Policy Briefing — SEBI BRSR Reporting Mandate
SEBI mandated Business Responsibility and Sustainability Reporting for the top 1,000 listed entities on May 10, 2021, replacing the Business Responsibility Report with a richer ESG governance framework from FY 2022-23.
Executive briefing: On 10 May 2021 the Securities and Exchange Board of India issued a circular requiring the top 1,000 listed entities by market capitalisation to file Business Responsibility and Sustainability Reports (BRSR) from FY 2022-23. The new format aligns with the National Guidelines on Responsible Business Conduct and demands granular board oversight, policy, and performance disclosures across environmental, social, and governance pillars.
Key requirements
- BRSR Core and comprehensive sections. Entities must disclose governance structures, policy commitments, management processes, and quantitative performance indicators across nine principles of responsible business conduct.
- Value-chain reporting. Companies must explain how they extend responsible business conduct to suppliers and distributors, including grievance mechanisms and board oversight.
- Transition timeline. FY 2021-22 filings could adopt BRSR voluntarily, while FY 2022-23 filings made it mandatory for the top 1,000 listed entities.
Implications for boards
- Indian issuers. Boards need to assign responsibility for each BRSR principle, ensuring audit committee oversight of ESG controls and assurance pathways.
- Global investors. Asset managers should update stewardship checklists to capture BRSR governance metrics and incorporate them into engagement with Indian portfolio companies.
- Public sector undertakings. State-owned enterprises must coordinate across ministries to gather social impact and supply chain data required for board-level disclosures.
Action checklist
- Map BRSR indicators to existing sustainability and statutory filings, identifying control owners and evidence repositories.
- Integrate BRSR governance responses into risk and audit committee agendas, including escalation pathways for policy breaches.
- Develop supplier engagement programmes to capture grievance redressal, due diligence, and capacity-building metrics.
Sources
- Business Responsibility and Sustainability Reporting by listed entities
- SEBI board meeting decisions – May 2021
Zeph Tech equips Indian issuers with BRSR governance templates, control mappings, and investor reporting packs to meet SEBI’s mandatory ESG disclosure regime.