BRSR Core assurance: what the phased SEBI mandate means for mid-caps

SEBI's Business Responsibility and Sustainability Report (BRSR) has been mandatory for the top 1,000 listed companies by market capitalisation for several years. The more consequential change is BRSR Core: a defined set of key performance indicators covering emissions, energy, water, waste, employee wellbeing, gender diversity, inclusive development, customer complaints and business openness, which must be independently assured. Assurance is being phased in by market-cap band, starting with the largest companies and extending to progressively smaller ones over successive financial years, as currently notified.

Why assurance changes the job

Writing a BRSR is a reporting exercise; getting it assured is an audit exercise. An assurance provider will ask where each number came from, who approved it, how it was calculated and whether the method was applied consistently across plants. Scope 1 and 2 emissions have to trace back to fuel invoices and electricity bills; water figures to meter readings or abstraction records; waste figures to manifests and recycler certificates. For a company that has so far compiled its ESG section from plant-level spreadsheets, that is a substantial step up.

What mid-caps in the next tranche should do this year

• Map each BRSR Core KPI to a data owner, a source document and a calculation method, and write that method down before the year's data is collected.
• Run a dry-run assurance on last year's figures to find the gaps while there is still time to fix the data collection, not just the report.
• Bring environmental compliance data (consents, Form V, hazardous waste returns, EPR filings) into the same system as the BRSR figures, because assurance providers cross-check them.
• Decide early whether you will seek reasonable or limited assurance where the rules give you a choice, since the evidence standard differs.
• Extend the exercise to the value chain disclosures that apply to your band, as these are being phased in alongside the core KPIs.

The companies that struggle with BRSR Core are rarely the ones with bad environmental performance. They are the ones whose good performance is not documented in a way an auditor can test.

There is also a practical upside. The same traceable data set that satisfies an assurance provider is what lenders, large customers and rating agencies now ask for, and it is the baseline for any credible net-zero or decarbonisation roadmap. We help listed and pre-IPO companies build the BRSR data architecture, prepare the report and support the assurance engagement so the first assured year is not a scramble.