Harun Raaj & AssociatesHarun Raaj & Associates
Audit & Assurance

BRSR Assurance

BRSR Assurance

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SCOPEConfirmed in writing

Regulatory Framework

BRSR Core assurance is governed by SEBI's phased mandate under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, originally introduced by circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023 and subsequently eased by a further circular dated 28 March 2025 ("Measures to facilitate ease of doing business with respect to framework for assurance or assessment..."). The applicability glide path, based on market capitalisation ranking among listed entities required to report BRSR, is: top 150 listed entities from FY 2023-24, top 250 from FY 2024-25, top 500 from FY 2025-26, and top 1,000 from FY 2026-27 — each subsequent year folding in the next band without dropping entities already covered.

The March 2025 amendment gave covered entities a choice between "assurance" and "assessment" for BRSR Core and value-chain ESG disclosures: where the assurance route is chosen, it must be reasonable assurance (the higher of the two IFAC-recognised levels, requiring the provider to gather sufficient evidence to issue a positive opinion) rather than limited assurance; where the assessment route is chosen instead, it follows criteria to be issued by the Industry Standards Forum (ISF) in consultation with SEBI. Value-chain BRSR disclosures (for upstream/downstream partners each representing 2% or more of the listed entity's purchases/sales by value) remain voluntary for FY 2025-26 reporting of FY 2024-25 data under the same March 2025 relaxation. Given the still-evolving ISF assessment criteria and the fact that this is a market-cap-linked (not universal) mandate, applicability for any specific listed entity should be confirmed against its current market-capitalisation ranking at the relevant financial year-end before scoping.

Overview

BRSR — the Business Responsibility and Sustainability Report — is the sustainability disclosure framework that SEBI made mandatory for the top 1000 listed entities by market capitalisation under Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015, from FY 2022-23 onwards. The BRSR Core — a subset of key performance indicators — carries an assurance requirement: SEBI phased in independent assurance of the BRSR Core for the top listed entities (VERIFY: the phased applicability timeline and entity thresholds in the SEBI circular of 14 July 2023 on BRSR Core assurance). Assurance is a chartered-accountant-led engagement, conducted under the assurance framework of the ICAI.

The BRSR has moved sustainability reporting in India from narrative to numbers. The report covers governance, environmental performance — energy, emissions, water, waste — and social performance — workforce, communities, value chain. The BRSR Core reduces the framework to a defined set of KPIs with a prescribed assurance scope, so that the numbers reported are actually verified. For the companies within its ambit, this is now a listed-entity compliance, not a voluntary ESG exercise.

The risk of treating BRSR as a fill-in-the-blank document is that assurance finds the gaps. Assurers test the reported KPIs against the underlying data — if the energy data, the workforce data or the value chain data does not support the reported figure, the assurance conclusion reflects it, and that conclusion goes into the annual report and to the exchanges. A qualified or adverse assurance finding on a mandatory ESG disclosure is a governance event for a listed company.

This service is for listed companies within the BRSR and BRSR Core ambit, and their value chain partners who must supply data. We map the disclosure requirements under Regulation 34(2)(f) of the LODR Regulations, build the data capture from the company's systems, draft the BRSR and the BRSR Core disclosures, and provide the independent assurance engagement to the prescribed standard.

How It Works

  1. 1

    Applicability & Scope Mapping

    We confirm your BRSR and BRSR Core obligations under Regulation 34(2)(f) of the SEBI LODR Regulations 2015.

    Harun Raaj & Associates does this3-5 days
  2. 2

    KPI Data Capture Design

    We design the data capture for the BRSR Core KPIs — energy, emissions, workforce and value chain.

    Harun Raaj & Associates does this1-2 weeks
  3. 3

    Disclosure Drafting

    We draft the BRSR disclosures from verified data in the SEBI-prescribed format.

    Harun Raaj & Associates does this2-4 weeks
  4. 4

    Assurance Engagement

    We perform the independent assurance of the BRSR Core to the applicable assurance framework.

    Harun Raaj & Associates does this2-4 weeks
  5. 5

    Assurance Report & Filing

    We issue the assurance conclusion and support the filing with the exchanges and in the annual report.

    Harun Raaj & Associates does this1 week

Frequently Asked Questions

Which listed companies must get BRSR Core indicators assured, and from which financial year?
SEBI circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated July 12, 2023 mandates assurance on BRSR Core KPIs for the top 150 listed entities by market cap from FY 2023-24, the top 250 from FY 2024-25, and the top 500 from FY 2025-26. The requirement flows from Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR), which requires the BRSR to form part of the Annual Report.
What is the difference between reasonable and limited assurance for BRSR Core?
Reasonable assurance requires the practitioner to issue a positive-form conclusion that BRSR Core indicators are free from material misstatement and involves more extensive evidence-gathering; limited assurance results in a negative-form conclusion (nothing came to our attention) with lighter procedures. SEBI has phased in reasonable assurance for higher market-cap cohorts from FY 2024-25 per the July 2023 circular. Both engagement types are conducted under ISAE 3000 (Revised) as adapted by ICAI in its Technical Guide on Sustainability Assurance Engagements (2023).
Who is eligible to sign a BRSR Core assurance report?
The assurance must be performed by a Chartered Accountant holding a valid Certificate of Practice, as SEBI has not yet recognised non-CA sustainability assurers for listed-entity BRSR. The engagement partner must demonstrate competence in sustainability reporting and maintain independence under the ICAI Code of Ethics 2020. ICAI guidance recommends applying ISAE 3000 (Revised) and documenting specific capability — generalist audit experience alone is insufficient.
Which BRSR Core KPIs are assured and what source evidence is typically required?
BRSR Core KPIs include Scope 1 and Scope 2 GHG emissions (reported in tCO2e using IPCC AR6 GWP values), energy intensity (GJ per rupee of turnover), water withdrawal by source (kilolitres), waste generated by type, and number of value-chain partners assessed on ESG criteria. Evidence examined includes utility bills, fuel purchase records, emission-factor workings, board-approved measurement methodologies, and ERP data. All KPIs are disclosed under Section C (Principle-wise Performance) of the BRSR format appended to the SEBI LODR circular.
What is the typical timeline and process for a BRSR Core assurance engagement?
The engagement runs in three phases: planning (materiality assessment, risk identification per KPI, engagement letter), fieldwork (document review, walkthroughs with sustainability and operations teams, data testing against source records, site visits for material KPIs), and reporting (issuance of the assurance report for inclusion in the Annual Report filed under Regulation 34(2) of SEBI LODR). For a mid-size top-500 company, the process typically takes 4-6 weeks from data readiness to signed report. Early engagement — ideally in Q4 of the financial year — avoids compressed timelines before the Annual Report deadline.

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