The principles remain the same. The evidence, reporting boundaries, and third-party verification expectations have changed.
Executive summary
- Who is affected: The top 1,000 listed companies in India by market capitalisation.
- What changes: BRSR Core KPIs must be independently assessed or assured.
- When: FY 2026-27 is the first year in which the top 1,000 listed companies face this requirement.
- What to do: Define consistent reporting boundaries, align methodology with the Industry Standards on Reporting of BRSR Core, and make supplier and value chain data verifiable—not merely estimated.
SEBI introduced the Business Responsibility and Sustainability Report (BRSR) through its circular dated 10 May 2021. Initially, BRSR was primarily a disclosure framework. By FY 2026-27, it has evolved into a much more standardised, independently assessed source of ESG data. In FY 2026-27, the top 1,000 listed companies in India must obtain independent assessment or assurance for BRSR Core metrics.
The nine principles at the heart of the BRSR framework remain unchanged. What companies are expected to prove against them has changed.
Where the nine principles come from
Contrary to a common misconception, these principles were not developed by SEBI. They originate from the National Guidelines on Responsible Business Conduct (NGRBC), issued by the Ministry of Corporate Affairs (MCA) on 15 March 2019. SEBI subsequently developed the BRSR framework based on these guidelines.
Accordingly, Section C of the BRSR requires companies to report their performance against each of the following principles:
- Governance of the business based on ethics, transparency, and accountability.
- Providing goods and services sustainably and safely.
- Wellbeing of employees in the enterprise and value chain.
- Responsiveness to all stakeholder interests.
- Respect for and promotion of human rights.
- Preservation and restoration of the environment.
- Transparent participation in policy-making processes.
- Commitment to inclusive growth and equitable development.
- Conscientious involvement with the consumer and providing value for them.
There are two levels of indicators for each principle. Essential indicators are mandatory. Leadership indicators are voluntary and are intended for reporting beyond the baseline.
BRSR Core is not the same as the nine principles
This distinction matters.
- The nine principles are the broad responsible business principles under BRSR Section C.
- BRSR Core is a limited set of KPIs under nine attributes. It includes GHG, water and energy footprints, circularity, welfare and safety of employees, gender diversity, inclusive growth, business integrity with consumers and suppliers, and transparency in business.
- Only the BRSR Core metrics are subject to independent assessment or assurance.
In other words, BRSR Core is not a replacement for the nine principles. It is the verifiable, KPI-based layer that determines whether key ESG claims can be trusted.
From disclosure to verification
BRSR became compulsory for the largest 1,000 companies listed by market capitalisation from FY 2022-23, following more than 175 companies that filed it voluntarily in FY 2021-22.
| Financial year | BRSR Core assessment or assurance scope |
| FY 2023-24 | Top 150 listed companies |
| FY 2024-25 | Top 250 listed companies |
| FY 2025-26 | Top 500 listed companies |
| FY 2026-27 | Top 1,000 listed companies |
The major development came through SEBI’s circular dated 12 July 2023, which introduced BRSR Core. BRSR Core is subject to independent assessment or assurance, and its implementation has been phased based on market capitalisation:
Value chain relaxations apply in parallel, and companies should verify their exact applicability against the relevant SEBI circulars.
What SEBI changed in 2024 and 2025
In December 2024, SEBI adopted certain business-friendly reforms, which were issued in a circular dated 28 March 2025.
First, “assurance” was broadened to “assessment or assurance.” The assessment needs to be done based on the Industry Standards on Reporting of BRSR Core, established by the Industry Standards Forum of ASSOCHAM, FICCI, and CII in consultation with SEBI through a SEBI circular dated 20 December 2024.
Second, value chain reporting was limited and made optional. Reporting of upstream and downstream partners whose proportion of procurement or sales to the business is 2% or above has become optional for up to 75% of the value chain. Reporting of such information for the top 250 companies becomes voluntary from FY 2025-26, and assessment or assurance of the same data becomes voluntary from FY 2026-27. Companies should confirm the precise coverage calculation and applicability in the SEBI circular.
Third, a new Leadership indicator under Principle 6 asks businesses to disclose green credits created or acquired by the business and its top ten value chain partners.
Why “voluntary” does not mean optional
The value chain relaxation can easily be over-interpreted.
Principles 3 and 6 go beyond the responsibility of a business’s own operations. A deactivated supplier data process will have to be rebuilt as soon as requirements become stricter. For suppliers—whether listed companies or unlisted MSMEs—the outcome remains the same: big buyers who must comply with BRSR will require their numbers.
Data like this is being collected outside India too. Steel, aluminium, and other materials within the scope of the Carbon Border Adjustment Mechanism (CBAM) are expected to come with embedded emissions data. CBAM’s definitive period started on 1 January 2026.
For companies in scope, the challenge for FY 2026-27 is not simply applying each principle in a narrative fashion. The real challenge is verifying the veracity of BRSR Core numbers through an independent third party: consistent reporting boundaries, sound methodology, and supplier data that can actually be verified, not just estimated.
What listed companies must demonstrate in FY 2026-27
Companies should treat BRSR Core readiness as an evidence and controls exercise, not a reporting formality. Key areas to demonstrate include:
- Consistent reporting boundaries across entities, locations, and geographies.
- Methodology aligned with the Industry Standards on Reporting of BRSR Core.
- Verifiable supplier and value chain data, not estimates.
- Internal controls, ownership, and audit trails for each BRSR Core KPI.
- Evidence for GHG, energy, water, waste, circularity, employee safety and welfare, gender diversity, and inclusive growth.
- Grievance and remediation mechanisms.
- A restatement policy for errors or methodology changes.
- Readiness for independent assessment or assurance.
Final takeaway
The principles define the direction. BRSR Core and its assessment regime will determine whether a report can be trusted.
For FY 2026-27, the real test is not narrative reporting. It is verifiable, boundary-consistent, methodologically sound data—supported by supplier information that stands up to independent scrutiny.
This article updates Snowkap’s original explainer on the nine principles of BRSR. Read it here: https://snowkap.com/brsr-9-principles-exploring-the-foundations-of-accountability?utm_source=utm_powerweave&utm_medium=utm_blogsummary&utm_campaign=utm_campaign=brsr9principles
