India’s First Full BRSR Core Assurance Cycle: What We Learned
FY 2025-26 was the first year that BRSR Core assurance became mandatory for India’s top 150 listed companies under SEBI’s phased implementation schedule. As annual reports are filed and assurance statements are submitted, the experience of this inaugural cycle reveals important lessons for the next wave of companies.
Common Non-Conformances
Assurance providers across the market have identified recurring patterns in the gaps that companies struggle with:
- Scope 3 emissions incompleteness: Many companies reported only one or two Scope 3 categories, despite having material emissions across upstream supply chains, employee commuting, and business travel. BRSR Core requires disclosure of emissions intensity, and incomplete Scope 3 data undermines the credibility of the reported figure.
- Employee and worker metrics inconsistencies: BRSR requires detailed breakdown of employees, workers, and differently-abled persons across permanent, temporary, and contractual categories. Discrepancies between HR records, payroll systems, and sustainability reports were among the most common data quality issues.
- Energy data reconciliation failures: Energy consumption data reported in BRSR frequently could not be reconciled with utility bills, internal metering, or energy audit reports. This is a fundamental data governance failure that undermines assurance.
- Governance disclosures lacking specificity: Sustainability governance sections often described committee structures in generic terms without specifying meeting frequency, agenda items reviewed, or board-level oversight mechanisms.
The Next Wave: Top 500 Companies for FY 2026-27
SEBI’s phased rollout means that the top 500 listed companies by market capitalisation must file BRSR Core with assurance for FY 2026-27. This next cohort includes mid-cap companies that typically have less mature ESG data governance systems than the Nifty 50 and Next 50 constituents who filed first.
Companies in this bracket should not wait until the fourth quarter to begin preparation. The lessons from the first cycle are clear: data governance must be addressed structurally, not as a last-minute compliance exercise.
How to Prepare: A Practical Checklist
- Appoint a BRSR owner: Designate a senior leader responsible for BRSR data collection across functions (HR, operations, EHS, finance, supply chain)
- Map data sources: For each BRSR Core attribute, identify the source system, data owner, and update frequency. Build a data register.
- Internal dry run: Conduct an internal readiness assessment against BRSR Core attributes before engaging an external assurance provider
- Choose assurance level early: Limited assurance (the current SEBI requirement) and reasonable assurance have different evidence requirements. Understand what your assurance provider will need.
- Engage the board: Ensure the board’s audit committee or sustainability committee has BRSR assurance on its agenda well before the filing deadline
RSustain’s BRSR Core Assurance Capability
RSustain is an AA1000-licensed assurance provider with hands-on experience in BRSR Core assurance for Indian listed companies. Our assurance sprint programme takes companies from compliance gap assessment to assurance-ready filing in a structured 12-week engagement, combining data governance support with independent assurance under AA1000 and ISAE 3000.
For companies in the next-500 cohort, early engagement ensures that data systems are fit for purpose before the filing deadline creates unnecessary pressure.