BRSR Core: What the Top 250 Listed Companies Must Disclose

The Business Responsibility and Sustainability Reporting (BRSR) framework introduced by India's Securities and Exchange Board of India (SEBI) has become the gold standard for ESG disclosure. In 2023, SEBI refined the framework further by introducing BRSR Core - a focused, mandatory subset of 49 key performance indicators (KPIs) designed to capture the most material ESG metrics for large listed companies. This guide explains what BRSR Core is, who must comply, and what it means for your organization and supply chain.

What is BRSR Core - A Focused ESG Disclosure Framework

Understanding BRSR Core as a Subset of Full BRSR

BRSR Core is not a separate reporting standard. Instead, it is a curated selection of 49 KPIs extracted from the broader BRSR framework, which itself contains over 100 data points. SEBI introduced BRSR Core in 2023 to address a critical challenge: while comprehensive BRSR reporting is valuable, investors and regulators needed a standardized baseline of truly material ESG metrics that would enable meaningful comparison across large listed companies.

The 49 KPIs in BRSR Core focus on the most financially and operationally significant ESG factors. These include environmental metrics like greenhouse gas (GHG) emissions intensity and energy intensity, social metrics like gender diversity and pay equity, and governance metrics related to board composition and anti-corruption measures. By concentrating on these core indicators, BRSR Core ensures that the top 250 Indian listed companies disclose the ESG data that matters most to investors, regulators, and stakeholders.

The Key Difference: BRSR Core vs. Full BRSR

Companies complying with BRSR Core are also expected to implement the broader BRSR framework principles. However, BRSR Core imposes mandatory third-party assurance (a requirement we discuss in detail below) only on these 49 specific KPIs. This tiered approach balances the need for rigorous assurance of material metrics with the flexibility to allow companies to report additional BRSR data without full external verification, if they choose.

Learn more about the broader framework in our guide on What is BRSR Reporting?

Who Must Comply with BRSR Core - The Timeline and Company Size Threshold

Phase 1: Top 150 Listed Companies (FY 2023-24)

BRSR Core compliance began with India's top 150 listed companies by market capitalization in FY 2023-24. These organizations, primarily from sectors like finance, energy, pharmaceuticals, automobiles, and technology, faced the first mandatory deadline to disclose their BRSR Core KPIs. This phased rollout allowed the market to stabilize and companies to build the data infrastructure and governance processes required.

Phase 2: Expansion to Top 250 Listed Companies (FY 2024-25)

From FY 2024-25 onwards, the requirement expanded to include the top 250 listed companies by market capitalization. This significant expansion brought mid-cap companies and sector leaders from industries like retail, infrastructure, consumer goods, and telecommunications into the BRSR Core compliance net. Companies that joined this second wave had to implement their BRSR Core data collection and reporting infrastructure quickly, often within 12-18 months of the announcement.

Determining Your Compliance Status

If your company is listed on the National Stock Exchange (NSE) or Bombay Stock Exchange (BSE) and ranks within the top 250 by market capitalization at the start of a financial year, BRSR Core compliance is mandatory for that fiscal year's annual report and sustainability disclosure. Many companies use their fiscal year-end market capitalization rank to determine their status, though this can vary slightly based on SEBI's specific guidance issued in any given year.

The 49 BRSR Core KPIs - What You Must Disclose

Environmental Metrics

BRSR Core requires disclosure of three intensity-based environmental KPIs that allow meaningful comparison across companies of different sizes:

• GHG Emissions Intensity: Total Scope 1, 2, and 3 greenhouse gas emissions expressed as emissions per unit of revenue or production output. This metric is critical for investors assessing climate risk and the company's decarbonization progress.
• Energy Intensity: Total energy consumed (renewable and non-renewable) per unit of revenue or production output. Companies must also disclose the percentage of energy from renewable sources.
• Water Intensity: Total water consumed per unit of revenue or output, allowing investors to evaluate water stress exposure and circular economy practices.

Additional environmental KPIs include waste generation (both hazardous and non-hazardous), waste recycling rates, and plastic waste metrics.

Social Metrics

BRSR Core's social indicators focus on workforce diversity, equity, and human rights:

• Gender Diversity: Percentage of women in the workforce, across management levels, and in leadership roles. This metric addresses both ethical considerations and empirical evidence linking diversity to organizational performance.
• Pay Equity: The ratio of average salary paid to men versus women, measured across all job levels. This is one of the most scrutinized BRSR Core metrics by institutional investors.
• Human Rights Due Diligence: Disclosures on supplier assessments, grievance mechanisms, and remediation actions related to forced labor, child labor, and freedom of association.
• Employee Turnover and Engagement: Metrics on retention rates and employee satisfaction, which correlate with operational resilience.

Governance and Business Ethics Metrics

BRSR Core includes metrics on board independence, diversity, remuneration transparency, and anti-corruption measures. Companies must disclose details on ethics training, whistleblower grievances, and instances of corruption or misconduct.

Mandatory Third-Party Assurance for BRSR Core - Who Can Verify

The Assurance Requirement

Unlike full BRSR, which allows for self-assessment, the 49 BRSR Core KPIs require mandatory third-party assurance. This assurance must be provided by SEBI-registered Category I Merchant Bankers or qualified independent auditors. The assurance provides limited or reasonable assurance (depending on the company's governance framework and the specific KPI) that the BRSR Core data disclosed is accurate, material, and aligned with SEBI's guidance.

Finding an Approved Assurance Provider

Your organization's external auditor (Big Four firms and mid-tier audit firms all participate) or a SEBI-registered sustainability consultant can provide BRSR Core assurance. The assurance provider conducts data verification, process audits, and stakeholder interviews to validate the disclosed KPIs. This independent verification adds credibility and reduces the risk of greenwashing - a concern that drove SEBI's assurance requirement in the first place.

Timeline and Planning for Assurance

Assurance typically takes 8-12 weeks from the point your organization submits its complete data package. To meet annual reporting deadlines, companies usually begin assurance planning 4-5 months before their fiscal year-end. Platforms like Greenio can streamline data collection and documentation, reducing the time your assurance provider needs to verify information.

Read more about regulatory requirements in Is BRSR Mandatory?

BRSR Core and Supply Chain - Cascading Disclosure Requirements

Supply Chain ESG Data Collection

The top 250 listed companies must disclose ESG data not only for their own operations but also for their supply chain, particularly Tier-1 suppliers. SEBI's guidance requires companies to assess and report on supplier diversity, environmental practices, and labor standards across their procurement network.

Impact on MSME Suppliers

This requirement has created significant cascading obligations for micro, small, and medium enterprises (MSMEs) that supply large listed companies. MSMEs are now expected to provide ESG data to their buyer companies, often without having the internal capacity or technology infrastructure to do so. Many large companies are implementing supplier portals or using third-party platforms to collect this data in standardized formats.

Practical Supply Chain Compliance Steps

1. Map your supplier base by tier, revenue contribution, and industry sector.
2. Identify Tier-1 suppliers that represent significant environmental or social risk.
3. Develop a supplier ESG data template aligned with BRSR Core metrics.
4. Communicate timelines and expectations clearly to suppliers at least 6 months before your reporting deadline.
5. Provide technical support to smaller suppliers struggling with data collection, or use a platform that simplifies the process.

Key Takeaways on BRSR Core Compliance

• BRSR Core is a curated set of 49 mandatory KPIs for India's top 250 listed companies, introduced to standardize material ESG disclosure.
• Two-phase compliance timeline: Top 150 companies from FY 2023-24, expanding to top 250 from FY 2024-25 onwards.
• Third-party assurance is mandatory and must be performed by SEBI-registered providers.
• Supply chain ESG disclosure cascades to Tier-1 suppliers, creating new obligations for MSMEs.
• Data infrastructure is critical: Companies need robust processes to collect, validate, and report the 49 KPIs consistently year over year.

Frequently Asked Questions

What is BRSR Core and how is it different from full BRSR?

BRSR Core is a subset of 49 mandatory KPIs within the broader BRSR framework, focused on material ESG metrics. The main difference is that BRSR Core KPIs require third-party assurance, while full BRSR allows for more flexibility in verification and includes additional non-mandatory indicators. Companies must meet BRSR Core requirements but can also report additional BRSR metrics if they choose.

Which companies must comply with BRSR Core?

The top 150 listed companies by market capitalization were required to comply from FY 2023-24. From FY 2024-25 onwards, this expanded to the top 250 listed companies on the NSE and BSE. Market capitalization rank is typically determined at the start of the financial year to establish compliance status.

What assurance is required for BRSR Core?

All 49 BRSR Core KPIs require mandatory third-party assurance from SEBI-registered Category I Merchant Bankers or independent auditors. The assurance is typically limited or reasonable assurance (depending on materiality and control maturity) and certifies the accuracy and completeness of the disclosed metrics.

How does BRSR Core affect MSME suppliers?

BRSR Core requires top 250 companies to collect and disclose ESG data from their supply chain, particularly Tier-1 suppliers. This creates cascading obligations for MSMEs, which must now provide environmental and social data to their buyer companies, often without existing data collection infrastructure. Large companies are helping suppliers by providing data templates and platforms to simplify compliance.

When is the next BRSR Core deadline in 2026?

For FY 2025-26, all top 250 listed companies must disclose BRSR Core KPIs in their annual reports, typically published 3-4 months after fiscal year-end (by Q3 2026 for companies with March 31 year-ends). Third-party assurance must be completed and disclosed alongside the KPI data.

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BRSR Core represents a maturation of India's ESG disclosure landscape. By focusing on 49 material KPIs and requiring independent assurance, SEBI has created a more investor-friendly, comparable dataset while maintaining the flexibility of the broader BRSR framework. For the top 250 listed companies, implementing robust BRSR Core processes today is not just regulatory compliance - it is a competitive advantage that strengthens stakeholder trust and operational resilience.