SEBI BRSR Core Assurance: 9 KPIs & Circular Rules

Since financial year 2022-23, India's top 1,000 listed entities by market capitalization have been required to file the Business Responsibility and Sustainability Report (BRSR). However, the transition from voluntary self-disclosure to mandatory external audit began with SEBI Circular `SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122`, issued on 12 July 2023.

The circular created the BRSR Core: a sub-set of 9 measurable, auditable Environmental, Social, and Governance (ESG) attributes designed to provide capital markets with verifiable sustainability metrics. For listed companies, understanding the exact data points and assurance expectations is now a mandatory governance priority under our BRSR Core software module.

The Mandatory Glide Path for Listed Entities

SEBI structured the rollout of BRSR Core assurance across four financial years to allow the market to build audit capacity:

In March 2025, SEBI issued Circular `SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42`, which modified the terminology from strict 'assurance' to 'assessment or assurance'. This enables companies to engage accredited third parties under standards formulated by the Industry Standards Forum (ISF) representing ASSOCHAM, CII, and FICCI.

The 9 BRSR Core Attributes and Their Specific KPIs

Under Annexure I of the July 2023 circular, the BRSR Core establishes clear, quantifiable key performance indicators across 9 parameters:

1. Green-house Gas (GHG) Footprint: Metric tonnes of CO2 equivalent for Scope 1 (direct) and Scope 2 (purchased electricity). Requires mandatory reporting of GHG intensity per rupee of turnover and intensity per physical unit of production.
2. Water Footprint: Total water consumed in kilolitres, water intensity per rupee of turnover, and percentage of water discharged into surface water or recycled.
3. Energy Footprint: Total energy consumption in gigajoules (GJ), ratio of renewable energy to total energy, and energy intensity per rupee of turnover.
4. Waste Management & Circularity: Total waste generated across hazardous and non-hazardous categories, proportion sent for recycling, and zero-waste-to-landfill metrics.
5. Employee Well-being & Safety: Spending on employee well-being, lost time injury frequency rate (LTIFR), and gross wages paid to female employees.
6. Gender Diversity in Workforce: Ratio of female employees to total workforce, and median remuneration parity between male and female employees.
7. Inclusive Development: Purchases made from Micro, Small, and Medium Enterprises (MSMEs), and percentage of procurement from suppliers in Tier 2 and Tier 3 cities under Scope 3 value chain tracking.
8. Fair Business Conduct: Percentage of input credits reconciled, statutory dues paid on time, and trading days taken to settle vendor invoices.
9. Openness of Business: Number of consumer complaints received and resolved, and disclosures regarding regulatory penalties.

What External Assurance Providers Actually Test

Under the Institute of Chartered Accountants of India (ICAI) Standard on Sustainability Assurance Engagements (SSAE 3000), assurance providers must establish an unbroken trail from the reported number back to primary evidence.

Specifically, auditors evaluate four control parameters:

• Completeness of Boundary: Ensuring all operational manufacturing sites, branch offices, and warehouses under operational control are included in the inventory.
• Factor Lineage: Confirming that emission factors cite specific editions of statutory sources (e.g., CEA Baseline Database v20.0 or IPCC Sixth Assessment Report GWP values).
• Cut-off Accuracy: Ensuring invoices spanning month-ends or fiscal year-ends are accurately prorated to 31 March.
• Data Integrity Controls: Verifying that data extraction from physical bills into the sustainability reporting register includes role-based access logs and sign-off records.

Internal Controls Needed Before Undergoing Assurance

For mid-cap listed companies entering mandatory assurance for the first time, readiness begins with three institutional changes:

1. Centralizing Document Ingestion: Establishing an enterprise repository where plant-level diesel slips, e-way bills, and electricity bills are scanned and catalogued monthly, rather than scrambled for at year-end.
2. Eliminating Spreadsheet Macro Calculators: Replacing unversioned Excel workbooks with deterministic engines that lock input data and calculation logs.
3. Engaging Assurers Early: Appointing an assurance provider by Q2 of the financial year to conduct an interim pre-assurance walk-through, identifying documentation gaps before fiscal year close.

How ZeroCarbon Prepares BRSR Core Filings

ZeroCarbon automates BRSR Core data collection by reading primary utility bills and ERP purchase ledgers directly into our enterprise carbon accounting platform. Our engine extracts the physical units required by SEBI Annexure I, maps them to CEA and IPCC factors deterministically, and prepares audit-ready workpapers where every single figure links to its underlying PDF document and approval signature.