Evolution of ESG Reports in India
ESG reports in India have evolved from a mere compliance requirement to a strategic tool for creating value and driving positive change in society and the environment.
Initially, it was considered a compliance requirement, but now it has become a strategic tool for companies to create value and drive positive change in society and the environment.
Companies are now expected to not only disclose their ESG performance but also set targets and report progress towards achieving them. This shift towards ESG reporting reflects a growing awareness of the impact of business on the environment and society, and the need for greater transparency and accountability in corporate practices.
Evolution process
Why do we need BRSR?
According to the Ministry of Corporate Affairs (MCA), Business Responsibility and Sustainability Reporting (BRSR) is needed for the following reasons:
- To align business strategies with sustainable development goals and to promote responsible business conduct.
- To provide stakeholders with reliable and standardized information on a company’s environmental, social, and governance (ESG) performance.
- To encourage companies to adopt sustainable and socially responsible practices, which can lead to long-term value creation.
- To increase transparency and accountability in corporate reporting, which can help build trust among stakeholders and investors.
- To facilitate comparability of ESG performance across companies and industries, which can help identify best practices and areas for improvement.
The business community needs to move beyond compliance and demonstrate its commitment to responsible and sustainable business practices.
Reporting on ESG performance has become a global trend, and India needs to align with international best practices.
There is a growing demand for transparency and accountability from stakeholders, including investors, customers, employees, and communities.
ESG issues can have a material impact on the financial performance and long-term sustainability of companies, and it is therefore important for investors to have access to reliable information.
BRSR can help companies identify and manage ESG risks and opportunities, which can ultimately lead to better business performance and value creation.
Basis of BRSR Reporting requirements
The National Guidelines on Responsible Business Conduct (NGRBC), which provide a framework for companies to report on their ESG performance. The BRSR is a standardized reporting format developed by SEBI based on the NGRBC, which requires the top 1000 listed companies in India to report on their ESG performance across nine key principles of responsible business conduct. These nine principles are:
- Business ethics and transparency
- Product and service responsibility
- Human rights
- Labour practices
- Environment
- Consumer issues
- Community development
- Corporate governance
- Inclusive development and poverty reduction
Companies are required to report on their policies, practices, and performance related to these principles and provide evidence of their impact on stakeholders. The BRSR reporting requirements are designed to encourage greater transparency and accountability among companies, and to promote the adoption of sustainable and responsible business practices in India.
BRSR with other International Framework
The BRSR framework is designed to be compatible with other international reporting frameworks,
- Global Reporting Initiative (GRI)
- United Nations Sustainable Development Goals (UN SDGs)
- Task Force on Climate-related Financial Disclosures (TCFD)
- Sustainability Accounting Standards Board (SASB)
- Carbon Disclosure Project (CDP)
- International Integrated Reporting Council (IIRC) Framework
- ISO 26000:2010 Guidance on social responsibility.
In fact, the BRSR includes a table that maps the BRSR indicators to the GRI Standards and the SASB Standards, making it easier for companies to align their reporting across different frameworks.
This compatibility allows companies to report on their ESG performance in a standardized way that can be easily understood by investors and other stakeholders who are familiar with these frameworks.
It is worth noting that while these frameworks share some common principles and indicators with BRSR, they may have their own unique reporting requirements and guidelines.
Reporting Structure of BRSR
Under BRSR, the number of reporting sections has been divided to 3 Sections.
Section A: General disclosures : The section contains details of the listed entity; products/services; operations; employees; holding, subsidiary and associate companies (including joint ventures); CSR; transparency and disclosure compliances.
Section B: Management and process disclosures : It contains questions related to policy and management processes, governance, leadership and oversight.
Section C: Principle-wise performance disclosures : Companies are required to report upon KPIs in alignment with the 9 principles of the NGRBC.
- Principle 1: Businesses should conduct and govern themselves with integrity, and in a manner that is ethical, transparent, and accountable.
- Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe.
- Principle 3: Businesses should respect and promote the well being of all employees, including those in their value chain.
- Principle 4: Businesses should respect the interests and be responsive to all their stakeholders.
- Principle 5: Businesses should respect and promote human rights.
- Principle 6: Businesses should respect and make efforts to protect and restore the environment.
- Principle 7: Businesses, when engaging in influencing public or regulatory policy should do so in a manner that is responsible and transparent.
- Principle 8: Businesses should promote inclusive growth and equitable development.
- Principle 9: Businesses should engage with and provide value to their customers in a responsible manner.
The section classifies KPIs into two sub-categories that companies are required to report upon:
Essential indicators (mandatory):
KPIs include data on training programmes conducted, environmental data on energy, emissions, water and waste, social impact generated by the company, etc.
Leadership indicators (voluntary):
Companies are expected to comply with these indicators for better accountability and responsible purpose. Some of the KPIs include data on life cycle assessments (LCAs), details on conflict management policy, additional data on biodiversity, breakup of energy consumption, Scope 3 emissions and supply chain disclosures
From BRR to BRSR
Business Responsibility Reporting (BRR) was the first mandatory reporting requirement for Indian listed companies on ESG-related aspects, introduced by SEBI in 2012. It required the top 100 listed companies to disclose information on their social, environmental, and governance performance.
In August 2020, the Committee from Ministry of Corporate Affairs (MCA) addressed various aspects and issues that could improve the quality and utility of disclosures and recommended Business Responsibility and Sustainability Reporting (BRSR) as an update on the existing Business Responsibility Reporting (BRR) and became a regulatory provision on 5th May 2021.
BRSR is a much more comprehensive disclosure framework than BRR. As compliance is mandatory from FY 2022–23, it is imperative for companies to get themselves ready for the change.
What is the difference between BRR and BRSR?
BRR
1. Applicable to the top 1,000 listed companies by market capitalisation.
2. Disclosures to be made in annual report.
3. Only quantitative disclosures
4. One universal template
BRSR
1. Applicable to the top 1,000 listed companies by market capitalisation from FY2023. Expected to be applicable to all listed and unlisted companies in the near future.
2. Disclosures to be made in Annual report and also in
MCA21 portal through XBRL language
3. Both quantitative and qualitative disclosure.
4. Two formats:
Comprehensive: For large companies and companies already reporting under the Listing Regulations (this format consists of the three sections shown in the structure below)
Lite: For companies who have no prior experience of sustainability reporting (this format requires lesser details and information that is expected to be available with all companies)
NOTE:
MCA-21 MCA21 is an e-governance initiative of the Ministry of Corporate Affairs (MCA), Government of India, aimed at providing easy and secure access to MCA services in an online mode. The MCA21 portal is a one-stop solution for company incorporation, compliance management, and regulatory filings for companies registered in India. It has transformed the way companies interact with the MCA and has simplified the compliance process for businesses.
XBRL (eXtensible Business Reporting Language) : It is a language for the electronic communication of business and financial data which is used for preparing and submitting financial statements and reports in a standardized and machine-readable format. XBRL is used in various countries, including India, to enhance transparency and efficiency in financial reporting. In India, the Ministry of Corporate Affairs (MCA) has mandated the use of XBRL for filing financial statements and annual reports by certain categories of companies.
BRSR Mandatory?
Yes, BRSR (Business Responsibility and Sustainability Reporting) is mandatory for the top 1000 listed companies in India. As per the SEBI (Securities and Exchange Board of India) guidelines, these companies are required to report on their ESG (Environmental, Social, and Governance) performance using a standardized format that covers 9 key principles of responsible business conduct. Companies are required to file their BRSR with the stock exchanges annually, starting from the financial year 2022-23.
BRSR became regulatory by way of an amendment to Regulation 34(2)(f) of the Listing Regulations, notified on 5th May 2021. Further, SEBI vide circular dated 10th May 2021 introduced the format of BRSR and the guidance note to enable the companies to interpret the scope of disclosures.
The reporting of BRSR shall be voluntary for FY 2021 – 22 and mandatory from FY 2022 – 23.
For the purpose of determining the applicability of the requirement, the market capitalization would be calculated as of 31 March of every financial year.
Reporting for unlisted companies
The Ministry of Corporate Affairs (MCA) recommendations include the reporting requirement may be extended to unlisted companies based on specified threshold of turnover and/or paid-up capital. The smaller unlisted companies below this threshold can adopt a lite version of the format, on a voluntary basis.
There are two formats for disclosure :
Comprehensive format (for listed companies)
Lite version (for non-mandatory disclosures)
BRSR - ESG Pillars
Environmental
• Energy and GHG/scope emissions
• Solid waste management
• Water consumption and withdrawal
• 3R practices
• Sustainable sourcing
• Extended producer responsibility (EPR)
• Life cycle assessments (LCAs)
Social
• Employee well-being
• Health and safety of workers
• Trainings
• Human rights
• Social impact assessment
• Gender equality – representation of women at the top levels
• CSR activities and details of beneficiaries
Governance
• Anti-corruption and anti-bribery policies
• Conflict management process
• Retention policies
• Remuneration policies
• Stakeholder engagement
Alignment of BRSR principles with the SDGs
