Top 1000 Listed Companies to File ESG Reports with SEBI

ESG reporting in India commenced in 2009 when the Ministry of Corporate Affairs (MCA) issued voluntary guidelines on Corporate Social Responsibility. This was the first step towards mainstreaming the business responsibility concept in India. Since then, the ESG reporting landscape has come a long way. From Business Responsibility Report to National Guidelines on Responsible Business Conduct, ESG reporting in India has moved to Business Responsibility and Sustainability Report framework.

On 10th May 2021, the Securities and Exchange Board of India (SEBI) mandated filings under the Business Reporting and Sustainability Reporting (BRSR) from the fiscal year 2022-23. The mandate applies to the top 1,000 listed companies by market cap. Continue reading to learn more about the disclosure requirements in the new BRSR framework.

Refer to SEBI Updates on ESG Disclosure

But first, let’s understand what ESG reporting is.

What is ESG Reporting?

 Sustainability is fast becoming a priority for corporates all around the globe. With a shift in the mindset of investors, priorities have expanded to include sustainability growth along with the primary wealth creation goal. As a result, businesses today are expected to demonstrate ethics and moral duty towards society.

ESG reporting is the disclosure of a company’s data covering operations in three areas, i.e., environmental, social, and corporate governance. ESG reporting is an invaluable tool for organisations as it helps identify risks, track sustainability, and report their performance. Data covered under ESG reporting include:

• Environmental: biodiversity, climate change strategy, energy efficiency, etc.
• Social: equal opportunities, human rights, health, and safety, etc.
• Governance: business ethics, shareholder democracy, compliance, etc.

Structure of BRSR Format

The reporting format is divided into three sections:

 Section A: General Disclosures

The section includes details of the listed entity – its operation, products/services, employees, holding, subsidiary and associate companies, CSR, and transparency and disclosure compliance.

This section introduces the company and its business operations, including basic contact information, business addresses, and stock exchanges where the company is listed. It also clarifies the reporting boundary, indicating whether the report covers just the company or also its subsidiaries and portfolio companies.

General ESG Reporting disclosures include details about the company’s products and services, as well as the locations of its plants and offices, both within India and internationally.

Employee details are also disclosed, including diversity metrics such as the number of differently abled employees and workers, representation of women in the company, and employee turnover data. This section also reports on the number of employee complaints and grievances filed.

“Over 90% of S&P companies have sustainability reporting on their websites, highlighting the growing importance of ESG disclosures”

 Section B: Management and Process Disclosures

The section includes policy and management processes, leadership, governance, and oversight questions.

This section helps listed companies demonstrate their compliance with the National Guidelines on Responsible Business Conduct (NGRBCs). Companies must show that NGRBC-compliant policies exist, are approved by leadership, and are translated into procedures with measurable, time-bound goals.

“ The BRSR aims to promote transparency and standardization, allowing for greater comparability across companies.”

 Section C: Principle-Wise Performance Disclosures

This section requires companies to report the KPIs in alignment with the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC).

This section demonstrates how key principles and core elements of the standards are incorporated into business practices and decision-making, forming the bulk of the report. It includes quantitative data reported in a standardized manner to document year-over-year progress.

“A 2021 survey by PwC revealed that 80% of respondents prefer to buy from companies focused on environmental issues, underscoring the importance of ESG reporting.”

Nine NGRBC principles are included in this section, with indicators categorized as Essential or Leadership. Essential indicators must be reported by all companies filing a Business Responsibility and Sustainability Report (BRSR), while Leadership indicators are for companies aiming to demonstrate a higher commitment to sustainability.

Principles of Business Responsibility and Sustainability Reporting in India

Principle 1: Ethical, Transparent, and Accountable Conduct

Businesses should conduct and govern themselves with integrity, in a manner that is ethical, transparent, and accountable. This principle emphasizes the importance of honest practices and clear communication with stakeholders, ensuring that companies build trust through responsible governance.

Principle 2: Sustainable and Safe Goods and Services

Businesses should provide goods and services in a manner that is sustainable and safe. This principle underscores the importance of producing and delivering products and services that are environmentally friendly, responsibly sourced, and safe for consumers and the broader community.

Principle 3: Employee Well-being

Businesses should respect and promote the well-being of all employees, including those in their value chains. This principle highlights the need for fair wages, safe working conditions, and support for employees throughout the company’s operations, ensuring their health, safety, and growth.

Principle 4: Responsiveness to Stakeholders

Businesses should respect the interests of and be responsive to all stakeholders. This principle emphasizes the importance of engaging with stakeholders, including customers, investors, and the community, to understand their needs and concerns, and to incorporate their feedback into business decisions.

Principle 5: Human Rights

Businesses should respect and promote human rights. This principle calls for companies to uphold and protect the rights of all individuals affected by their operations, including employees, customers, and communities, ensuring ethical and humane practices throughout the supply chain.

Principle 6: Environmental Protection and Restoration

Businesses should respect and make efforts to protect and restore the environment. This principle emphasizes the importance of minimizing environmental impact, promoting sustainable practices, and taking active measures to restore ecosystems affected by business operations.

Principle 7: Responsible Public and Regulatory Influence

Businesses, when engaging in influencing public and regulatory policy, should do so in a responsible and transparent manner. This principle calls for companies to engage ethically with policymakers and regulators, ensuring that their influence supports fair, transparent, and responsible governance.

Principle 8: Inclusive Growth and Equitable Development

Businesses should promote inclusive growth and equitable development. This principle highlights the need for companies to support growth that benefits all segments of society, addressing social and economic disparities and contributing to equitable development.

Principle 9: Responsible Consumer Engagement

Businesses should engage with and provide value to their consumers in a responsible manner. This principle emphasizes the importance of clear product labeling, safe products, and addressing consumer concerns promptly and transparently, ensuring value and trust in the company’s offerings.

 Disclosure Requirements Under the New BRSR Format

The new BRSR format for ESG reporting is based on nine principles of the Indian government’s NGRBC. These guidelines define responsible business conduct for Indian companies. The nine principles under these guidelines address several sustainability issues, such as human rights, business ethics and transparency, fair labor practices, and environmental safety.

The following table shows the principles of NGRBC that cover the aspects of ESG reporting.

Changes in the Comprehensive BRSR Framework

Section A: Assurance Provider Information

With the introduction of the “BRSR Core,” listed companies must provide details about the assurance provider’s name and explicitly state the type of assurance obtained.

Section C: Essential Indicators

The “Essential Indicators” in Section C have been updated to incorporate new KPIs from the BRSR Core framework, and some KPIs have been moved from “Leadership” to “Essential Indicators.” The transitions are as follows:

Principle 6: Environmental Protection and Restoration

Businesses should respect and make efforts to protect and restore the environment. The following indicators have transitioned from “Leadership” to “Essential”:

• Energy Consumption: Details of total energy consumed (in joules or multiples) from renewable and non-renewable sources.
• Energy Intensity: Energy intensity per rupee of turnover, adjusted for Purchasing Power Parity (PPP), and energy intensity in terms of physical output.
• Water Discharge: Details related to water discharge for the current and previous financial year.

Principle 9: Responsible Consumer Engagement

Businesses should engage with and provide value to their consumers in a responsible manner. The following indicator has transitioned from “Leadership” to “Essential”:

• Data Breaches: Information related to data breaches.

BRSR Reporting Timelines for Disclosure and Assurance

The reporting of BRSR Core KPIs is mandatory for the top 1000 listed companies from 2023-24 onwards. Additionally, a glide path has been defined for implementing reasonable assurance for BRSR Core disclosures:

• 2023-24: The top 1000 companies will report on BRSR Core KPIs, with reasonable assurance applicable to the top 150 listed companies.
• 2024-25: The top 1000 companies will continue reporting, with reasonable assurance extending to the top 250 listed companies.
• 2025-26: The top 1000 companies will maintain reporting, with reasonable assurance extending to the top 500 listed companies.
• 2026-27: The top 1000 companies will continue reporting, with reasonable assurance covering all top 1000 listed companies.

How to Submit Business Reporting and Sustainability Report (BRSR)?

Submitting your Business Reporting and Sustainability Report (BRSR) is a crucial step in fulfilling your reporting obligations as a listed company. Here’s a step-by-step guide to help you navigate the process smoothly:

Prepare Your Report

Gather all the necessary information and data required for your BRSR. Ensure that your report covers all the relevant aspects of your business operations, including environmental, social, and governance (ESG) performance.

Choose the Right Format

Your BRSR needs to be submitted in both PDF and XBRL formats. The PDF format provides a comprehensive overview of your report, while XBRL ensures that your data is machine-readable and easily analyzed.

Access the Submission Platform

Navigate to the XBRL section of the BSE’s Listing Centre to access the XBRL utility for BRSR submission. This platform provides the necessary tools and resources to facilitate the submission process.

Use the XBRL Utility

Utilize the XBRL utility to seamlessly convert your PDF report into XBRL format, simplifying the entire conversion process. This efficient tool ensures that your report adheres to the necessary digital standards, facilitating smooth submission.

For reliable XBRL services, consider leveraging DataTracks’ expertise. With DataTracks, you can trust in accurate and efficient conversion, allowing you to meet your reporting obligations with confidence

Review and Finalize

Before submission, thoroughly review your BRSR to ensure accuracy and completeness. Double-check all data and information to minimize errors and discrepancies.

Submit Your Report

Once you’re satisfied with your BRSR, proceed to submit it through the XBRL platform. Follow the provided instructions carefully to complete the submission process.

Listed companies are required to submit BRSR in both PDF and XBRL formats. Companies that have filed BRSR in PDF must also submit it in XBRL mode. Filers can find XBRL utility for BRSR submission in the XBRL section of BSE’s Listing Centre.

Download  PDF – BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORTING FORMAT

Conclusion

The new ESG reporting requirements promote transparent, standardised disclosures on sustainability-related risks and opportunities for listed companies in India. It will help companies better convey their sustainability objectives, performance, and position in the market. As a result, it helps increase investors’ ability to make informed ESG-related decisions. 

BRSR is a more comprehensive reporting framework than BRR. Companies must prepare themselves for the change mandated from the fiscal year 2022-23. For more details regarding the ESG reporting mandate in India, stay updated at https://www.datatracks.com/in/blog/.