Regional spotlight: Corporate climate disclosures in India — what's different and why it matters

India's Securities and Exchange Board (SEBI) now requires the top 1,000 listed companies by market capitalization to file Business Responsibility and Sustainability Reports (BRSR), making it one of the largest mandatory climate disclosure regimes in any emerging economy. As of FY 2024-25, compliance rates for the core BRSR framework reached 92% among the top 500 listed companies, yet only 34% of those filings included Scope 3 emissions data with any degree of methodological rigor, according to a 2025 analysis by the Centre for Science and Environment (CSE). For engineers, sustainability professionals, and investors operating in or exposed to the Indian market, the gap between regulatory ambition and reporting quality creates both risk and opportunity that demands close attention.

Why It Matters

India is the world's third-largest emitter of greenhouse gases, responsible for approximately 7.6% of global CO2 emissions in 2024 (Global Carbon Project, 2025). The country's economy grew at 6.8% in FY 2024-25, and its manufacturing sector is expanding rapidly under the Production Linked Incentive (PLI) scheme across 14 sectors. This growth trajectory means that Indian corporate emissions are rising, not declining, making disclosure frameworks the primary mechanism through which regulators, investors, and supply chain partners can assess and influence corporate climate performance.

India's disclosure regime operates in a regulatory landscape fundamentally different from the EU or US. The BRSR framework, introduced in 2021 and made mandatory in phases from FY 2022-23, was designed specifically for the Indian context rather than adopted wholesale from international standards. While SEBI has signaled alignment with ISSB (International Sustainability Standards Board) standards, the current framework reflects Indian policy priorities: emphasis on water stewardship, waste management, and social metrics alongside climate data. This creates a reporting structure that covers more ground than a pure climate disclosure framework but with less depth on any single dimension.

The financial stakes are significant. Foreign portfolio investors held approximately $720 billion in Indian equities as of March 2025 (NSDL, 2025). Many of these investors operate under EU SFDR (Sustainable Finance Disclosure Regulation) or similar regimes that require portfolio-level emissions reporting. When Indian companies produce incomplete or non-comparable climate data, the cost falls on investors who must either accept data gaps or commission independent assessments at $50,000 to $200,000 per company.

Key Concepts

BRSR and BRSR Core

The BRSR is structured around nine principles derived from India's National Guidelines on Responsible Business Conduct. Climate-related disclosures fall primarily under Principle 6 (environment) and include Scope 1 and Scope 2 emissions, energy consumption by source, water withdrawal and discharge, and waste generation metrics. In 2023, SEBI introduced BRSR Core, a subset of key performance indicators intended for assurance and supply chain reporting. BRSR Core includes greenhouse gas emissions intensity, water intensity, and waste-to-landfill ratios, with mandatory reasonable assurance required for the top 150 listed companies from FY 2024-25 and extending to the top 1,000 by FY 2026-27.

Scope 3 and Value Chain Reporting

BRSR Core includes a value chain reporting requirement that asks listed companies to report BRSR Core metrics for their top upstream and downstream partners. This is a distinctive feature: rather than requiring companies to estimate aggregate Scope 3 emissions using spend-based or average-data methodologies (as the GHG Protocol prescribes), India's framework pushes for entity-level data collection from specific supply chain partners. In practice, this means large Indian corporates are asking their suppliers and distributors to complete BRSR Core templates, creating a cascading disclosure obligation that reaches companies far smaller than the listed entities subject to the primary mandate.

Assurance Requirements

SEBI mandates reasonable assurance on BRSR Core indicators, a higher standard than the limited assurance that the EU CSRD initially requires. However, the assurance ecosystem in India is still developing. The Institute of Chartered Accountants of India (ICAI) issued sustainability assurance standards in 2024, but the pool of qualified assurance practitioners remains small relative to the 1,000 companies that will eventually require coverage. A 2025 survey by KPMG India found that only 28 audit firms in the country had dedicated sustainability assurance teams with more than five trained professionals, creating a bottleneck that risks formulaic, low-quality assurance engagements (KPMG India, 2025).

What's Working

Regulatory Clarity and Phased Implementation

SEBI's phased approach to mandatory disclosure has allowed companies time to build reporting infrastructure while maintaining regulatory certainty. The top 1,000 companies knew by 2021 that they would eventually be subject to BRSR requirements, and the graduated timeline (top 1,000 by market cap for basic BRSR, top 150 for assured BRSR Core, expanding annually) has given early movers a competitive advantage. Infosys, Tata Consultancy Services, and Mahindra Group established dedicated sustainability reporting teams ahead of the mandate, and their BRSR filings now serve as de facto templates for mid-cap companies entering the framework.

Reliance Industries provides a notable example. The conglomerate's FY 2024-25 BRSR filing runs to 186 pages and includes granular site-level emissions data for its refining, petrochemicals, retail, and telecom operations. Reliance reports Scope 1 emissions of 54.8 million tonnes CO2e, Scope 2 emissions of 3.2 million tonnes CO2e, and Scope 3 estimates across 10 of the 15 GHG Protocol categories. The company's disclosure intensity reflects its exposure to international capital markets and its net-zero 2035 target, which creates internal demand for robust data regardless of regulatory minimums (Reliance Industries, 2025).

Digitization of Supply Chain Data

India's existing digital infrastructure, particularly the Goods and Services Tax Network (GSTN) that processes over 1 billion invoices per month, provides a foundation for supply chain emissions data collection that few other countries can match. Several Indian climate-tech startups have built integrations with GSTN data to estimate emissions from procurement records, triangulating invoice data with emissions factors to produce Scope 3 estimates. Sinai Technologies, TraceX Technologies, and Greenjoules are among the companies offering BRSR-aligned reporting platforms that can ingest GSTN data, reducing the manual data collection burden that plagues Scope 3 reporting in other jurisdictions.

The Bombay Stock Exchange (BSE) launched a BRSR reporting portal in 2024 that standardizes digital submission and enables cross-company comparison. As of January 2026, 847 companies had submitted BRSR filings through the portal, creating a structured dataset that researchers and investors can query programmatically (BSE, 2026).

Sector-Specific Depth in Heavy Industry

Indian heavy industry has produced some of the most detailed climate disclosures in any emerging market. JSW Steel, India's largest private-sector steel producer, reports emissions intensity of 2.07 tonnes CO2 per tonne of crude steel (FY 2024-25), benchmarked against the World Steel Association average of 1.91 tonnes. Dalmia Cement reports blended cement emissions intensity of 408 kg CO2 per tonne, positioning it among the lowest-carbon cement producers globally and below the global average of 620 kg per tonne reported by the Global Cement and Concrete Association. These sector-level disclosures allow meaningful comparison against international peers and highlight where Indian industry is competitive on carbon intensity.

What's Not Working

Inconsistent Scope 3 Reporting

Despite BRSR Core's value chain provisions, Scope 3 remains the weakest element of Indian corporate climate disclosure. A 2025 analysis of 200 BRSR filings by the Climate Policy Initiative found that: 42% of companies reported zero Scope 3 emissions; 31% reported only one or two upstream categories; and just 12% reported downstream emissions in any category. Methodological inconsistency is rampant: some companies report Scope 3 in absolute tonnes, others report intensity metrics only, and boundary definitions vary widely even within the same industry (Climate Policy Initiative, 2025).

The value chain reporting requirement in BRSR Core compounds this problem. When listed companies ask their suppliers to report BRSR Core metrics, many SME suppliers lack the capacity to respond. A survey by the Confederation of Indian Industry (CII) found that 67% of Tier 1 suppliers to BRSR-obligated companies had no emissions measurement capability, and 81% lacked the staff or budget to implement one (CII, 2025). The result is that value chain data is either missing or based on proxy calculations that may not withstand assurance scrutiny.

Limited Climate Scenario Analysis

International frameworks such as TCFD and ISSB IFRS S2 emphasize climate scenario analysis as a core element of disclosure. Indian BRSR filings rarely include scenario analysis. Among the top 150 BRSR Core companies, only 23 published any form of climate scenario assessment in FY 2024-25, and most of those were limited to qualitative descriptions rather than quantified financial impacts. This gap is particularly significant for companies with long-lived physical assets (power generation, real estate, infrastructure) that face material transition and physical risks over 10 to 30-year horizons.

Assurance Quality Concerns

The rapid expansion of assurance requirements has outpaced the development of qualified practitioners. Several early BRSR Core assurance reports have been criticized for boilerplate language that fails to identify specific data quality issues or methodological limitations. The National Financial Reporting Authority (NFRA), India's audit regulator, issued guidance in 2025 calling for "substantive rather than procedural" sustainability assurance, but enforcement mechanisms remain undeveloped. Companies spending $15,000 to $40,000 on BRSR Core assurance may be receiving compliance documentation rather than genuine data quality validation.

Key Players

Established Organizations:

• SEBI (Securities and Exchange Board of India): regulatory authority driving BRSR framework design and enforcement
• ICAI (Institute of Chartered Accountants of India): standard setter for sustainability assurance in the Indian context
• BSE (Bombay Stock Exchange): operator of the BRSR digital reporting portal enabling structured data submission
• National Stock Exchange (NSE): publishes the Nifty ESG indices and promotes disclosure quality among listed companies
• Confederation of Indian Industry (CII): industry body supporting BRSR capacity building among member companies

Startups:

• Sinai Technologies: AI-powered carbon management platform with BRSR-aligned reporting and GSTN data integration
• TraceX Technologies: blockchain-based supply chain traceability platform supporting value chain BRSR Core reporting
• Greenjoules: climate accounting software with automated emissions factor mapping for Indian industrial sectors
• ESGRisk.ai: machine learning platform that scores BRSR filings for completeness and consistency

Investors and Research Organizations:

• Climate Policy Initiative India: research organization analyzing BRSR compliance quality and policy gaps
• Centre for Science and Environment (CSE): independent analysis of corporate environmental disclosures in India
• KPMG India: advisory firm supporting BRSR implementation and assurance readiness

Action Checklist

• Assess current BRSR filing completeness against BRSR Core indicators, prioritizing Scope 1, Scope 2, energy intensity, and water intensity metrics
• Map Scope 3 emissions categories material to your sector and establish data collection from top 10 suppliers and distributors by spend
• Evaluate GSTN-integrated reporting platforms to automate procurement-based emissions estimation for value chain reporting
• Engage qualified assurance providers early, as the pool of experienced sustainability assurance practitioners in India is limited
• Develop at least one quantified climate scenario analysis covering physical and transition risks over a 10 to 20-year horizon
• Benchmark emissions intensity metrics against sector peers using BSE portal data and international datasets (World Steel Association, GCCA, IEA)
• Build internal capacity for sustainability data management, including designated data owners at each reporting entity or site
• Monitor SEBI regulatory updates, particularly the expected alignment with ISSB IFRS S1 and S2 standards anticipated for FY 2027-28

FAQ

Q: How does India's BRSR compare to the EU CSRD in scope and rigor? A: BRSR covers a broader set of sustainability topics (nine principles spanning environment, social, and governance) but with less prescriptive detail on any single dimension compared to CSRD's European Sustainability Reporting Standards (ESRS). CSRD requires double materiality assessment; BRSR does not explicitly mandate this but includes both financial and impact metrics. CSRD's assurance requirements start at limited assurance and escalate; India's BRSR Core begins with reasonable assurance for the top 150, a higher initial bar. However, CSRD's sector-specific standards (expected from 2026) will provide significantly more granular reporting requirements than BRSR currently contemplates.

Q: Are Indian companies that export to the EU affected by both BRSR and CSRD? A: Yes, potentially. Indian companies with EU revenues exceeding EUR 150 million are expected to fall within CSRD's extraterritorial scope from 2028-29. Companies like Tata Steel (which operates the Port Talbot plant in the UK and IJmuiden plant in the Netherlands), Infosys, and Wipro will need to reconcile BRSR and CSRD reporting requirements. The practical approach for most companies is to build a unified data collection infrastructure and map outputs to both frameworks, using ISSB standards as the common denominator where possible.

Q: What is the penalty for non-compliance with BRSR in India? A: SEBI can impose penalties under the SEBI Act and listing regulations, including fines of up to INR 25 crore (approximately $3 million) per violation, suspension of trading, and delisting proceedings. In practice, SEBI has focused on engagement rather than enforcement during the initial implementation phase. However, SEBI issued show-cause notices to 12 companies in 2025 for material omissions in BRSR filings, signaling a shift toward active enforcement (SEBI, 2025).

Q: How should multinational companies operating in India approach BRSR reporting for their Indian subsidiaries? A: Multinational subsidiaries listed in India must comply with BRSR independently of parent-company reporting under CSRD, SEC rules, or other frameworks. The most efficient approach is to integrate BRSR data requirements into the global reporting data collection process, adding India-specific metrics (particularly water stewardship and waste management categories that may not be covered by global frameworks) as supplementary data fields. Several multinationals, including Unilever India (Hindustan Unilever) and Siemens India, have published standalone BRSR filings that cross-reference their parent company's global sustainability reports.

Sources

• Centre for Science and Environment. (2025). State of Corporate Environmental Disclosure in India: BRSR Analysis 2024-25. New Delhi: CSE.
• Global Carbon Project. (2025). Global Carbon Budget 2024. Earth System Science Data.
• National Securities Depository Limited. (2025). Foreign Portfolio Investment: Monthly Data Bulletin, March 2025. Mumbai: NSDL.
• Climate Policy Initiative. (2025). Scope 3 Reporting Quality in Indian Corporate Climate Disclosures. New Delhi: CPI India.
• Confederation of Indian Industry. (2025). Supply Chain Sustainability Readiness Survey: BRSR Value Chain Reporting. New Delhi: CII.
• KPMG India. (2025). Sustainability Assurance Landscape in India: Capacity, Quality, and Market Development. Mumbai: KPMG.
• Reliance Industries Limited. (2025). Business Responsibility and Sustainability Report FY 2024-25. Mumbai: RIL.
• Bombay Stock Exchange. (2026). BRSR Reporting Portal: Annual Summary and Data Quality Assessment. Mumbai: BSE.
• SEBI. (2025). Circular on Enhanced Enforcement of Business Responsibility and Sustainability Reporting Requirements. Mumbai: SEBI.