covers: Gender diversity data, including wages paid to women, one of the India-specific KPIs SEBI highlighted.
Data to gather:
- Payroll data by gender for the reporting period.
- Total wages, so the share paid to women can be calculated and re-performed.
Watch for: Payroll extracts contain personal data. Share the aggregated figures and the method, and keep the extract under controlled access.
Inclusive development (2 KPIs)
What it covers: Contribution to inclusive growth, including job creation in smaller towns, one of the India-specific KPIs SEBI highlighted.
Data to gather:
- Wage records by location, classified the way the format requires.
- Procurement records with the supplier attributes the format asks for.
Watch for: Location classification is the hard part. Record the classification basis used for each site once, and reuse it.
Fairness with customers and suppliers (2 KPIs)
What it covers: How fairly the company deals with its customers and suppliers, including customer data breaches.
Data to gather:
- Records of customer data breaches from IT or information security.
- The customer and supplier records the format names, from the functions that own them.
Watch for: Owners of this data are often outside the sustainability team. Assign each KPI to a named contributor and reviewer early.
Openness of business (7 KPIs)
What it covers: The openness of the company's business dealings, including related-party transactions.
Data to gather:
- Purchase and sales records, to calculate the shares the format asks for.
- Related-party transaction records from the company secretariat and finance.
- Reconciliation to the audited financial statements.
Watch for: These figures must agree with the financial statements. Involve finance and the company secretary as reviewers.
Related reading: Scope 2 in India: CEA factors and versions, and glossary entries for NCV, emission factor, LTIFR and consolidation boundary.
Building the evidence file
The circulars decide who must be checked and who may check. They do not tell you how to organise your working papers; your provider sets their own procedures. In practice, an assessor picks a reported figure and follows it down to the calculation, the factors, the facility entries, the documents and the approvals. Our post What an assessor will ask for lists the six things to hold for each Core KPI.
What to do: organise the file by KPI, not by department, and build it during the year as values are approved. It is then complete when the year closes.
Readiness checklist
Use this list to find gaps before your assessor does. It is practical guidance, not a regulatory list.
Scope and route
- We have confirmed whether we are in the top 1000 on the exchange's basis, and recorded the check.
- We have chosen assessment or assurance, and read the March 2025 circular for that route.
- Our provider has confirmed in writing that it provides us and our group no products or non-assurance services, including consulting.
- We have decided whether to make a voluntary value-chain disclosure this year.
Boundary and ownership
- Every facility is listed, with its consolidation basis, and every exclusion has a written justification.
- Every Core KPI has a named owner at each facility, a contributor and a reviewer who is a different person.
- Finance and the company secretary review the KPIs that must agree with the financial statements.
Data and calculations
- Monthly data is collected by facility, not only as annual totals.
- Units are converted in one place, and the original readings are kept.
- Every calculation can be shown with the period's real inputs and a per-facility breakdown.
- Intensity ratios record the turnover figure and PPP conversion basis used.
Factors
- Every emission factor and NCV has a source and a version or vintage.
- Factor versions match the reporting year, or the difference is explained.
- We know which grid factor version we used for Scope 2, and which method each Scope 2 figure uses.
Evidence and approvals
- Each facility value links to the document that supports it.
- Each value records who entered, reviewed and locked it, and when.
- Changes after review are recorded with before and after values and a reason.
- We have taken one attribute through to a complete evidence file as a dry run.
Filing
- The PDF and XBRL are produced from the same locked values.
- The timetable works back from the annual report date, with time for the assessment or assurance report.
A working timeline
FY2026-27 runs from April 2026 to March 2027. The circulars fix the scope and the filing day; the plan below is our suggestion for a first cycle, starting from today. Adjust it to your annual report date.
| When | Focus |
|---|---|
| October to November 2026 | Confirm scope and route. Appoint and check the independence of your provider. Fix the facility list, boundary and KPI owners. Decide on value-chain disclosure. |
| November to December 2026 | Load April to September data by facility and month, with evidence. Record every factor's source and version. Take one attribute through a dry run. |
| January to March 2027 | Collect monthly as you go. Review and lock each month after it closes. Resolve gaps found in the dry run. Agree with your provider what they will sample and how. |
| April 2027 onwards | Close the year. Lock the period. Reconcile facility totals to reported figures and financial figures. Hand over the evidence file. |
| Before the annual report | Assessment or assurance report received. BRSR finalised in PDF and XBRL from the same locked values, and filed on the same day as the annual report. |
How Sustano helps
Sustano is ESG reporting software built around the evidence file described above.
- Collection from every plant, with evidence on every figure, and each person seeing only what they are responsible for. Data collection
- All nine attributes, calculated from your data, with each figure traceable to its emission factor and its source entries. Carbon accounting
- Two-person approval and locked periods, so every figure shows who entered, reviewed and locked it. Approvals and audit trail
- Automatic checks and the evidence pack. Problems are flagged before you report, and the pack brings together each attribute's evidence file. BRSR reporting
- A trail your assessor can verify independently, without relying on Sustano. Audit trail