BRSR applicability: which companies must file and when

The most common question from new clients is also the most basic: does BRSR apply to us, and if so, which parts? The answer depends on market capitalisation rank, filing history, and whether the company is listed at all. This post gives you a precise answer for each company type you are likely to advise.

The statutory basis

BRSR is mandatory under SEBI's Listing Obligations and Disclosure Requirements (LODR) Regulations, specifically Regulation 34(2)(f). SEBI first made BRSR compulsory for the top 1000 listed companies by market capitalisation starting from FY 2022-23. The format replaced the old Business Responsibility Report (BRR) that had been required since 2012. BRSR is filed as part of the Annual Report, not as a separate document, and is typically due three months after the financial year ends. For FY 2025-26, that means the Annual Report containing the BRSR is expected by late September or October 2026.

The BRSR structure: three sections, 108 Section-C indicators

All BRSR filers complete the same format. Section A covers general disclosures: corporate identity, products and services, employee count, subsidiaries, and CSR details. Section B covers management and process disclosures: policies adopted for each of the 9 National Guidelines on Responsible Business Conduct (NGRBC) principles, and governance structures. Section C covers principle-wise performance disclosures. It contains 68 Essential indicators and 40 Leadership indicators across P1 through P9, totalling 108 indicators in all.

BRSR Core: the assurance sub-set

BRSR Core is a curated sub-set of 42 KPIs from BRSR Essential that require independent assurance. SEBI introduced the BRSR Core glide path to progressively raise the assurance bar across the top 1000 companies. The schedule is as follows:

Value chain: voluntary now, mandatory from FY 2026-27

SEBI's March 2025 circular deferred mandatory value chain ESG disclosure to FY 2026-27. In FY 2025-26, disclosure for value chain partners is voluntary. When it becomes mandatory, the scope covers partners that individually account for 2% or more of the company's total purchases or sales, capped at 75% in aggregate. This 2% threshold meaningfully narrows the scope compared to what was originally anticipated, but for large listed companies it still typically captures 10 to 20 key suppliers or customers.

Unlisted companies and suppliers

Unlisted companies are not required to file BRSR. However, many unlisted companies file voluntarily, either because their promoters value the discipline, or because they are preparing for a future IPO. From FY 2026-27, unlisted suppliers to listed companies that meet the 2% value-chain threshold will receive ESG data requests from their listed customers. Proactively preparing these suppliers is a growing advisory opportunity.

Quick-reference applicability table

Key takeaways for consultants

• Confirm your client's market-cap rank at the start of every engagement. BSE/NSE publish periodic lists of top 1000 companies by market cap.
• First-time filers need only Essential indicators in Section C. Clarify this upfront to avoid over-scoping the data collection.
• Top 500 clients require reasonable assurance on 42 BRSR Core KPIs for FY 2025-26. Appoint the assurer early.
• Value-chain work is voluntary this year but advisable for top-250 companies. Starting now avoids a rush next year.
• BRSR is filed inside the Annual Report (not a separate submission). Coordinate with the company secretary on the Annual Report timeline.