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What Does ESG in India Involve, and Why Does BRSR Compliance Still Run on Spreadsheets?

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By Ram Nethaji

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ESG in India

This financial year, SEBI’s BRSR Core assurance requirement finally reaches all of India’s top 1,000 listed companies, not only the largest 500. Many sustainability teams still gather the underlying data through Excel sheets, email threads, and WhatsApp messages sent department by department. That gap between a demanding new assurance standard and an informal data-collection process is where ESG in India compliance most often breaks down.

What Does ESG in India Actually Involve?

In practice, ESG in India runs through two separate legal requirements rather than one voluntary standard. The Securities and Exchange Board of India requires large listed companies to file the Business Responsibility and Sustainability Report (BRSR), while the Companies Act separately requires many companies, listed or not, to spend on corporate social responsibility programs.

These two requirements measure different things. BRSR asks for detailed environmental, social, and governance data across a company’s own operations, while the CSR mandate is narrower and governs only a fixed share of profit directed toward social programs.

A company can be subject to one requirement, both, or neither, depending on its size and whether it is listed. A large unlisted manufacturer might owe CSR spending under the Companies Act without ever filing a BRSR, while a mid-size listed company just below the top 1,000 threshold might file BRSR voluntarily to satisfy investors even though the law does not yet require it.

For a CTO or finance leader, the practical question is rarely which law applies in theory. It is whether the company’s existing systems, enterprise resource planning (ERP), HR, payroll, and vendor records, among them, can actually produce the specific figures either requirement asks for, on a schedule that matches the filing calendar rather than a best-effort basis. Many finance leads start by bringing in sustainability consulting support to map that gap before deciding where to invest first.

Why Is BRSR Mandatory for Indian Companies?

The Securities and Exchange Board of India introduced BRSR in 2021, replacing an earlier Business Responsibility Report that had applied to a smaller group of companies since 2012. BRSR is the single biggest driver of ESG in India today, and full disclosure became mandatory for the top 1,000 listed companies by market capitalization starting the 2022-23 financial year.

  • BRSR replaced the earlier Business Responsibility Report starting in 2021
  • The mandate applies to the top 1,000 listed companies by market capitalization
  • Full disclosure became mandatory from the 2022-23 financial year
  • BRSR Core, introduced in 2023, adds nine mandatory ESG attributes with phased assurance
  • Companies outside the top 1,000 can adopt BRSR voluntarily

That assurance requirement is what changed this year: BRSR Core now reaches all top 1,000 listed companies, not only the largest few hundred. For companies newly in scope, that means an external auditor or assessor will now trace disclosed figures back to source documents in the same way financial statements are already checked, which is a materially higher bar than simply filling in a disclosure template once a year.

How Is BRSR Different From Global ESG Frameworks Like GRI?

Companies that also report to international investors often need to reconcile BRSR with a broader global framework such as GRI. The two exist for different reasons, and knowing which one governs which audience keeps a reporting team from duplicating the same work twice.

BRSR is built specifically for SEBI’s disclosure requirements and the nine principles of India’s National Guidelines on Responsible Business Conduct. GRI, by contrast, was designed for cross-border comparability and is often what an international investor or parent company expects to see, even when it plays no role in an Indian company’s own regulatory filings.

A company with only domestic listing obligations can usually treat BRSR as the complete requirement. One with foreign parent reporting or international investors on its cap table often ends up preparing both, which is exactly the situation where a shared underlying data system saves the most duplicated effort.

FrameworkApplicable ToMandatory or Voluntary
BRR (SEBI, 2012)Top 100 listed companies (original scope)Superseded by BRSR in 2021
BRSR (SEBI, 2021)Top 1,000 listed companies by market capitalizationMandatory from FY 2022-23
BRSR Core (SEBI, 2023)Phased by market-cap rank, reaching all top 1,000 by FY 2026-27Mandatory assessment or assurance
GRI (independent global standard-setter)Companies reporting to international investorsVoluntary in India

Why Do Indian Companies Still Collect BRSR Data Through Spreadsheets and WhatsApp?

Many sustainability teams gather BRSR data the same way they gather any internal report: through email requests, shared spreadsheets, and informal messages sent to department heads. That approach works when only a handful of numbers are needed, but BRSR asks for data across environmental, social, and governance categories from departments that rarely share a common system.

  • Emissions and energy data often sit with facilities or operations teams, not finance
  • Workforce and wage figures come from HR systems that were never built for ESG disclosure
  • Supply chain data depends on vendors who may not track the same metrics consistently
  • Manual consolidation before every filing raises the risk of inconsistent or outdated figures
  • Reporting timelines stretch to weeks because each department is asked separately

None of these problems are about whether a company takes sustainability seriously. They are about whether its existing systems were ever built to produce this specific kind of report, and most were built for financial data, not for tracking emissions or supplier wage data across dozens of sites.

What Should an ESG Compliance System Look Like for an Indian Company?

Building that kind of system is a data engineering problem before it is a filing problem. A working BRSR compliance system pulls data from the departments that actually hold it, rather than asking each one to fill out a form by hand every quarter, and maps that data to BRSR’s essential and core indicators well before the filing window opens.

That mapping matters more this year than in past cycles. Once a company’s disclosures move under assessment or assurance, an external reviewer expects to trace each figure back to its source, not just see a finished number on a page.

ESG in India

The most useful systems also keep a record of where each figure came from, which matters once a company’s BRSR Core disclosures move from assessment to full assurance.

How Can Businesses Build ESG Compliance Systems That Meet SEBI’s Requirements?

Meeting SEBI’s BRSR requirements is ultimately a data problem before it becomes a compliance one, and it is the part of ESG in India that determines whether a filing goes smoothly. Zethic designs custom software that connects the departments holding BRSR data into a single, audit-ready system, replacing the spreadsheet-and-WhatsApp starting point with a repeatable process built around SEBI’s own indicators. Businesses preparing for their next filing cycle can start that conversation early.

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Frequently Asked Questions

ESG is the global framework covering environmental, social, and governance factors, while BRSR is SEBI’s specific mandatory disclosure format that asks Indian listed companies to report ESG data in a standardized way.

BRSR is mandatory for the top 1,000 listed companies in India by market capitalization, though smaller listed companies can adopt it voluntarily.

BRSR Core is a subset of nine mandatory Key Performance Indicators within the full BRSR framework, introduced with a phased requirement for third-party assessment or assurance starting with the largest filers.

Unlisted companies are not directly required to file BRSR, though many face indirect pressure through customer, investor, or lending relationships with companies that do file, and voluntary adoption can ease future compliance as thresholds expand.

BRSR and the CSR mandate are separate requirements. BRSR covers broad ESG disclosure, while the CSR mandate specifically requires qualifying companies to spend a fixed share of profit on social programs and report that spending.

BRSR is filed annually alongside a company’s other annual report disclosures to the stock exchanges.

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Ram Nethaji
Written by

Ram Nethaji

Founder

Ram brings deep expertise in product strategy and system architecture across fintech, SaaS, and AI platforms. He specializes in pre-execution planning to help teams build scalable technology foundations and avoid costly rebuilds.

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