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ESG Assurance & BRSR Reporting — Sustainability Audit & Business Responsibility Report

Assurance and advisory for ESG (Environmental, Social, Governance) reporting — BRSR Core assurance for top-1000 listed companies (mandatory from FY 2023-24), GRI/SASB/TCFD-aligned sustainability report preparation, Scope 1/2/3 GHG emissions quantification, supply chain ESG mapping, and ESG rating agency data preparation.

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STARTING FROM₹74,999
TYPICAL TIMELINE60 days
DOCS REQUIRED6 documents
APPLICABLE TOCompany

Regulatory Framework

SEBI Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated 10 May 2021 — introduction of BRSR replacing BRR; mandatory for top-1,000 listed companies from FY 2022-23. SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023 — BRSR Core (49 KPIs) subject to reasonable assurance: top-150 from FY 2023-24, top-250 from FY 2024-25. SEBI LODR Regulations 2015: Regulation 34(2)(f) — BRSR as part of Annual Report for listed companies. National Guidelines on Responsible Business Conduct (NGRBC), Ministry of Corporate Affairs, 2019 — nine principles. Companies Act, 2013: Section 135 — CSR obligation (net worth ≥₹500 crore, or turnover ≥₹1,000 crore, or net profit ≥₹5 crore — spend 2% of average net profit of preceding 3 years). ICAI Guidance Note on Reports or Certificates for Special Purposes — assurance engagements on non-financial information. ISAE 3000 (Revised) — International Standard on Assurance Engagements Other than Audits or Reviews of Historical Financial Information. GHG Protocol Corporate Accounting and Reporting Standard (WRI/WBCSD). IFRS S1/S2 (ISSB 2023) — under consideration by SEBI for India adoption.

Overview

Environmental, Social, and Governance (ESG) reporting has shifted from voluntary disclosure to mandatory assurance for India's largest listed companies. The Securities and Exchange Board of India (SEBI) has made BRSR (Business Responsibility and Sustainability Report) mandatory for the top-1000 listed companies by market capitalisation from FY 2022-23, with BRSR Core (reasonable assurance by a CA firm or SEBI-registered agency) mandatory from FY 2023-24.

BRSR — Business Responsibility and Sustainability Report:
SEBI Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated 10 May 2021 introduced BRSR as a replacement for BRR (Business Responsibility Report). BRSR covers nine principles of the National Guidelines on Responsible Business Conduct (NGRBC) issued by the Ministry of Corporate Affairs:

1. Principle 1 — Businesses should conduct themselves with integrity.
2. Principle 2 — Businesses should provide sustainable and safe goods and services.
3. Principle 3 — Businesses should respect and promote employee well-being.
4. Principle 4 — Businesses should respect the interests of all stakeholders.
5. Principle 5 — Businesses should respect and promote human rights.
6. Principle 6 — Businesses should respect and protect the environment.
7. Principle 7 — Businesses should engage with policy advocacy responsibly.
8. Principle 8 — Businesses should promote inclusive growth.
9. Principle 9 — Businesses should engage with customers responsibly.

BRSR Core — Mandatory Assurance (FY 2023-24 onwards):
SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023 introduced BRSR Core — a subset of 49 Key Performance Indicators (KPIs) from the BRSR that are subject to mandatory reasonable assurance from FY 2023-24 for the top-150 listed companies by market cap, and from FY 2024-25 for the top-250. BRSR Core KPIs cover: GHG emissions (Scope 1 and 2), energy intensity, water withdrawal/consumption, waste generation, employee well-being (gender pay gap, safety metrics), supply chain sustainability (% of value chain subjected to sustainability assessments).

GHG Emissions Quantification:
Scope 1 (direct emissions from owned/controlled sources), Scope 2 (indirect emissions from purchased electricity), and Scope 3 (all other indirect emissions — supply chain, business travel, employee commuting, product use and disposal) must be quantified per the GHG Protocol Corporate Standard (WBCSD/WRI). For BRSR Core, only Scope 1 and 2 are mandatory; Scope 3 is encouraged.

ESG Ratings and Agency Data:
Companies are increasingly rated by ESG agencies (MSCI ESG, Sustainalytics, ISS ESG, CRISIL ESG, ICRA ESG) on the basis of their disclosed data. CA firms can assist in preparing clean, auditable ESG data packs that improve rating outcomes.

International Frameworks:
GRI (Global Reporting Initiative) Standards — most widely used globally. SASB (Sustainability Accounting Standards Board) — sector-specific KPIs. TCFD (Task Force on Climate-related Financial Disclosures) — climate risk disclosures. ISSB (International Sustainability Standards Board) — IFRS S1 (General Requirements) and IFRS S2 (Climate-Related Disclosures), adopted by India's ICAI and under consideration by SEBI for phased mandatory application.

How It Works

  1. 1

    BRSR Applicability Assessment & Baseline Gap Analysis

    Determine BRSR applicability: (i) mandatory BRSR (full disclosure): top-1,000 listed companies by market cap from FY 2022-23; (ii) mandatory BRSR Core assurance: top-150 from FY 2023-24, top-250 from FY 2024-25, top-500 from FY 2025-26, top-1000 from FY 2026-27. Conduct a baseline gap analysis against the BRSR template: identify data that is already captured in existing systems (HR, finance, operations, EHS) and data that requires new tracking systems. Map the nine NGRBC principles against the company's current policies, practices, and disclosures.

    Government5-7 days
  2. 2

    Data Collection — GHG Emissions, Energy, Water, Waste & Social KPIs

    Collect and verify environmental KPIs: Scope 1 GHG emissions (combustion of fuels, process emissions, fugitive emissions — apply IPCC emission factors); Scope 2 GHG emissions (purchased electricity — location-based and market-based methods per GHG Protocol); total energy consumption by fuel type; water withdrawal by source (ground, surface, third-party municipal); water consumption; waste generated by type (hazardous vs. non-hazardous) and disposal method. Collect social KPIs: permanent vs. contractual employee breakdown by gender; equal remuneration ratio (male/female at similar levels); occupational health and safety metrics (LTIFR, fatalities); training hours per employee; CSR expenditure. Verify data accuracy by cross-checking against utility bills, fuel purchase records, payroll data, and EHS reports.

    Government15-20 days
  3. 3

    BRSR / Sustainability Report Preparation (Nine Principles + Core KPIs)

    Prepare the full BRSR disclosure covering all nine NGRBC principles: Section A (general company disclosures), Section B (management and process disclosures — policy statements, governance structure, compliance), and Section C (principle-wise performance disclosures with quantitative KPIs and qualitative disclosures). For the 49 BRSR Core KPIs: prepare accurate, traceable, and audit-ready data points with sources referenced. If preparing a standalone sustainability report: align disclosures to GRI Standards (GRI 302 — Energy, GRI 303 — Water, GRI 305 — Emissions, GRI 403 — Occupational Health & Safety). Prepare the TCFD-aligned climate risk disclosure (physical risks and transition risks) if applicable.

    Government15-20 days
  4. 4

    BRSR Core Assurance — Reasonable Assurance Engagement

    Conduct a reasonable assurance engagement on the BRSR Core KPIs. Reasonable assurance: a high level of assurance (but not absolute) — equivalent to a statutory audit in the context of financial statements. The assurance engagement follows ISAE 3000 (Revised) — International Standard on Assurance Engagements for Non-Historical Financial Information. Engagement procedures: (i) risk assessment of material misstatement in each KPI; (ii) test of controls — review data collection systems, approval processes, and internal controls; (iii) substantive procedures — agree KPIs back to source data (utility bills, payroll, production records); (iv) analytical procedures — trend analysis, benchmark comparison. Issue the assurance report: state the assertion level (reasonable assurance), any qualifications or emphasis of matter, and the CA firm's conclusion.

    Government15-20 days
  5. 5

    ESG Rating Agency Data Pack & Stakeholder Disclosure

    Prepare ESG data packs for rating agency questionnaires — MSCI ESG, Sustainalytics, ISS ESG, CRISIL ESG, or ICRA ESG ratings. Each agency has its own questionnaire format (MSCI IVA, Sustainalytics Company Assessment, S&P Global Corporate Sustainability Assessment). Ensure the data pack cites the BRSR KPIs and third-party assured data where available — assured data carries significantly more weight in agency scoring than unassured data. Advise on voluntary initiatives: Science-Based Targets initiative (SBTi) commitment, RE100 renewable energy pledge, UN Global Compact participation — each improves ESG score on agency frameworks. Prepare the ESG disclosure section of the Annual Report (typically in the Directors' Report or standalone ESG Report).

    Government5-10 days

Frequently Asked Questions

Is BRSR mandatory and who must file it?
BRSR (Business Responsibility and Sustainability Report) is mandatory under SEBI LODR Regulations (Regulation 34(2)(f)) for the top-1,000 listed companies by market capitalisation from FY 2022-23. Filing is done as part of the Annual Report. BRSR Core (reasonable assurance on 49 specific KPIs) is an additional requirement: (i) top-150 listed companies from FY 2023-24; (ii) top-250 from FY 2024-25; (iii) top-500 from FY 2025-26; (iv) top-1,000 from FY 2026-27. For companies outside the top-1,000 by market cap, BRSR is currently voluntary but is widely adopted as a governance best practice. Unlisted companies are not required to file BRSR under SEBI regulations, but may choose to prepare a sustainability report aligned with GRI Standards for stakeholder communication.
What are BRSR Core KPIs and why are they subject to assurance?
BRSR Core is a subset of 49 Key Performance Indicators from the full BRSR that SEBI has designated as most material for sustainability assessment of India's listed companies. These KPIs cover: (i) GHG emissions — Scope 1 and 2 per unit of revenue/production; (ii) energy intensity; (iii) water withdrawal and consumption intensity; (iv) waste generation; (v) gender pay gap and equal remuneration ratio; (vi) occupational health and safety metrics; (vii) supply chain sustainability assessment (% of value chain covered). SEBI mandates reasonable assurance on BRSR Core KPIs because these metrics are used by investors, ESG rating agencies, index providers (MSCI, FTSE4Good), and lenders for investment and lending decisions. Assured data is significantly more credible than self-reported data and reduces greenwashing risk.
What is the difference between limited assurance and reasonable assurance on ESG data?
In assurance engagements under ISAE 3000 (Revised), two levels are defined: (i) Reasonable assurance: a high level of assurance — the practitioner collects sufficient evidence to conclude the subject matter is free of material misstatement with high probability. Comparable to a statutory audit of financial statements. Procedures include tests of controls, detailed substantive procedures, and substantive analytical procedures. The assurance report uses positive language: 'In our opinion, the BRSR Core KPIs are presented fairly, in all material respects...'. (ii) Limited assurance: a lower level of assurance — the practitioner performs limited procedures (primarily inquiry and analytical review) and concludes that nothing has come to their attention that causes them to believe the information is materially misstated. The assurance report uses negative language: 'Based on our procedures, nothing has come to our attention that causes us to believe...'. SEBI requires reasonable assurance for BRSR Core from the applicable years.
What are Scope 1, Scope 2, and Scope 3 GHG emissions?
The GHG Protocol Corporate Standard (WRI/WBCSD) classifies GHG emissions into three scopes: Scope 1 — Direct emissions from sources owned or controlled by the company: combustion of fuels in boilers, furnaces, vehicles; process emissions from chemical reactions; fugitive emissions from refrigerants and natural gas leaks. Scope 2 — Indirect emissions from the generation of purchased electricity, steam, heat, or cooling consumed by the company. Two methods: location-based (average national/regional emission factor for the electricity grid) and market-based (emission factor from contractual instruments — RECs, green power contracts). Scope 3 — All other indirect emissions that occur in the company's value chain: upstream (purchased goods, capital goods, fuel and energy activities, transportation, waste) and downstream (use of sold products, end-of-life treatment, investments). BRSR Core mandates only Scope 1 and 2 reporting — Scope 3 is voluntary but encouraged by SEBI.
How does ESG assurance affect a company's ESG rating?
ESG ratings by major agencies (MSCI, Sustainalytics, S&P Global, CRISIL, ICRA) evaluate companies on the quality, completeness, and credibility of their ESG disclosures. Third-party assured data carries significantly more weight than self-reported data — MSCI and Sustainalytics specifically reward assured environmental metrics with higher scores in their frameworks. Key impacts of ESG assurance: (i) GHG emission figures with third-party assurance are accepted at face value; unassured figures are often discounted or flagged; (ii) companies with assured BRSR Core data are more likely to be included in ESG-themed indices (Nifty100 ESG, FTSE4Good India); (iii) SBTi (Science Based Targets initiative) requires that base-year emissions be verified before a company's targets are validated; (iv) ESG-linked financing (green bonds, sustainability-linked loans) typically requires assured environmental KPIs for reporting covenants.

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