Regulatory Landscape for ESG in India
BRSR, BRSR Core and What Applies to You

ESG regulation in India arrived quietly and then moved quickly. A voluntary set of guidelines in 2009 became a mandatory report for the top hundred listed companies in 2012, a substantially expanded disclosure for the top thousand in 2022, and from the financial year that began on 1 April 2026 an externally verified set of measurable indicators for that same thousand. Each step raised the evidentiary bar, and the current step raises it furthest.

The practical difficulty is not the reporting format. It is that measurable ESG indicators require data most companies were never built to produce. Electricity bills exist; tonnes of carbon dioxide equivalent do not. Water is drawn but rarely metered by source. The gap between having the underlying records and having assurable numbers usually takes six to twelve months of work to close.

N D Savla & Associates advises companies across Mumbai, Navi Mumbai, Thane and Goa on what the ESG regulatory framework actually requires of them, which year they enter the perimeter, and what has to be built before an assessor arrives. We map applicable regulations, review current compliance, design the policies and controls, and prepare the ESG assurance readiness position ahead of the reporting year rather than during it.

India has no single ESG statute. What exists is a disclosure framework administered by SEBI, sitting on top of a much older body of environmental, labour and company law that governs the underlying conduct. Understanding which of these actually binds you is the starting point.

The disclosure limb is Business Responsibility and Sustainability Reporting (BRSR), forming part of the annual report of listed entities and structured around the nine principles of the National Guidelines on Responsible Business Conduct. The full BRSR applies to the top 1,000 listed entities by market capitalisation, and has done so since FY 2022-23.

The conduct limb is everything else — Companies Act provisions on governance and CSR, environmental statutes on pollution and waste, the labour codes, and sector-specific requirements. These impose obligations regardless of listing status, and generate the facts BRSR asks companies to disclose. A disclosure that accurately reports a lapsed consent does not solve the problem; it publishes it.

Business Responsibility and Sustainability Reporting

BRSR is the primary ESG reporting framework for listed companies in India. It requires disclosure across environmental impact, employee wellbeing, community engagement, customer relationships and governance, split between essential indicators that must be reported and leadership indicators that are voluntary.

BRSR Core and the nine ESG attributes

BRSR Core is the assurable subset — key performance indicators grouped under nine attributes: greenhouse gas emissions, water, waste, energy, gender diversity, wages, inclusive development, fairness in engaging with customers and suppliers, and openness of business. SEBI deliberately confined the Core to indicators that can be objectively measured, sampled and tested.

Companies Act, 2013 provisions

Corporate Social Responsibility under Section 135 requires eligible companies to spend two per cent of average net profits on Schedule VII activities. Implementing agencies register through CSR-1, and reporting runs through CSR-2. Board composition, independent director requirements and related party disclosure all feed the governance component of ESG assessment.

Environmental regulation

The Water Act 1974, Air Act 1981 and Environment (Protection) Act 1986 form the base layer, administered through State Pollution Control Boards. Extended producer responsibility regimes under the plastic, e-waste and battery waste rules impose registration, collection and recycling obligations. The Energy Conservation (Amendment) Act, 2022 introduced the framework for a domestic carbon credit trading scheme.

Labour and social welfare law

The four labour codes consolidate a large body of earlier legislation. Wage data, contract labour arrangements, safety records and social security contributions are all BRSR Core inputs, so labour compliance and ESG reporting draw on the same evidence base.

Corporate governance regulation

Listing regulations impose board composition, committee, disclosure and related party requirements on listed entities, constituting the governance pillar in practice. Corporate governance advisory work and ESG work overlap substantially here.

Applicability is determined by market capitalisation rank as at 31 March of the relevant financial year. Companies close to a boundary should track their rank prospectively, because entry can happen on a single year's price movement.

The Indian framework was built in stages over roughly fifteen years, and each stage was a response to the limitations of the one before it.

The starting point was the Corporate Social Responsibility Voluntary Guidelines issued by the Ministry of Corporate Affairs in 2009 — entirely advisory, producing uneven adoption. They were superseded in 2011 by the National Voluntary Guidelines, establishing the nine-principle structure that survives today. The principles were sound; the voluntary character was the weakness.

Mandatory disclosure arrived in 2012, when SEBI required the top 100 listed companies to file a Business Responsibility Report, extended to the top 500 in 2015. The BRR made non-financial disclosure compulsory for the first time, but allowed narrative answers, so comparability across companies was poor.

Two developments changed that. The Companies Act, 2013 made CSR spending mandatory through Section 135. And in 2019 the Ministry issued the National Guidelines on Responsible Business Conduct, aligning them with the UN Sustainable Development Goals and Guiding Principles on Business and Human Rights.

BRSR followed in 2021, voluntary for FY 2021-22 and mandatory for the top 1,000 listed entities from FY 2022-23, delivered in machine-readable form so the data could be aggregated and compared for the first time.

The final stage addressed credibility. BRSR Core was introduced in 2023 through a SEBI circular establishing measurable indicators subject to third-party verification, with a glide path from the top 150 in FY 2023-24 to the top 1,000 in FY 2026-27. A circular of 28 March 2025 softened the language from reasonable assurance to assessment or assurance, giving companies a choice and easing the position for value chain reporting.