BRSR Series. Part 2: BRSR Core Audits

With BRSR Core audits set to expand from the Top 500 to the Top 1,000 listed companies in FY 2026–27, the compliance landscape for Indian corporates is shifting in ways that demand more than last-minute preparation. For senior leadership - particularly CFOs, Chief Sustainability Officers, and Company Secretaries - this expansion is not simply a regulatory milestone. It is an inflection point that separates companies building genuine sustainability infrastructure from those still treating ESG as a reporting exercise.

This article breaks down everything you need to know: who is covered, what the audit actually examines and how the verification process works

The BRSR Core: A Subset Built for Assurance

The full BRSR covers nine Principles under India's National Guidelines for Responsible Business Conduct. BRSR Core is a curated, standardised, assurance-ready subset of this broader framework — a focused set of KPIs selected for their materiality, measurability, and cross-sector comparability. It is designed to be reported and assured consistently across industries, making it a practical tool for benchmarking and portfolio-level ESG analysis without the burden of assuring the entire BRSR.

The Nine Attributes of BRSR Core

🌿Environmental Indicators

1. GHG Footprint — Total Scope 1 (direct) and Scope 2 (purchased energy) emissions in CO₂ equivalent, measured per the GHG Protocol, along with GHG emission intensity normalised by revenue and output.

2. Water Footprint — Total water consumption (water permanently removed from the ecosystem, distinct from gross withdrawal), water intensity by revenue and output, and water discharge by destination and level of treatment.

3. Energy Footprint — Total energy consumption across all sources, the share of renewables as a percentage of total energy consumed, and energy intensity normalised by revenue and unit of output.

4. Waste Management and Circularity — Waste generated across eight regulated categories (plastic, e-waste, bio-medical, construction, battery, radioactive, hazardous, and non-hazardous), along with waste intensity, quantities recovered through recycling or reuse, and disposal by method.

🦺Social Indicators

5. Employee Wellbeing and Safety — Wellbeing spend as a percentage of revenue (covering health, accident, and maternity benefits, and mental health support), plus safety performance through LTIFR, permanent disabilities, and fatalities — covering both permanent employees and contract workers.

6. Gender Diversity — Gross wages paid to female employees as a percentage of total wages, and POSH complaints disclosed by total received, percentage of female workforce, and complaints upheld.

7. Enabling Inclusive Development — Input material sourced from MSMEs within India as a percentage of total purchases, and wages paid in smaller towns (per RBI classification) as a percentage of total wage cost.

⚖️Governance Indicators

8. Fairness in Engaging with Customers and Suppliers — Customer data breaches as a percentage of total cybersecurity events, and number of days of accounts payable as a measure of supplier payment fairness.

9. Openness of Business — Concentration of purchases and sales with trading houses, dealers, and related parties, and the share of related party transactions in purchases, sales, loans, and investments — verified against RPT disclosures audited by the financial auditors.

Who Is Covered? The Glide Path Explained

SEBI introduced BRSR Core assurance/assessment on a phased basis, structured by market capitalisation ranking:

Financial Year	Companies Required to Obtain BRSR Core Assurance/ Assessment
FY 2023–24	Top 150 listed companies
FY 2024–25	Top 250 listed companies
FY 2025–26	Top 500 listed companies
FY 2026–27	Top 1,000 listed companies

Rankings are based on average market capitalisation from 1 July to 31 December, published on 31 December by all recognised stock exchanges. Companies ranked between 501 and 1,000 will be subject to BRSR Core assurance for the first time in FY 2026–27 — requiring new data systems, internal accountability structures, and third-party assurance engagement. The time to prepare is not Q4 of FY 2026–27. It is now.

Assessment vs. Assurance: Understanding the Distinction

Assessment refers to third-party evaluation under standards developed by the Industry Standards Forum (ISF), formed in consultation with SEBI specifically for this purpose. It is an alternative to rigorous third-party "reasonable assurance“ which are guided assurance standards and generally more elaborate in their procedures.

Assurance refers to the broader professional practice of expressing a conclusion on the reliability of reported information. It is more comprehensive in scope, procedures and level of assurance obtained.

The industry norm for BRSR Core is reasonable assurance — the higher of the two standard levels — providing a positive-form conclusion comparable in rigour to a statutory audit.

Both assessment & assurance satisfy the verification requirement. The choice depends on stakeholder expectations, internal data readiness, and whether the company has international investors or cross-border supply chains that would benefit from alignment with globally recognised standards. Companies early in their ESG data journey may find a phased approach — starting with assessment and building toward reasonable assurance — more sustainable.

Applicable Standards

SEBI's framework is deliberately standard-agnostic. In practice, three standards dominate:

ISAE 3000 — the global benchmark for assurance on non-financial information, issued by the IAASB.

SSAE 3000 — issued by the ICAI, a sustainability-specific assurance standard building on ISAE 3000 principles.

SAE 3410 — issued by the ICAI, designed specifically for assurance on greenhouse gas statements, particularly relevant for the GHG Footprint attribute and carbon-intensive sectors.

Who Can Conduct the Audit?

Any provider must satisfy two conditions: independence (no conflict of interest with the entity) and competence (technical expertise across sustainability measurement, data verification, and applicable standards). BRSR Core assurance is explicitly profession-agnostic — not restricted to Chartered Accountants. Sustainability consultants, environmental engineers, accredited ESG auditors, and specialist advisory firms are all eligible. The statutory auditor may conduct the engagement; the internal auditor may not, as structural proximity to the organisation makes genuine independence impossible.

How Esgity Advisors Can Help

At Esgity Advisors, we work with listed companies across sectors to navigate the practical and strategic dimensions of BRSR compliance and ESG disclosure. Our services span BRSR Core gap assessments, ESG data systems design, assurance readiness preparation, and stakeholder communication strategy.

If your organisation is approaching the BRSR Core assurance requirement for the first time — or looking to significantly improve the quality of your existing process — we would welcome the conversation.

📩 Get in touch: info@esgityadvisors.com

This article is part of the Esgity Advisors BRSR Series, which breaks down India's sustainability reporting framework one post at a time. Follow us for Post 3: Value Chain Partners