SEBI has expanded mandatory BRSR Core assurance to the top 250 listed companies from FY2024—25. If your company is within that universe, you need a third-party assurance engagement in place before your annual report is filed. Here is what BRSR Core requires, what changes from FY2023—24, and how to prepare your assurance provider.
What is BRSR Core?
BRSR (Business Responsibility and Sustainability Report) is a SEBI-mandated disclosure framework for listed companies aligned to India's National Guidelines on Responsible Business Conduct (NGRBC). Within BRSR, SEBI designated a subset of 49 Key Performance Indicators (KPIs) as "BRSR Core" — and made their third-party assurance mandatory for the top listed companies.
SEBI's phased rollout: who must comply when
- Top 150 listed entities — BRSR Core assurance mandatory from FY2023—24 (reports published in 2024)
- Top 250 listed entities — mandatory from FY2024—25 (reports published in 2025)
- Top 500 listed entities — expected from FY2025—26 (subject to SEBI confirmation)
- Top 1000 listed entities — BRSR main report (without Core assurance) mandatory from FY2022—23
The 49 BRSR Core KPIs: what they cover
The 49 KPIs are drawn from Principles 1, 3, 4, 6, and 8 of the NGRBC and cover three ESG categories:
- Environmental (E) — GHG emissions (Scope 1 & 2 in CO2 equivalent), energy intensity, water intensity and withdrawal, waste management metrics, and extended producer responsibility compliance
- Social (S) — employee well-being metrics (median wages, safety statistics, training hours), supply chain disclosures (supplier assessments on safety & labour practices), and community development expenditure
- Governance (G) — percentage of business value chain assessed for ESG, details of fines/penalties from regulators, and related party transactions in the value chain
The KPIs are quantitative — which means they require underlying data collection systems, not just narrative disclosures. Many companies in the top 250 are not yet collecting data at the required granularity.
Assurance levels: limited vs reasonable
SEBI requires "reasonable assurance" or "limited assurance" — the company may choose. The practical distinction:
- Limited assurance — lower cost, less invasive. The assurance provider obtains sufficient evidence to conclude that nothing has come to attention to indicate material misstatement. Negative assurance opinion ("nothing came to attention").
- Reasonable assurance — higher standard, more evidence-intensive. Positive assurance opinion ("the KPIs are fairly presented in all material respects"). Required by some institutional investors and ESG rating agencies.
Companies seeking strong ESG ratings or institutional capital should aim for reasonable assurance from the outset.
Who can provide BRSR Core assurance?
SEBI's BRSR framework permits assurance by:
- Statutory auditors (Chartered Accountants)
- Independent assurance providers who meet specified competency requirements
Companies should note that SEBI's auditor independence norms apply — the assurance provider may not be the same as the statutory auditor in all configurations. We recommend using a separate BRSR assurance provider to maintain clear independence and avoid creating dual-role audit risk.
How to prepare: an engagement checklist
For companies in the top 250 preparing for FY2024—25 BRSR Core assurance:
- Data readiness — establish collection systems for all 49 KPIs by April 2025 (start of FY2025). Many companies are missing Scope 2 emissions data and supply chain safety assessment records.
- Appoint the assurance provider early — engage your BRSR assurance provider by Q2 of FY2025 so they can attend data collection and identify gaps before year-end
- Internal review — conduct a dry-run internal BRSR Core review against the prior year report to identify KPIs where data quality is weak
- Scope 3 readiness — SEBI has not yet mandated Scope 3 emissions, but the top companies are voluntarily including it; prepare to do so
- Supply chain data — begin supplier ESG assessment surveys; the KPIs require data on the percentage of supply chain screened for safety and labour practices
DeccanBridge BRSR Core assurance
Our India assurance team provides BRSR Core limited and reasonable assurance for listed companies from our two Telangana centres for clients across India. We assign a dedicated ESG partner — separate from your statutory audit team — and provide early data gap analysis before year-end to prevent assurance qualification.
Contact: connect@deccanbridge.com or +91 94922 01497.