The reporting landscape: fitting the frameworks together

Financial reporting has one main rulebook in India: Ind AS. Sustainability reporting has several, and each answers a slightly different question for a different reader.

Some frameworks ask: "How do ESG issues affect this company's value?" They are written for investors. Others ask: "How does this company affect people and the planet?" They are written for a wider group, including employees, communities and regulators. A few try to do both.

For an Indian listed company, one framework is compulsory: SEBI's BRSR. The others are voluntary in India, but many large companies use them anyway because global investors, customers or lenders ask for them. That is why one annual report can contain a BRSR, a GRI index, a TCFD section and a CDP score all at once.

For an analyst, the practical point is this: before you compare any ESG number across companies, find out which framework it was reported under and what boundary it covers. Two "water withdrawal" figures from two frameworks may not measure the same thing.

The frameworks at a glance

BRSR

The BRSR has three sections:

• Section A: general disclosures (company details, operations, employees, CSR)
• Section B: management and process disclosures (policies, governance and oversight)
• Section C: performance against the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC). Each principle has essential indicators, which are mandatory, and leadership indicators, which are voluntary.

BRSR Core

BRSR Core is a subset of BRSR: a set of key indicators grouped under nine ESG attributes, including intensity ratios adjusted for purchasing power parity. These indicators must be independently checked, phased in by market capitalisation rank: top 150 from FY 2023-24, top 250 from FY 2024-25, top 500 from FY 2025-26 and top 1,000 from FY 2026-27.

The original framework required reasonable assurance. SEBI's circular of 28 March 2025 changed this to a choice: a company can obtain either assurance under recognised assurance standards, or a third-party assessment against standards developed by the Industry Standards Forum in consultation with SEBI.

Only BRSR Core is independently checked, not the whole BRSR.

Value chain disclosures

Value chain disclosures under BRSR Core apply to the top 250 listed entities on a voluntary basis from FY 2025-26, with assessment or assurance of them voluntary from FY 2026-27.

ISSB: IFRS S1 and IFRS S2

• IFRS S1: general requirements for sustainability-related financial disclosures
• IFRS S2: climate-related disclosures, including Scope 1, 2 and 3 emissions, climate resilience and scenario analysis

Both use four pillars taken from TCFD: governance, strategy, risk management, and metrics and targets. IFRS S1 points companies to the SASB Standards for industry-specific metrics.

GRI

GRI has three layers: universal standards (for every reporter), sector standards and topic standards (for example emissions, water, occupational health and safety). GRI is the most common framework for voluntary sustainability reports worldwide.

TCFD

TCFD built the four-pillar structure that ISSB now uses. Its recommendations live on through IFRS S2, and its structure remains common in Indian annual reports.

Banks and NBFCs

RBI issued Directions on climate finance and the management of climate change risks on 28 November 2025, with separate versions for commercial banks, NBFCs and small finance banks. They mainly set rules for green deposits and green lending. A separate framework for public disclosure of climate-related financial risks, built on the four TCFD pillars, was issued in draft in February 2024 and had not been finalised at the time of this review (see the Climate Disclosure for Banks and NBFCs guide).