How to Create a Business Responsibility and Sustainability Report That Meets SEBI Guidelines

Preparing a Business Responsibility and Sustainability Report (BRSR) isn't an exercise you complete a few weeks before publishing the annual report. By the time reporting season arrives, most of the work should already be in place.

Companies that leave the exercise until the last minute usually face the same problems. Data sits with different departments, ESG disclosures don't match internal records, supporting documents remain incomplete, and the reporting team spends valuable time reconciling information instead of reviewing it.

SEBI's BRSR framework doesn't expect companies to write better narratives. It expects them to report verifiable information in a prescribed format. That means every disclosure, whether it relates to governance, environmental performance, workforce practices, or business conduct, should be supported by records the company can produce if required.

A structured reporting process makes that possible.

Make the Report Around SEBI's Disclosure Structure

Many companies make the mistake of collecting information first and matching it to the BRSR format later. That approach usually creates reporting gaps.

Start with SEBI's reporting framework instead. The BRSR follows the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC), with specific disclosures under governance, environmental performance, employee welfare, value chain, and community impact. Mapping internal data to these disclosure requirements at the beginning makes reporting more structured and reduces last-minute revisions.

Collect Verifiable Data, Not General Statements

Every disclosure in a BRSR should trace back to records maintained by the company.

For example, if the report includes information on energy consumption, greenhouse gas emissions, workplace injuries, gender diversity, waste management, or training hours, the underlying records should support those figures. 

Companies also need a consistent methodology for calculating these numbers across different business units. Inconsistent data is one of the most common reasons reports require multiple rounds of internal review.

Involve Every Function That Owns the Data

A BRSR cannot be prepared by the compliance or legal team alone.

Most disclosures come from different parts of the business. HR manages workforce data. Operations track resource consumption and waste generation. Procurement maintains supplier information. Finance validates numerical disclosures, while legal and secretarial teams review regulatory compliance and governance-related information.

When each function owns its data and follows a common reporting timeline, preparing the final report becomes significantly easier.

Review the Report Before It Reaches the Board

The final review should focus on accuracy rather than language.

Check whether the numbers remain consistent throughout the report, whether every disclosure matches supporting records, and whether mandatory disclosures have been completed in the prescribed format. Companies should also confirm that internal policies referred to in the report are current and formally approved.

For companies covered under the phased implementation of BRSR Core, this review becomes even more important because SEBI has introduced assessment or assurance requirements for specified listed entities based on market capitalization.

Keep Supporting Policies and Records Ready

A BRSR is not based only on numbers. Many disclosures also refer to the company's internal policies, governance practices, and management systems.

Before finalising the report make sure the following things are properly documented: 

• Review whether policies relating to ethics 

• Anti-corruption

• Employee welfare

• Human rights, 

• Environmental management

• Grievance redressals

• Supplier engagement 

Companies should also maintain records that support these disclosures, as regulators, investors, or assurance providers may seek additional clarification if required.

Keeping these documents organised alongside the reporting data makes the final review more efficient and reduces the risk of inconsistencies across disclosures.

Bottom Line

A compliant Business Responsibility and Sustainability Report is built over the course of the financial year, not during the annual report drafting process. 

Companies that maintain organised records, assign reporting responsibilities early, and align disclosures with SEBI's prescribed framework are better placed to complete the exercise accurately and within timelines.