BRSR Reporting: What Mid-Market Manufacturers Need to Know

TL;DR Summary: BRSR reporting is a SEBI rule that applies to the top 1,000 listed companies in India by market value. It is not mandatory for private manufacturers. But your listed customers may still ask for your ESG data. The report covers nine principles: ethics, product safety, employee welfare, stakeholders, human rights, environment, public policy, inclusive growth and consumer care. BRSR Core is a smaller set of 9 ESG attributes that need reasonable assurance. It is rolling out to more companies each year. Emissions, water and waste data are the hardest for manufacturers to collect, since most plants don’t track them today. A simple internal process, built early, saves you from a last-minute scramble each year.

BRSR reporting is India’s mandatory ESG (Environmental, Social and Governance) disclosure framework introduced by SEBI for the top 1,000 listed companies. 

It replaces the older Business Responsibility Report with quantifiable, principle-based metrics aligned with the National Guidelines on Responsible Business Conduct.

This blog explains BRSR applicability, its core principles, the differences between BRSR Core and full BRSR and the practical steps manufacturers can take to build an internal ESG process and overcome data collection challenges.

What is BRSR and Who is Mandated to File It

BRSR or Business Responsibility and Sustainability Reporting is SEBI’s structured ESG disclosure framework under Regulation 34(2)(f) of the SEBI Listing Obligations and Disclosure Requirements (LODR) Regulations, 2015.

It requires listed companies to disclose their performance across environmental, social and governance dimensions structured around the nine NGRBC principles.

Applicability

BRSR is mandatorily applicable to the top 1,000 listed entities by market capitalization and this coverage includes both companies and financial institutions such as banks, NBFCs and insurance firms. 

SEBI determines the applicable list each year based on market capitalization rankings published by stock exchanges as of March 31, so a company’s inclusion can shift from one financial year to the next depending on its valuation. 

The requirement came into effect from FY 2022-23. Smaller listed entities may adopt BRSR voluntarily to enhance investor confidence and prepare for future compliance.

 Companies nearing the threshold should monitor their market position, as entering the top 1,000 triggers reporting obligations from the next reporting cycle.

BRSR Core and Assurance Timeline

SEBI introduced BRSR Core in July 2023 as a focused set of key ESG performance indicators across nine attributes. It streamlines the broader BRSR framework into quantifiable and comparable metrics to enable consistent benchmarking by regulators and investors.

BRSR Core requires independent third-party reasonable assurance on a phased basis, allowing companies time to establish the systems and controls needed for assurance-ready reporting.

Financial Year	Listed Entities Covered (by market capitalisation)
FY 2023-24	Top 150
FY 2024-25	Top 250
FY 2025-26	Top 500
FY 2026-27	Top 1,000

The phased rollout means all entities covered under mandatory BRSR will eventually need assurance-ready data. Companies should strengthen ESG data collection processes early rather than waiting for their applicable reporting year.

Value Chain Disclosure Expansion

From FY 2025-26, the top 250 listed entities must disclose ESG information for value chain partners, extending BRSR beyond their own operations. 

This applies to upstream and downstream partners contributing individually to 2% or more of purchases or sales, with coverage extending to 75% of total purchases and sales.

Companies will need to establish data-sharing mechanisms and reporting formats with suppliers and customers to collect relevant ESG information. Value chain assessment or assurance requirements begin from FY 2026-27 on a comply-or-explain basis, providing limited time to formalize these processes.

Early engagement with value chain partners is essential, as external ESG data collection usually takes longer to develop than internal reporting systems.

Why Mid-Market Manufacturers Are Being Asked for BRSR Data Anyway

You may not be a listed company, you may never have filed a BRSR in your life, but your largest customer probably has. That customer must now report ESG data from its suppliers and you are one of them.

The Value Chain Effect

BRSR Core now extends reporting obligations into the value chain. Large listed companies must collect ESG information from upstream and downstream partners representing at least 75% of their purchases and sales. 

Your customer needs data on your emissions, water use, waste generation and labour practices to complete their own BRSR filing.

This shifts the compliance burden downstream: a listed company’s BRSR score now depends partly on how well its suppliers can produce credible ESG numbers. 

If you supply a top-250 listed entity, expect the first data request within the next reporting cycle, if it hasn’t arrived already.

The MSME Reality

India’s MSMEs contribute close to 30% of GDP, employ more than 110 million people and account for around 45% of exports, making them the operational backbone of nearly every large manufacturer’s supply chain.

Most are not required to file BRSR. Yet they form the backbone of corporate supply chains. A large manufacturer’s supply base can run to thousands of vendors, and only a handful are listed companies.

Building this capability early gives MSMEs a real advantage over competitors who wait until a customer’s deadline forces the issue. PKC Management Consulting works with several such suppliers on exactly this gap.

What Customers Are Asking For

Customers request data on energy consumption, water withdrawal, waste generation, greenhouse gas emissions, workforce composition and health and safety indicators and the scope of these requests keeps expanding as SEBI’s Core framework matures. 

Some ask for emissions data broken down by Scope 1, 2, and 3. Others want pollution control licence status and EPR compliance evidence.

Suppliers should expect structured questionnaires or vendor portals, often with tight deadlines. Tracking these metrics internally ahead of time makes responses faster and less disruptive.

If you cannot provide this data, you risk being replaced by a supplier who can. Large companies are increasingly using ESG performance as a procurement filter. 

Your ability to respond to data requests directly affects your position in the supply chain.

The Nine BRSR Principles at a Glance

BRSR is built on the National Guidelines on Responsible Business Conduct (NGRBC), issued by the Ministry of Corporate Affairs (MCA).

These guidelines set out nine principles that every disclosure in the BRSR format maps back to. You don’t need to memorise the SEBI form to understand BRSR.

You need to understand these nine principles, since they define what “responsible business conduct” means in the Indian context.

Principle	What it covers
P1: Ethics, transparency and accountability	Governance, anti-corruption and honest conduct across operations
P2: Sustainable and safe products	Product lifecycle impact, from design to disposal
P3: Employee well-being	Wages, safety, benefits and welfare, including value chain workers
P4: Stakeholder responsiveness	Engagement with shareholders, communities and other stakeholders
P5: Human rights	Respecting and promoting human rights across the business and supply chain
P6: Environment	Protecting and restoring the environment, including emissions, water and waste
P7: Public policy advocacy	Responsible and transparent engagement with regulators and policymakers
P8: Inclusive growth	Equitable development, including for local and marginalised communities
P9: Consumer value	Fair engagement with and value delivery to customers

Principle 1: Ethical, Transparent and Accountable Conduct

Businesses must operate with integrity, making ethics the foundation of all BRSR disclosures. 

This principle requires companies to publish anti-corruption and anti-bribery policies, grievance mechanisms, and conflict-of-interest protocols, and crucially, to disclose how these apply to directors and all employees.

 Companies must report complaints received and disciplinary actions taken, giving investors concrete proof of enforcement, not just policy statements. For suppliers, this means: customer requests for your own code of conduct as supporting documentation.

Principle 2: Safe and Sustainable Goods and Services

Responsibility extends across the full product lifecycle, from raw material sourcing to end-of-life disposal.

You need to disclose the percentage of recycled input materials, product safety certifications, and Extended Producer Responsibility (EPR) compliance. This is particularly relevant for packaging, electronics, and plastics manufacturers. 

Companies must also disclose life-cycle assessments for select products and risk mitigation measures for unsafe goods. Suppliers handling recycled content, EPR-regulated packaging, or safety-certified components may need detailed documentation requests tied directly to this principle.

Principle 3: Employee Wellbeing

Labour welfare is treated as a measurable governance outcome. This data-intensive principle requires disclosure of health and accident insurance, maternity/paternity benefits, safety measures, training hours, and wages relative to minimum wage. 

Companies must report work-related injuries and fatalities not only for direct employees but also for contract workers, extending accountability beyond the company’s own payroll. 

For manufacturers with large contract workforces, this is often the most demanding principle, and customers frequently request this labour data as part of value-chain assessments.

Principle 4: Stakeholder Responsiveness

Obligations extend beyond shareholders to employees, communities, regulators, and supply chain partners. This principle requires companies to document formal stakeholder engagement processes and grievance mechanisms:

• how groups are identified
• what channels exist for raising concerns
• how frequently engagement occurs. 

Companies must also disclose whether stakeholder consultation actually influenced economic, environmental, or social decisions during the reporting period. 

Principle 5: Respect For Human Rights

Businesses should promote respect for and awareness of human rights in their business operations and this principle applies not only to a company’s own workforce but to its entire value chain. 

BRSR disclosures cover policies, due diligence, training, complaints, remediation, and measures to prevent forced labour, child labour and discrimination. 

Manufacturers with contract labour or complex supplier networks should be prepared to provide evidence on wages, working hours, and freedom of association practices.

Principle 6: Environmental Protection and Restoration

This principle covers greenhouse gas emissions, energy consumption, water usage, waste management, and circularity practices. 

Companies must report absolute figures alongside intensity ratios for year-on-year and peer comparison. A new leadership indicator now requires disclosure of green credits generated or procured by the company and its value-chain partners. 

This is where customer data requests concentrate most heavily, since a listed company’s Scope 3 emissions depend entirely on supplier-provided data. Manufacturers should prioritize tracking energy and water consumption first since these are the earliest and most frequently requested data points. If you’re building this into your existing risk process, our guide on internal audit risk assessment covers how to fold ESG risks like emissions and climate exposure into a standard risk assessment framework.

Principle 7: Responsible Public Policy Advocacy

Companies involved in public or legislative policy discussions must operate transparently. This includes disclosing memberships in trade associations and industry bodies, public policy positions they support, and whether these positions align with their sustainability commitments. 

Companies must also report any corrective actions taken for anti-competitive behaviour. 

While this principle mainly applies to large listed companies, mid-sized manufacturers are less often asked to report on advocacy activities, as supply-chain assessments usually focus more on operational performance.

Principle 8: Inclusive Growth

This principle focuses on how businesses create social value beyond their direct operations. 

Key areas include job creation in smaller towns and rural areas, CSR contributions, and sourcing from small producers, local businesses, women-owned enterprises, and marginalised communities. 

Companies must also disclose social impact assessments for projects that significantly affect communities.

For manufacturers operating in smaller towns or rural areas, this can be an advantage, as companies looking for inclusive sourcing partners may prefer vendors that support local employment and small-business participation.

Principle 9: Customer Value and Fairness

This principle focuses on ensuring products deliver value while protecting customer interests. Companies must report on customer satisfaction, product safety issues, data privacy practices, cybersecurity incidents, and complaint-handling processes. 

They must also disclose the availability of safe-use information for products and any regulatory actions related to unfair trade practices. 

For component manufacturers, this applies mainly through customer requirements for product safety, quality assurance, and documentation that helps ensure the final product is safe for end users.

TIP: Starting point for manufacturers

If you’re preparing ESG data for the first time, focus on Principles 3 and 6, since they carry the heaviest data requirements and are where customers requesting value-chain information concentrate their questions most frequently.

Data Points Manufacturers Struggle to Collect (Emissions, Water, Waste)

For most manufacturers, the hardest part of BRSR is collecting the actual data, since the numbers a customer or regulator asks for rarely exist in one place, in one format, ready to be dropped into a report.

Greenhouse Gas Emissions

Emissions data is the most challenging metric for manufacturers. Scope 1 emissions from direct operations require fuel consumption records. 

Scope 2 emissions from purchased electricity need the latest CEA-published grid emission factor for India. Scope 3 emissions from the supply chain require data from suppliers, which is often unavailable .

Manufacturers without direct measurement capabilities can use a spend-based approach to estimate emissions based on annual spending data, but this is only an initial measure. 

If primary data is unavailable, use the spend-based method. Do not continue using it once measurable data becomes available

Water Consumption

Water data requires tracking withdrawal, consumption and discharge across facilities, and manufacturers with multiple plants often find that each site records this information differently, if at all. 

The Central Ground Water Authority guidelines provide a framework for estimation, covering groundwater abstraction limits, permissible extraction rates, and reporting formats that facilities can align their internal logs against. 

Manufacturing units abstracting more than 100 cubic metres per day must conduct water audits . Overseas locations must use country-specific consumption rates

Waste Management

Manufacturers must report waste generation by type and disposal method. 

This includes hazardous waste, e-waste, plastic waste and solid waste, each governed by separate regulatory regimes with their own documentation and disposal requirements. 

EPR compliance data is required for products covered under EPR regulations . The challenge lies in tracking waste at multiple locations and maintaining disposal records

Practical Solutions

1. Start with pilot facilities to test data collection processes before rolling changes out across every plant, since working out formats and responsibilities at one site first avoids repeating the same mistakes company-wide. 
2. Install sub-meters for energy and water at major consumption points, giving finance and sustainability teams granular, verifiable figures instead of relying on aggregate utility bills that blur consumption across departments. 
3. Train procurement teams to capture supplier information at invoice booking, since this is the point where spend data, vendor details and material quantities are already being recorded, making it the cheapest place to start building a supplier ESG database. 
4. Reconcile environmental data with financial records quarterly rather than waiting for year-end, catching gaps and inconsistencies early instead of discovering them under deadline pressure during annual report preparation.
5. Assign a single owner for environmental data consolidation, since scattered ownership across plants is usually what causes reporting delays.

The data usually exists across meters, invoices, registers, and operational records, but is scattered across teams and formats. The challenge is data governance, not sustainability, and it can be solved with the right processes.

BRSR Core vs. Full BRSR: What’s the Difference

Full BRSR and BRSR Core are not separate alternatives. BRSR Core is a subset of the full BRSR, specifically identified for assurance purposes.

Full BRSR

Full BRSR includes around 140 reporting questions across essential and leadership indicators. Essential indicators are mandatory, while leadership indicators provide a pathway for companies to demonstrate more advanced transparency. 

It covers all nine NGRBC principles with both quantitative and narrative disclosures, meaning a company must report hard numbers like emissions and wages alongside qualitative descriptions of policies, governance structures and stakeholder engagement processes. 

Full BRSR is the complete annual disclosure document that every mandated listed entity files as part of its annual report, regardless of whether it falls within the BRSR Core assurance timeline for that financial year. 

Preparing the report requires inputs from functions including HR, EHS, procurement and finance.

BRSR Core

BRSR Core is a set of key ESG indicators covering nine ESG attributes. It simplifies the larger BRSR framework into a standardised dataset that enables consistent comparison across companies and reporting years.

These are the metrics an independent assurance provider can test, sample and verify with reasonable assurance, which is why SEBI limited the Core framework to indicators that are objectively measurable rather than narrative or policy-based.

Attribute	Key Performance Indicator
Greenhouse gas footprint	Scope 1 and 2 emissions intensity
Water footprint	Water consumption intensity
Energy footprint	Energy consumption intensity
Circularity	Waste intensity
Employee wellbeing	Workplace safety complaints
Gender diversity	Total wages paid to women
Inclusive development	Jobs created in small towns
Fairness	Customer complaints
Openness of business	Total value distribution

Companies preparing for their first assurance cycle should treat this table as a checklist, since each row maps to specific data points that must be audit-ready before the assurance provider arrives. 

At PKC Management Consulting, we recommend building internal controls around these nine attributes well ahead of the applicable financial year.

Key Differences

Assurance Requirement

Full BRSR does not require assurance, while BRSR Core requires reasonable assurance on a phased basis, expanding to more listed entities each year until FY 2026-27.

Scope and Coverage

Full BRSR covers all nine principles, including policies, governance details, and qualitative disclosures, while BRSR Core focuses only on measurable ESG indicators.

Data Focus

BRSR Core includes quantitative, assurance-ready KPIs designed for independent verification, removing the broader narrative elements of Full BRSR.

Reporting Format

Full BRSR is included in the annual report, with BRSR Core forming part of the same report rather than being filed separately.

Standardization Framework

The Industry Standards Forum, led by ASSOCHAM, FICCI, and CII, has developed guidelines to improve consistency and comparability in BRSR Core reporting.

Intensity Calculations

BRSR Core requires intensity ratios based on PPP-adjusted revenue and output-based measures for manufacturing, enabling comparison across companies of different sizes.

Building an Internal Process to Collect ESG Data Year-Round

ESG data collection is not a year-end task. Like financial reporting, it requires continuous processes to capture, verify, and maintain accurate data throughout the year.

Here’s a step by step process you can use: 

Step 1: Map Your Data Sources

Before designing any ESG data process, identify where each data point currently exists. This avoids gaps and ensures the process is built around available information.

For example:

• Emissions data may sit with plant teams in fuel logs or spreadsheets.
• Water data may be tracked by maintenance teams through meter records.
• Workforce data may be spread across HR systems, payroll, attendance, and welfare records.

Start by mapping the source of each data point across all nine BRSR Core attributes, including the responsible department, system, or person holding the information.

Step 2: Assign Ownership

Appoint a sustainability lead to coordinate BRSR reporting and ensure timely data collection across departments.

Assign specific data owners:

• Procurement: Supplier data and value chain disclosures.
• Operations: Emissions, energy, water, and waste data.
• HR: Workforce, wages, safety, and diversity data.

Clear ownership ensures accountability and prevents last-minute data gaps.

Step 3: Build Your Supplier Engagement Plan

BRSR requirements often extend through the supply chain, making supplier data collection essential.

• Identify suppliers covering 75% of procurement value and prioritise engagement with them.
• Send data requests early and provide clear templates to improve response quality.
• Support smaller suppliers with guidance and training, as many MSMEs may be new to ESG reporting.

Step 4: Establish Verification Processes

Reasonable assurance requires traceable, repeatable records, meaning every number in your BRSR disclosure needs supporting documentation an assurance provider can independently trace back to its source. 

• Maintain records showing the source, owner, and calculation method for each data point.
• Verify information using supporting documents such as invoices, utility bills, and financial records.
• Avoid relying only on supplier declarations; ensure data can withstand assurance review.

Step 5: Use Technology Strategically

Spreadsheets do not scale once a company is tracking dozens of KPIs across multiple plants, departments and reporting years, since version control and manual consolidation become error-prone at that volume. 

• Use ESG reporting tools that connect with existing ERP and operational systems.
• Automate data collection for frequently tracked metrics like energy, water, and waste.
• Choose systems that support both estimated and primary data during the transition to stronger data practices.

Common Mistakes to Avoid

• Late Gap Detection: Don’t wait for auditors to identify data gaps. A missing KPI discovered during assurance leaves no time to fix it before the filing deadline.
• Passive Supplier Requests: Don’t assume suppliers will provide data without asking directly and repeatedly. Most suppliers have no independent incentive to prepare ESG figures unless a customer specifically requests them with a clear deadline.
• Spreadsheet Overreliance: Don’t rely solely on manual spreadsheets for 40+ KPIs spread across multiple plants and departments. The coordination overhead alone becomes unmanageable as the reporting scope grows.
• Siloed Reporting: Don’t treat BRSR as a separate exercise from financial reporting. Environmental and social data reconciles most cleanly when tracked alongside the same quarterly financial cycles a company already follows, rather than as an isolated annual scramble.

PKC’s BRSR & ESG Reporting Advisory

PKC Management Consulting’s team of 100+ professionals provides comprehensive BRSR and ESG reporting advisory for businesses struggling with India’s evolving sustainability disclosure landscape. This work sits within PKC’s broader Governance, Risk & Compliance services, which help businesses build the internal controls and reporting frameworks that credible BRSR disclosure ultimately depends on.

Our Approach

• Applicability & Scoping: We identify exactly which BRSR principles and clauses apply to your business. Many companies over-report or under-report simply because they misread their obligations. We eliminate that guesswork.
• Data Gap Analysis: PKC maps your existing data sources against regulatory requirements and fix gaps before they become compliance failures. Most companies already hold the data they need, they just don’t know where to find it or how to structure it.
• Process Integration: We build internal workflows that connect seamlessly with your financial and operational systems, making data collection, verification, and reporting routine, not disruptive. No more frantic year-end data hunts.
• Sector-Specific Support: For manufacturers, we specialise in emissions measurement, water accounting, waste tracking, and gathering supply-chain data. These are precisely where most gaps hide and where customer data requests concentrate most heavily.
• Assurance Readiness: We conduct mock assurance reviews so you walk into your actual audit fully prepared. We test your documentation, verify your calculations, and stress-test your processes exactly as an auditor would.

Begin at least 12 months before your first assurance deadline. That gives you sufficient lead time to onboard suppliers, build internal workflows, and resolve data gaps before the auditor arrives. 

Companies that start earlier spend less on last-minute fixes and enter the audit process with confidence.

FAQs

Is BRSR mandatory for private, unlisted manufacturing companies? 

No. BRSR under SEBI applies only to listed companies, specifically the top 1,000 by market capitalization. Private and unlisted manufacturers have no direct filing obligation. However, many still need to share ESG data with listed customers who report on their value chains, so the practical pressure to track this data exists even without a legal mandate.

Why are manufacturers being asked for BRSR data by their customers?

Large listed companies, especially the top 250 by market cap, must report ESG data for their value chain, including significant suppliers, from FY 2024-25. If you supply one of these companies, they need your emissions, water, and waste figures to complete their own BRSR Core disclosures, so the request reaches you even though you’re not required to file.

What is the difference between BRSR Core and full BRSR? 

Full BRSR covers 140 indicators across nine principles, with no mandatory third-party check. BRSR Core is a smaller set of 9 ESG attributes covering emissions, water, waste, energy, and social metrics, and it requires reasonable assurance from an independent provider. BRSR Core assurance is rolling out in phases, reaching the top 1,000 companies by FY 2026-27.

What data is hardest for manufacturers to collect for BRSR? 

Emissions, water, and waste data cause the most trouble. Most factories have electricity bills and fuel invoices but haven’t converted them into CO2 equivalents. Water is often metered at a single inlet point with no breakdown by process. Non-hazardous waste, scrap and packaging, is rarely tracked since it’s usually sold off informally.

Does BRSR reporting require a third-party audit? 

Full BRSR indicators don’t require assurance. BRSR Core attributes do, at a “reasonable assurance” standard, which is stricter than the “limited assurance” used in many other countries. This assurance requirement is being phased in, moving from the top 150 listed companies in FY 2023-24 to the top 1,000 by FY 2026-27.

How should a manufacturer start building an ESG data process? 

Start by listing every ESG metric you’re likely to be asked for and identifying where that raw data already sits, a meter, invoice, or register. Assign an owner for each data category, collect it monthly rather than annually and keep it in one central register. This turns ESG reporting into routine data hygiene instead of a yearly scramble.