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Top 1000 Listed Companies to File ESG Reports with SEBI

ESG reporting in India commenced in 2009 when the Ministry of Corporate Affairs (MCA) issued voluntary guidelines on Corporate Social Responsibility. This was the first step towards mainstreaming the business responsibility concept in India. Since then, the ESG reporting landscape has come a long way. From Business Responsibility Report to National Guidelines on Responsible Business Conduct, ESG reporting in India has moved to Business Responsibility and Sustainability Report framework.

On 10th May 2021, the Securities and Exchange Board of India (SEBI) mandated filings under the Business Reporting and Sustainability Reporting (BRSR) from the fiscal year 2022-23. The mandate applies to the top 1,000 listed companies by market cap. Continue reading to learn more about the disclosure requirements in the new BRSR framework.

Refer to SEBI Updates on ESG Disclosure

But first, let’s understand what ESG reporting is.

What is ESG Reporting?

 Sustainability is fast becoming a priority for corporates all around the globe. With a shift in the mindset of investors, priorities have expanded to include sustainability growth along with the primary wealth creation goal. As a result, businesses today are expected to demonstrate ethics and moral duty towards society.

ESG reporting is the disclosure of a company’s data covering operations in three areas, i.e., environmental, social, and corporate governance. ESG reporting is an invaluable tool for organisations as it helps identify risks, track sustainability, and report their performance. Data covered under ESG reporting include:

  • Environmental: biodiversity, climate change strategy, energy efficiency, etc.
  • Social: equal opportunities, human rights, health, and safety, etc.
  • Governance: business ethics, shareholder democracy, compliance, etc.


Structure of BRSR Format

The reporting format is divided into three sections:

 Section A: General Disclosures

The section includes details of the listed entity – its operation, products/services, employees, holding, subsidiary and associate companies, CSR, and transparency and disclosure compliance.

 Section B: Management and Process Disclosures

The section includes policy and management processes, leadership, governance, and oversight questions.

 Section C: Principle-Wise Performance Disclosures

This section requires companies to report the KPIs in alignment with the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC).


 Disclosure Requirements Under the New BRSR Format

The new BRSR format for ESG reporting is based on nine principles of the Indian government’s NGRBC. These guidelines define responsible business conduct for Indian companies. The nine principles under these guidelines address several sustainability issues, such as human rights, business ethics and transparency, fair labor practices, and environmental safety.

The following table shows the principles of NGRBC that cover the aspects of ESG reporting.




Principle 6: Businesses should respect and try to protect and restore the environment.

Social (Employees)

Principle 3: Businesses should promote the well-being of employees, including those in their value chains.

Principle 5: Businesses should promote individual human rights.

Social (Communities)

Principle 8: Businesses should promote overall growth and equitable development.

Social (Consumers)

Principle 9: Businesses should provide value to their customers in a responsible manner.


Principle 1: Businesses should govern themselves with integrity, ethics, transparency, and accountability.


How to Submit Business Reporting and Sustainability Report (BRSR)?

Listed companies are required to submit BRSR in both PDF and XBRL formats. Companies that have filed BRSR in PDF must also submit it in XBRL mode. Filers can find XBRL utility for BRSR submission in the XBRL section of BSE’s Listing Centre.



The new ESG reporting requirements promote transparent, standardised disclosures on sustainability-related risks and opportunities for listed companies in India. It will help companies better convey their sustainability objectives, performance, and position in the market. As a result, it helps increase investors’ ability to make informed ESG-related decisions. 

BRSR is a more comprehensive reporting framework than BRR. Companies must prepare themselves for the change mandated from the fiscal year 2022-23. For more details regarding the ESG reporting mandate in India, stay updated at

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