How to Prepare a BRSR Report: Step-by-Step Guide for Indian Companies

Surbhi Ahuja

If you manage compliance or sustainability for an Indian listed company, understanding how to prepare a BRSR report has never been more important. The Business Responsibility and Sustainability Report is now mandatory under SEBI BRSR guidelines for the top 1,000 listed entities by market capitalisation, effective FY 2022-23. It replaces the older BRR format and aligns corporate disclosures with global ESG standards.

Companies that learn how to prepare a BRSR report correctly gain a dual advantage: they stay compliant and build long-term credibility with institutional investors and ESG rating agencies. This step-by-step guide covers everything from team formation to the final BRSR filing process.

What Is BRSR? A Quick Overview

The BRSR reporting framework was introduced through SEBI's circular dated May 10, 2021. It is structured around the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC) issued by the Ministry of Corporate Affairs. The framework covers environmental, social, and governance (ESG) disclosures across three sections: General Disclosures (Section A), Management and Process Disclosures (Section B), and Principle-wise Performance Disclosures (Section C).

BRSR compliance in India is mandatory for the top 1,000 BRSR-listed companies, ranked by market capitalisation on the NSE and BSE. Each section contains Essential Indicators (mandatory) and Leadership Indicators (voluntary but recommended for best-in-class reporting).

Here’s How to Prepare a BRSR Report

Step 1: Determine Your BRSR Applicability

Before anything else, confirm whether your company falls within the mandatory scope. As per SEBI BRSR guidelines, the report is compulsory for the top 1,000 NSE- and BSE-listed companies by market capitalisation from FY 2022-23 onward. Companies outside this threshold may voluntarily adopt the format. Verify your market-cap ranking at the start of each financial year, as it shifts annually. This is the first compliance check in any BRSR compliance exercise in India.

Step 2: Assemble a Cross-Functional BRSR Team

The first practical step in learning how to prepare a BRSR report is recognising that it is not a one-department task. The BRSR disclosure requirements span finance, HR, operations, legal, and CSR, making cross-functional ownership essential. Build a core team that includes:

• Finance and Accounts - for revenue, capital expenditure, and R&D data

• Human Resources - for workforce composition, wages, and safety metrics

• Operations / EHS - for energy, water, and emissions data

• Legal and Secretarial - for governance, litigation, and regulatory disclosures

• CSR - for community and social-impact reporting

Appoint a dedicated BRSR coordinator who owns the reporting timeline, consolidates inputs from all departments, and liaises with external auditors or assurance providers.

Step 3: Map the Three Sections and Nine Principles

The BRSR reporting framework organises disclosures across three sections and nine NGRBC principles:

1. Section A - General Disclosures: Company overview, products/services, employee count, supply chain, CSR details, and transparency disclosures.

2. Section B - Management and Process Disclosures: Policies and governance mechanisms for each of the nine NGRBC principles.

3. Section C - Principle-wise Performance Disclosures: Quantitative metrics for all nine principles, split into Essential and Leadership Indicators.

The nine principles under the ESG reporting standards in India cover ethical business conduct, product safety, environmental stewardship, fair labour practices, inclusive growth, and responsible advocacy. Each principle has Essential Indicators that must include current-year and prior-year comparative data. You can download SEBI's official BRSR format here.

Step 4: Collect Accurate Data Against Each Indicator

A credible Business Responsibility and Sustainability Report hinges on data accuracy. For every BRSR mandatory indicator, document the primary data source, the responsible data owner, and the collection frequency before you begin. Common metrics required under ESG reporting India standards include:

• Energy consumption (GJ) - Scope 1 and Scope 2 emissions in metric tonnes of CO₂ equivalent

• Water withdrawal and discharge volumes (kilolitres)

• Waste generated by category - hazardous, non-hazardous, and plastic waste (metric tonnes)

• Total employees and workers by gender, contract type, and differently-abled status

• Median wages for employees and workers, reported separately for male and female

• Number of consumer complaints received, resolved, and pending

Standardise your data-collection template across all business units to minimise errors and simplify year-on-year comparison.

Step 5: Draft the Report Using SEBI's Prescribed Format

Once the data is ready, the next stage in preparing a BRSR report is drafting it in SEBI's exact tabular format prescribed for listed companies. Do not rearrange sections or rename columns. Use current-year data in Column A and prior-year data in Column B wherever comparative BRSR disclosure requirements apply. Provide clear N/A explanations wherever a metric is not applicable, rather than leaving cells blank.

For qualitative disclosures under Section B, write policy statements that reflect actual, current practice rather than aspirational language. ESG rating agencies flag gaps between stated policies and reported performance metrics, a common pitfall for first-time filers.

Step 6: Obtain Internal Review and External Assurance

Before initiating the BRSR filing process, route the draft through your audit committee and board of directors for approval. As per SEBI BRSR guidelines, the report must be signed off by the company's CEO/MD and CFO. External assurance of BRSR mandatory indicators is currently voluntary, but SEBI has indicated its intent to make it mandatory for the top 250 listed companies. Engaging an accredited assurance provider now strengthens credibility and future-proofs your process.

Step 7: File with the Stock Exchanges and Publish

Submit the approved report as part of your Annual Report to BSE and/or NSE per SEBI's LODR Regulations, a core requirement of BRSR compliance in India. The report must also be published on the company website. Your published document represents a public commitment to responsible and transparent governance. Ensure it is in a machine-readable format (e.g., accessible PDF or HTML) so ESG data aggregators and institutional investors can extract information efficiently.

Key Tips for a Strong BRSR Report

• Start data collection at least six months before your fiscal year-end to prevent last-minute gaps.
• Align BRSR metrics with GRI, SASB, or TCFD frameworks where possible to meet global ESG investor expectations.
• Document all data-collection methodologies and assumptions clearly this is closely examined during external assurance.
• Track year-on-year trends to demonstrate continuous improvement, a factor that positively influences ESG ratings.
• Use digital ESG data management tools to automate collection, reduce manual errors, and build an audit trail.

From Compliance to Competitive Advantage

Companies that master the preparation of a BRSR report gain far more than regulatory compliance; they earn the trust of investors, customers, and regulators alike. By following these seven steps, from applicability checks and team formation to data collection, drafting, assurance, and filing, Indian companies can produce a credible, data-driven BRSR that reflects a genuine commitment to responsible business. Start your process early, keep your data clean, and treat the report as a strategic asset, not just a compliance obligation.