BRSR Reports Are Mostly Marketing: Here's the 10% That Isn't

An Opinion, Clearly Labelled

This is an opinion piece. The opinion is that most of a typical Business Responsibility and Sustainability Report (BRSR) is closer to marketing than to analysis, and that investors can save time by reading a small, specific part of it carefully.

That is not a criticism of the framework. SEBI's BRSR has made Indian ESG disclosure far more consistent than it was. It is a comment on how companies fill it in, and on where the useful information sits.

The BRSR in Brief

The BRSR is SEBI's required format for sustainability reporting. The top 1,000 listed companies by market value have had to file it since FY2022-23. It is organised around nine principles of responsible business conduct, with "essential" indicators that must be reported and "leadership" indicators that are voluntary.

A full BRSR can run to many dozens of pages. Large parts consist of yes or no answers about whether policies exist, descriptions of programmes, and statements of intent.

The Problem With Most of It

• Policies are not performance. Saying "yes, we have a human rights policy" tells you little about what happens in practice.
• Narrative is unverified. Descriptions of programmes and initiatives are usually not checked by anyone outside the company.
• Leadership indicators are optional, so companies can pick what flatters them.
• Comparisons are hard when companies define boundaries, units and baselines differently.

None of this is unique to India. Sustainability reports worldwide have the same issue.

The Part That Is Different: BRSR Core

In 2023, SEBI introduced BRSR Core: a smaller set of KPIs under nine ESG attributes, chosen because they can be measured and checked. They cover:

1. Greenhouse gas footprint
2. Water footprint
3. Energy footprint
4. Circularity and waste management
5. Employee wellbeing and safety
6. Gender diversity
7. Inclusive development
8. Fairness in engaging with customers and suppliers
9. Openness of business

Many of these KPIs are reported as intensity ratios, adjusted for purchasing power parity, which makes them easier to compare across companies of different sizes.

The Assurance Glide Path

BRSR Core KPIs must be independently assessed or assured, phased in by company size:

SEBI's original 2023 framework required "reasonable assurance." In March 2025, SEBI amended this to allow either assurance under recognised standards or a separate "assessment," and made value chain disclosures voluntary for the top 250 companies from FY2025-26. The provider must be independent and cannot offer consulting services to the company or its group.

Whether a company's numbers were assured or only assessed, and by whom, is worth checking. It is the difference between figures someone outside the company has tested and figures the company has simply reported.

A Worked Example: Reading an Intensity Ratio

Illustrative example. A company emits 2.0 million tonnes of CO2 on revenue of ₹10,000 crore, an intensity of 200 tonnes per ₹ crore. The next year, it emits 2.1 million tonnes on revenue of ₹11,500 crore, an intensity of about 183 tonnes per ₹ crore.

• Intensity fell by about 9%. The company produced more output per tonne of emissions.
• Absolute emissions rose by 5%.

Both facts are true, and a report can stress whichever one looks better. Read both. For climate risk under India's carbon market, intensity targets matter. For a company's overall contribution to emissions, the absolute number matters. Revenue-based intensity can also improve simply because prices rose, so intensity per unit of physical output, such as per tonne of cement, is often more meaningful where companies disclose it.

The 10% Worth Reading

1. The BRSR Core KPIs, especially emissions, energy and water intensity, and safety data such as fatalities and lost-time injuries.
2. The trend over three years. One year of data says little. A falling emissions intensity over three years says more.
3. The assurance or assessment statement: who provided it, under what standard, and any qualifications.
4. Boundary and method notes: which plants and subsidiaries are included, and how emissions were calculated.
5. Comparison with peers on the same intensity measures.

For a cement or steel company, emissions intensity matters more than almost anything else in the report. For a bank, the customer and governance KPIs matter more. Match the reading to what is material.

The Narrative's Limited Uses

The narrative is not useless. Complaints and grievance numbers, descriptions of supply chain checks, and details of legal cases can give an early hint of problems. Read them as leads to follow, not as evidence.

Habits for Reading a BRSR

1. Go straight to BRSR Core and the assurance statement.
2. Track three years of the most material KPIs.
3. Compare intensity ratios with two or three peers.
4. Check boundaries before comparing companies.
5. Treat narrative as leads, not conclusions.

The Reframe

A long sustainability report is not more information. It is more words. The useful part of a BRSR is small, numerical and, increasingly, checked by someone else. Read that part first, and read it well.