BRSR Reporting in India: What It Requires and Who Needs to File
Business Responsibility and Sustainability Reporting is mandatory for India's top listed companies by market capitalization, and increasingly expected down the supply chain even for unlisted vendors.
The Business Responsibility and Sustainability Report (BRSR) is SEBI's mandated ESG disclosure framework for India's largest listed companies (currently the top 1,000 by market capitalization), covering environmental, social, and governance metrics in a structured, comparable format. For a foreign company's India subsidiary that isn't itself listed on an Indian exchange, direct BRSR filing obligation typically doesn't apply.
Where it becomes relevant indirectly: SEBI's BRSR framework increasingly requires listed companies to report on their value chain, meaning large Indian listed companies are pushing ESG data requirements down to their suppliers and vendors, including unlisted foreign-owned subsidiaries that supply into these value chains, similar in spirit to how CSRD pushes requirements down EU supply chains.
Foreign subsidiaries supplying goods or services to large Indian listed companies should expect these ESG data requests to become more structured and more frequent over time, building basic ESG data tracking capability proactively positions the entity well ahead of when a specific customer's value-chain reporting request arrives.