BRSR Reporting in India and Foreign Owned Subsidiaries (2026)

Written by CA Nandini Hasija, Krystal7 Consultants. Last updated 23 October 2026.

BRSR reporting is mandatory only for the top 1,000 listed entities by market capitalisation. The duty sits in regulation 34(2)(f) of the SEBI LODR Regulations, and SEBI's circular of 10 May 2021 sets the top 1,000 rule. An unlisted foreign owned Indian subsidiary files no BRSR of its own. It still gets pulled in. From FY 2025-26 the top 250 listed entities may report BRSR Core data for value chain partners, each at 2 percent or more of purchases or sales. An EU parent in CSRD scope also needs the subsidiary's data.

This guide covers who files BRSR and BRSR Core, the value chain rules and how an EU parent's CSRD reporting reaches India. It also covers the overlap with CSR and the data an Indian subsidiary should collect. It states the position on 28 Mar 2026 and adds what has changed since.

Does BRSR reporting apply to a foreign owned subsidiary in India?

Only if the subsidiary is itself listed and ranks in the top 1,000 by market capitalisation. SEBI's circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 of 10 May 2021 set the rule. BRSR became "mandatory for the top 1000 listed companies (by market capitalization)" from FY 2022-23. Unlisted private companies sit outside SEBI's listing rules, so no BRSR duty attaches to them.

Foreign ownership changes nothing on either side of that line. A foreign owned Indian company listed on an Indian exchange and ranked in the top 1,000 files BRSR like any other listed entity. A wholly owned private subsidiary of a US, UK or EU parent does not.

That is the legal answer. The practical answer differs, because three routes bring BRSR style data requests to unlisted subsidiaries:

1. Indian listed customers that report on their value chain partners.
2. Indian listed customers that assess suppliers for BRSR leadership indicators.
3. A foreign parent or customer that reports under its own sustainability rules, such as the EU's CSRD.

What is BRSR, and how is it structured?

BRSR is the Business Responsibility and Sustainability Report. It replaced the older Business Responsibility Report from FY 2022-23, under paragraph 7 of the 2021 circular. Disclosures follow the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC). Essential indicators are mandatory and leadership indicators are voluntary (paragraph 4).

The updated BRSR format of July 2023 has three sections:

1. Section A, general disclosures (items 1 to 26): the entity, its products, operations, employees, subsidiaries, CSR and grievances.
2. Section B, management and process disclosures: policies, governance and oversight for each principle.
3. Section C, principle wise performance: essential and leadership indicators under each of the nine principles.

Principle	Short title	Examples of data asked
1	Ethics, transparency and accountability	Fines, anti corruption policy, value chain awareness programmes
2	Sustainable and safe goods and services	Research spending on sustainable products, sustainable sourcing
3	Wellbeing of employees, including value chains	Benefits, safety incidents, parental leave, value chain health and safety assessments
4	Respect for stakeholder interests	Stakeholder groups and engagement
5	Human rights	Minimum wages, complaints, value chain assessments on child labour and forced labour
6	Protection and restoration of the environment	Energy, water, Scope 1 and Scope 2 emissions, waste; Scope 3 as a leadership indicator
7	Responsible public policy engagement	Trade association memberships
8	Inclusive growth and equitable development	Inputs sourced from MSMEs and small producers, CSR projects and beneficiaries
9	Responsible engagement with consumers	Consumer complaints, data privacy, product recalls

Item 13 of Section A asks whether the report covers the entity alone (standalone) or all entities in its consolidated financial statements. Item 23 lists holding, subsidiary, associate and joint venture companies, and asks whether each takes part in the listed entity's business responsibility initiatives.

The 2021 circular also lets an entity that reports under GRI, SASB, TCFD or Integrated Reporting cross reference those disclosures to BRSR (paragraph 6). That helps a listed Indian subsidiary of a global group reuse group data.

How is the top 1,000 by market capitalisation decided?

Each stock exchange ranks listed entities at 31 December on their average market capitalisation from 1 July to 31 December. Regulation 3(2) of the LODR Regulations sets this rule, as amended up to 22 Jan 2026. Provisions apply from 1 April after the ranking, or from the next financial year, whichever is later.

Once BRSR applies, it continues until the entity stays outside the threshold for three consecutive years, under regulation 3(2A). Regulation 3(2B) then ends the duty at the end of the following financial year. So one bad year in the share price does not switch BRSR off.

For a listed foreign owned company near the cut off, this means planning a year ahead. The ranking at 31 Dec 2025 decides who reports BRSR for FY 2026-27. We ask clients near the line to build the data systems before the ranking, not after it.

What is BRSR Core, and who needs assessment or assurance?

BRSR Core is a subset of BRSR indicators across nine ESG attributes. SEBI introduced it by circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 of 12 Jul 2023. That circular required "reasonable assurance" of the BRSR Core on a glide path by market capitalisation. The circular of 28 Mar 2025 allowed "assessment or assurance" instead.

The 2023 circular added indicators suited to India, such as job creation in small towns, openness of business and gross wages paid to women (paragraph 3.1). It bases intensity ratios on "revenue adjusted for Purchasing Power Parity (PPP)". From FY 2023-24 the top 1,000 listed entities report in the updated format (paragraph 3.4.1).

Financial year	Listed entities needing BRSR Core assessment or assurance	Value chain disclosures	Value chain assessment or assurance
FY 2023-24	Top 150	Not applicable	Not applicable
FY 2024-25	Top 250	Deferred by the 2025 circular	Not applicable
FY 2025-26	Top 500	Voluntary for the top 250	Not applicable
FY 2026-27	Top 1,000	Voluntary for the top 250	Voluntary

The 2025 circular, SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, made verification "profession agnostic" (paragraph 3.3). Assessment means a third party check under standards that the Industry Standards Forum (ISF) develops "in consultation with SEBI" (paragraph 3.4). The LODR FAQs of April 2025 answer the common questions on providers.

1. The provider need not be a chartered accountant. The board ensures that it has the necessary sustainability expertise.
2. The statutory auditor may give assurance, subject to competence and independence. The internal auditor may not.
3. No standard is mandated. ISAE 3000, ISSA 5000 or ICAI's SSAE 3000 may be used, and the provider discloses which.
4. Any non audit or non assurance service, such as consulting, to the listed entity or its group breaks independence.
5. The group means the holding company, subsidiaries, associates and joint ventures.

The independence rule reaches foreign groups. If a listed Indian company's provider consults for its foreign parent, the provider is out. A global group should check this before it appoints one firm for both roles.

Which value chain partners does BRSR cover?

From FY 2025-26, a value chain partner is an upstream or downstream partner with 2 percent or more of the listed entity's purchases or sales by value. The top 250 listed entities may disclose BRSR Core data for them on a voluntary basis. Paragraph 3.11 of the 2025 circular sets the definition.

The 2023 circular had a different design. Paragraph 4.1 defined the value chain as the top partners that together made up 75 percent of purchases or sales by value. Disclosure was to start on a comply or explain basis for FY 2024-25, with limited assurance on the same basis from FY 2025-26 (paragraph 4.4). The 2025 circular deferred both by one year and made them voluntary.

The 2025 rules keep 75 percent as an option. A listed entity may limit its value chain disclosure to partners that cover 75 percent of purchases and sales by value. It must then disclose the percentage it covers. For the first year, prior year figures are voluntary, so FY 2025-26 reports need not show FY 2024-25 data (paragraph 3.14).

Paragraph 4.2 of the 2023 circular matters most to a supplier. The KPIs are reported "to the extent" they are attributable to the listed entity's business with that partner. So the customer wants the share of the supplier's footprint that relates to its own orders, not the supplier's whole footprint.

How does an unlisted Indian subsidiary get pulled into BRSR?

Through its customers and its parent. A listed Indian customer may ask for BRSR Core data if the subsidiary is a value chain partner. Even below 2 percent, a customer may assess suppliers for leadership indicators under Principles 3, 5 and 6. A foreign parent may need the subsidiary's data for its own group report.

Route	What triggers it	What the subsidiary is asked for	Legal force on the subsidiary
Value chain disclosure by a top 250 listed customer	Sales to that customer at 2% or more of its purchases	BRSR Core KPIs attributable to that customer	None directly; contractual if the customer writes it into supply terms
Supplier assessment by any BRSR filer	Customer reporting the percentage of value chain partners it assessed	Questionnaires or audits on safety, human rights and environment	Contractual
Group sustainability report of the foreign parent	Parent in scope of the CSRD or another regime	Group template data for consolidation	Internal; the parent's law binds the parent
Sustainability report of an EU customer	Customer in CSRD scope	Value chain data, subject to the value chain cap	Contractual, limited by the cap
Lenders and investors	Loan covenants or investor ESG policies	Policies, incidents, emissions	Contractual

The leadership indicators that reach suppliers are specific. Under Principle 3, a filer reports the percentage of value chain partners it assessed for health and safety and working conditions. Principle 5 asks the same for sexual harassment, discrimination, child labour, forced labour and wages. Principle 6 asks it for environmental impacts.

So the request a subsidiary sees often looks like a supplier code of conduct and a questionnaire. Our view is to answer it from records the subsidiary already keeps for Indian law. The POSH annual report, wage registers under the labour codes and pollution consents cover most of it.

How does an EU parent's CSRD reporting reach an Indian subsidiary?

The CSRD is Directive (EU) 2022/2464. An EU parent in its scope reports a group sustainability statement that covers its subsidiaries, including any in India. The Indian subsidiary has no EU filing of its own. It supplies data through the parent's group reporting process, much as it supplies figures for the group accounts.

The EU has cut back the CSRD since 2025. The "stop the clock" Directive, Directive (EU) 2025/794 of 14 Apr 2025, postponed reporting "by two years". It covers large companies not yet reporting and listed SMEs. It entered into force on 17 Apr 2025. The Council's release gives the detail.

The Commission proposed the Omnibus I package on 26 Feb 2025, to apply the CSRD only to companies with more than 1,000 employees. The Parliament and the Council reached a political agreement on 9 Dec 2025. The result is Directive (EU) 2026/470 of 24 Feb 2026. It appeared in the Official Journal on 26 Feb 2026 and entered into force on 18 Mar 2026.

The amended scope has three tests:

1. An EU undertaking reports if, on its balance sheet date, it exceeds both EUR 450 million net turnover and an average of 1,000 employees.
2. A non EU group reports if its EU net turnover exceeded EUR 450 million in each of the last two consecutive financial years.
3. That non EU group reports through an EU subsidiary or branch with a net turnover above EUR 200 million in the preceding financial year.

The same directive adds the value chain cap. A "protected undertaking" in a reporter's value chain has an average of no more than 1,000 employees. It may decline to provide information beyond the voluntary standards that the Commission adopts under the amended Accounting Directive.

EU measure	Date	Effect for an Indian subsidiary
CSRD, Directive (EU) 2022/2464	14 Dec 2022	EU groups in scope report data that covers Indian subsidiaries
Stop the clock, Directive (EU) 2025/794	14 Apr 2025; in force 17 Apr 2025	Two year delay for large companies not yet reporting and listed SMEs
Quick fix, Delegated Regulation (EU) 2025/1416	Adopted 11 Jul 2025; Official Journal 10 Nov 2025	Postpones some disclosure requirements for certain undertakings already reporting
VSME recommendation	30 Jul 2025	Voluntary standard for SMEs; a common template for supplier data
Omnibus I political agreement	9 Dec 2025	Fewer EU companies in scope; a value chain cap on data requests
Omnibus I, Directive (EU) 2026/470	24 Feb 2026; in force 18 Mar 2026	Scope of 1,000 employees and EUR 450 million turnover; suppliers with up to 1,000 employees may refuse excess requests

Two practical points follow. First, fewer EU parents will report, and many will report later than planned. Second, the value chain cap protects suppliers with up to 1,000 employees. A CSRD reporter cannot force them to give more than the voluntary standards cover.

For an Indian subsidiary, the cap applies where it supplies an unrelated EU customer and has no more than 1,000 employees on average. It does not limit what its own parent asks for group consolidation. A parent can always ask its subsidiary for data. Our note on the India EU free trade agreement covers the trade side of the same relationship.

What do US, UK and other parents usually ask for?

The parent's own rules decide. A parent that publishes a group sustainability or climate report asks each subsidiary for the same template data: energy, emissions, headcount, safety and governance facts. The Indian subsidiary's task is the same whatever the parent's law: produce reliable numbers on the group's timetable.

The timetable is the hard part. Many foreign parents close their sustainability data on a 31 December year end. An Indian subsidiary runs a 31 March year. Our note on a 31 March year end under a December parent explains how to bridge the two for the accounts. The same bridge works for ESG data if you capture it monthly.

We advise one data set, held monthly, that feeds three uses:

1. The parent's group template, on the calendar year if the parent needs it.
2. BRSR Core requests from Indian listed customers, on the April to March financial year.
3. Indian statutory reports, such as the board's report and CSR-2.

How does CSR overlap with BRSR?

They share data but answer different questions. CSR under section 135 of the Companies Act, 2013 is a spending duty for any company over a threshold, listed or not. BRSR is a disclosure duty for the top 1,000 listed entities. A foreign owned subsidiary can owe CSR without ever filing BRSR.

Section 135(1) applies on the immediately preceding financial year. The tests are net worth of INR 500 crore, turnover of INR 1,000 crore or net profit of INR 5 crore, each "or more". The company then spends at least 2 percent of its average net profits of the three preceding years under section 135(5). Our CSR applicability guide covers the rules in full.

Data item	CSR under section 135	BRSR	Who needs it from a foreign owned subsidiary
Turnover and net worth	Threshold test, section 135(1)	Section A, item 24	MCA through CSR-2; a listed customer rarely
CSR applicability (yes or no)	Section 135(1)	Section A, item 24	The board, the auditor and the parent
CSR spend and projects	Annual report on CSR in the board's report; CSR-2	Principle 8 leadership indicators	Parent group reporting
Beneficiaries, including vulnerable groups	Impact assessment where rule 8(3) applies	Principle 8, leadership indicator 6	Parent group reporting
Projects in aspirational districts	Not required	Principle 8, leadership indicator 2	Rarely asked of subsidiaries
Inputs sourced from MSMEs	MSME Form 1 tracks late payments, not sourcing	Principle 8, essential indicator 4	A listed customer reporting its own sourcing

The penalty for missing a CSR transfer under section 135(7) is twice the amount or INR 1 crore, whichever is less, on the company. Each officer in default faces one tenth of the amount or INR 2 lakh, whichever is less. BRSR has no penalty for unlisted suppliers, because it does not bind them. Supplier payment data sits in a different return: see our note on MSME Form 1 and the 45 day rule.

What data should an Indian subsidiary collect?

Collect the data that BRSR Core and a group template both ask for, from records you already keep under Indian law. Monthly capture from source documents works best. Each item below maps to a BRSR indicator, so a listed customer or a parent can use it without rework.

Data item	Source in the Indian subsidiary	BRSR reference	Usually asked by
Electricity, fuel and renewable energy used (kWh, litres)	Electricity bills, diesel generator logs, fuel invoices	Principle 6, essential indicator 1	Listed customer; parent
Scope 1 and Scope 2 emissions (tCO2e)	Energy data with emission factors the customer or parent accepts	Principle 6, essential indicator 7	Listed customer; parent
Water withdrawn and discharged (kilolitres)	Water bills, meter readings, pollution board consents	Principle 6, essential indicators 3 and 4	Listed customer (water stressed sites)
Waste by category, recycled and disposed (tonnes)	Waste manifests, authorised recycler receipts	Principle 6, essential indicator 9	Listed customer; parent
Headcount by gender, permanent and other workers	Payroll and contractor registers	Section A, items 20 to 22	Parent; listed customer
Safety incidents, injuries and fatalities	Incident register under the OSH Code	Principle 3	Listed customer; parent
Sexual harassment complaints and outcomes	Internal Committee annual report	Principle 5	Listed customer
Minimum wage compliance	Wage registers under the Code on Wages	Principle 5	Listed customer
Purchases from MSMEs and from within India (INR)	Vendor master with Udyam numbers, purchase ledger	Principle 8, essential indicator 4	Listed customer
CSR spend, projects and beneficiaries	CSR-2, board's report, implementing agency reports	Section A, item 24; Principle 8	Parent
Sales to each listed customer (INR)	Sales ledger	Value chain test of 2% or more	Listed customer

Keep the evidence behind each number in one folder. An assessor of the listed customer, or the parent's auditor, will ask for it. Our guide to financial reporting for foreign subsidiaries covers the finance calendar that this data runs beside.

What has changed since 28 Mar 2026?

We found no SEBI circular or LODR amendment on BRSR dated between 28 Mar 2026 and 23 Oct 2026. The consolidated LODR text on sebi.gov.in is amended up to 22 Jan 2026. SEBI's board meeting of 17 Dec 2025 took no BRSR decision. Check the circulars list on sebi.gov.in before you rely on this. FY 2026-27 began on 1 Apr 2026, so the top 1,000 now need BRSR Core assessment or assurance for FY 2026-27.

Three changes outside SEBI matter to subsidiaries:

1. On 27 May 2026 the MCA notified G.S.R. 415(E) and G.S.R. 416(E). They add item (xiii) to Schedule VII: subscription to zero coupon zero principal instruments on a Social Stock Exchange. Spending on these is capped at 10 percent of a company's CSR spend for the year (PIB release of 29 May 2026).
2. On 3 Jul 2026 the European Commission adopted revised ESRS that cut mandatory datapoints by "over 60%". It also adopted a voluntary standard for undertakings protected by the value chain cap. Both apply after a two month scrutiny period, which can be extended by two months.
3. On 23 Oct 2026 the Commission's delegated acts page said neither July 2026 act was in force until published in the Official Journal. Until then, the value chain cap in Directive (EU) 2026/470 has no adopted standard in force to measure requests against.

What changed in 2026

The SEBI framework for FY 2025-26 and FY 2026-27 was set before 2026, by the circular of 28 Mar 2025. The 2026 changes sit in the dates those rules reach, in CSR and in EU law. The CSRD rows and the LODR row date from before 28 Mar 2026, the publish date of this guide. The other rows came after it.

Area	Old position	New position	Date	Instrument
BRSR Core assurance	Top 500 for FY 2025-26	Top 1,000 for FY 2026-27	From 1 Apr 2026	SEBI circular of 28 Mar 2025, paragraph 3.6
Value chain assessment or assurance	Not available	Voluntary for the top 250	From FY 2026-27	SEBI circular of 28 Mar 2025, paragraph 3.13
LODR text	Amended to 2025	Amended up to 22 Jan 2026; no BRSR change found	22 Jan 2026	LODR Regulations, consolidated text on sebi.gov.in
CSR Schedule VII	Twelve items	Item (xiii) added for Social Stock Exchange instruments, capped at 10% of CSR spend	27 May 2026	G.S.R. 415(E) and 416(E)
CSRD scope	Large undertakings and listed SMEs, in waves from FY 2024	Above 1,000 employees and EUR 450 million turnover; non EU groups above EUR 450 million EU turnover with an EU subsidiary or branch above EUR 200 million	In force 18 Mar 2026	Directive (EU) 2026/470 of 24 Feb 2026
CSRD value chain requests	No cap	Suppliers with up to 1,000 employees may decline requests beyond the voluntary standards	In force 18 Mar 2026	Directive (EU) 2026/470 of 24 Feb 2026
EU reporting standards	ESRS of 2023, with the 2025 quick fix	Revised ESRS; voluntary standard for the value chain cap	Adopted 3 Jul 2026; not in force on 23 Oct 2026	Commission delegated acts

Worked example

Kestrel Components India Private Limited (Kestrel India) is a wholly owned subsidiary of a German group. In FY 2025-26 its turnover is INR 300 crore. It sells INR 120 crore of parts to Banyan Motors Limited, a listed Indian company in the top 250. Banyan's total purchases for the year are INR 4,000 crore.

Is Kestrel India a value chain partner?

Step	Working	Result
Kestrel's share of Banyan's purchases	120 / 4,000 x 100	3.0%
Threshold under the 2025 circular	2% or more	Kestrel qualifies
Kestrel's share of its own sales to Banyan	120 / 300 x 100	40%
Kestrel's Scope 1 and Scope 2 emissions for the year	Measured from fuel and electricity records	1,500 tCO2e
Emissions attributable to Banyan, allocated by revenue	1,500 x 40%	600 tCO2e
Kestrel's electricity use	Meter readings	18,00,000 kWh
Electricity attributable to Banyan, allocated by revenue	18,00,000 x 40%	7,20,000 kWh

Banyan's value chain disclosure is voluntary for FY 2025-26. If Banyan chooses to make it, Kestrel is in scope at 3 percent. Allocation by revenue is one method; allocation by units or machine hours may suit a plant better. Agree the method with the customer in writing, and use it every year.

Does Kestrel India owe CSR?

Kestrel's net profits for the three preceding years were INR 6 crore, INR 8 crore and INR 10 crore. Net profit of INR 10 crore in the immediately preceding year crosses the INR 5 crore test in section 135(1). Its average net profit is (6 + 8 + 10) / 3 = INR 8 crore. The minimum CSR spend under section 135(5) is 2 percent of INR 8 crore, which is INR 16 lakh.

INR 16 lakh is below INR 50 lakh, so section 135(9) lets the board act in place of a CSR Committee. Kestrel's CSR-2 data also answers the German parent's social metrics request. One set of records serves both.

Common mistakes

1. Assuming BRSR binds an unlisted subsidiary. It does not, and some subsidiaries spend on full BRSR reports nobody asked for. Fix: find out which customer or parent needs which indicators, then collect those.
2. Ignoring the 2 percent test. A subsidiary that supplies one listed customer heavily can be its value chain partner. Fix: ask each listed customer each year whether you fall in its 2 percent list.
3. Giving the whole company footprint to one customer. The circular asks for KPIs attributable to the business with that customer. Fix: agree an allocation method and state it with the numbers.
4. Collecting data once a year. Annual collection misses a December parent's deadline and an April to March BRSR year. Fix: capture energy, water, waste and headcount data monthly.
5. Mixing up CSR and BRSR. CSR is a spending duty under section 135 for any company over the threshold. Fix: test section 135 every year, whether or not anyone asks for ESG data.
6. Appointing a conflicted assurance provider. SEBI's independence test covers the whole group, including a foreign parent. Fix: check the provider's services to every group company before a listed group entity appoints it.
7. Treating the CSRD value chain cap as a shield against the parent. The cap limits what CSRD companies ask of their value chain. It does not limit group consolidation. Fix: plan to give the parent full group template data.

Checklist

1. List every Indian listed customer and its share of your sales.
2. Ask each listed customer if you count as a value chain partner at 2 percent or more of its purchases or sales.
3. Confirm in writing which BRSR Core indicators each customer needs and the allocation method.
4. Obtain the foreign parent's group sustainability template and timetable.
5. Record energy, fuel, water, waste and headcount data every month from bills and registers.
6. Calculate Scope 1 and Scope 2 emissions using emission factors the customer or parent accepts.
7. Keep safety incidents, POSH complaints, wage records and pollution consents in one evidence file.
8. Test section 135 thresholds on the preceding year's financial statements.
9. Reconcile CSR spend with the board's report and CSR-2 before you share it with the parent.
10. Check any assurance provider's services to the whole group for conflicts.
11. Review the data set each quarter with the finance team that prepares the MIS report for the parent.

We set up this data file within our company compliance service for foreign owned subsidiaries.

Frequently Asked Questions

Is BRSR mandatory for unlisted companies in India?+

No. BRSR is mandatory only for the top 1,000 listed entities by market capitalisation under regulation 34(2)(f) of the SEBI LODR Regulations and SEBI's circular of 10 May 2021. Unlisted private companies, including foreign owned subsidiaries, have no BRSR filing. They may still receive data requests from listed customers and their parent.

Who must file BRSR in India?+

The top 1,000 listed entities, ranked by each stock exchange on average market capitalisation from 1 July to 31 December. The report forms part of the annual report. Once in, an entity keeps reporting until it stays outside the top 1,000 for three consecutive years, under regulation 3(2A) of the LODR Regulations.

What is the difference between BRSR and BRSR Core?+

BRSR is the full report on the nine NGRBC principles, with essential and leadership indicators. BRSR Core is a subset of its indicators across nine ESG attributes, set by SEBI's circular of 12 Jul 2023. BRSR Core needs assessment or assurance on a glide path, reaching the top 1,000 listed entities for FY 2026-27.

Which companies need BRSR Core assurance for FY 2025-26?+

The top 500 listed entities by market capitalisation need assessment or assurance of BRSR Core for FY 2025-26. The top 1,000 need it from FY 2026-27. SEBI's circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42 of 28 Mar 2025 sets this glide path and allows assessment as an alternative to assurance.

What is a value chain partner under BRSR?+

An upstream or downstream partner that individually accounts for 2 percent or more of a listed entity's purchases or sales by value. SEBI set this test in its circular of 28 Mar 2025. The listed entity may limit disclosure to partners covering 75 percent of purchases and sales, and must state the coverage.

Are value chain disclosures mandatory?+

No. Under SEBI's circular of 28 Mar 2025, value chain disclosures are voluntary for the top 250 listed entities from FY 2025-26, and their assessment or assurance is voluntary from FY 2026-27. SEBI's FAQs say these relaxations continue unless SEBI changes them by a later circular or regulation.

Can a supplier refuse a listed customer's BRSR data request?+

Legally yes, unless the supply contract requires the data. BRSR binds the listed entity, not its suppliers. Commercially, refusing a large customer is rarely wise. We advise agreeing the indicators, the allocation method and a confidentiality clause, then answering from records you already keep.

Does the CSRD apply to an Indian subsidiary of an EU company?+

Not directly. Directive (EU) 2022/2464 places the reporting duty on the EU company. Where an EU parent is in scope, its group sustainability statement covers the Indian subsidiary, which supplies data through group reporting. Directive (EU) 2026/470, in force from 18 Mar 2026, limits reporting to undertakings above 1,000 employees and EUR 450 million turnover.

What is the CSRD value chain cap?+

A limit on what CSRD companies may demand from smaller companies in their value chain. Under Directive (EU) 2026/470, a supplier with an average of no more than 1,000 employees may decline requests beyond the voluntary standards, which the Commission adopted on 3 Jul 2026. The cap helps an Indian subsidiary supplying an unrelated EU customer, not one answering its own parent.

Does CSR spending count towards BRSR disclosures?+

Yes, in part. BRSR Section A item 24 asks whether section 135 applies, with turnover and net worth. Principle 8 leadership indicators ask about CSR projects in aspirational districts and beneficiaries. A subsidiary that files CSR-2 already holds most of this data for a listed customer or its parent.

Can the statutory auditor give BRSR Core assurance?+

Yes, subject to competence and independence, according to SEBI's LODR FAQs. The internal auditor cannot. The provider must not offer non audit or non assurance services, such as consulting, to the listed entity or any group company, which includes a foreign parent.

Does BRSR require Scope 3 emissions?+

Scope 3 emissions are a leadership indicator under Principle 6 of BRSR, so their disclosure is voluntary. Scope 1 and Scope 2 emissions, with intensity, are essential indicators. A supplier's own Scope 1 and Scope 2 emissions form part of its customer's Scope 3, which is why customers ask for them.

What ESG reports does an unlisted foreign owned subsidiary already file in India?+

None under the name ESG, but several overlap. The board's report covers energy conservation under section 134(3)(m) of the Companies Act, 2013. A company over the section 135 threshold files CSR-2. POSH annual reports, labour code registers and pollution consents supply most social and environmental data.

Sources

• Securities and Exchange Board of India, Business responsibility and sustainability reporting by listed entities, SEBI/HO/CFD/CMD-2/P/CIR/2021/562, 10 May 2021, https://www.sebi.gov.in/sebi_data/attachdocs/may-2021/1620655793598.pdf
• Securities and Exchange Board of India, BRSR Core: framework for assurance and ESG disclosures for value chain, SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122, 12 Jul 2023, https://www.sebi.gov.in/sebi_data/attachdocs/jul-2023/1689166456465.pdf
• Securities and Exchange Board of India, Annexure II, updated BRSR format, July 2023, https://www.sebi.gov.in/sebi_data/commondocs/jul-2023/Annexure_II-Updated-BRSR_p.PDF
• Securities and Exchange Board of India, Measures to facilitate ease of doing business with respect to framework for assurance or assessment, ESG disclosures for value chain, and introduction of voluntary disclosure on green credits, SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, 28 Mar 2025, https://www.sebi.gov.in/sebi_data/attachdocs/mar-2025/1743159419610.pdf
• Securities and Exchange Board of India, FAQs on the LODR Regulations, Section V (BRSR Core and value chain), April 2025, https://www.sebi.gov.in/sebi_data/faqfiles/apr-2025/1745399101865.pdf
• Securities and Exchange Board of India, SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, amended up to 22 Jan 2026, https://www.sebi.gov.in/sebi_data/attachdocs/jun-2026/1780915347745.pdf
• Securities and Exchange Board of India, PR No. 84/2025, board meeting of 17 Dec 2025, https://www.sebi.gov.in/sebi_data/attachdocs/dec-2025/1765977060104.pdf
• Income Tax Department, Companies Act, 2013 section 135 (corporate social responsibility), read 23 Oct 2026, https://www.incometaxindia.gov.in/w/section-135-80
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