Collecting BRSR data from a client's team is consistently the most time-consuming part of any BRSR engagement. The problem is not that the data does not exist; it almost always does. The problem is that it lives with different people across different departments, none of whom have been briefed on what BRSR requires or why the request is urgent. This guide gives you a practical workflow for getting the right numbers from the right people in the shortest possible time.
Who owns what: the department map
The first step before sending any request is mapping each BRSR principle to the internal team that holds the relevant data. Getting this wrong means your request lands with someone who will forward it three times before it reaches the right person, losing a week each time.
| BRSR Principle(s) | Data owner team | What they hold |
|---|---|---|
| P1 (Ethics) | Company Secretary / Legal | Board policies, complaints, regulatory fines, advocacy positions |
| P2 (Products & lifecycle) | Procurement / R&D / EHS | EPR registrations, packaging data, recycled-input % |
| P3 (Employees) | HR | Headcount by type/gender, wages, training hours, H&S incidents, turnover rate |
| P4 (Stakeholders) | Company Secretary / Corp Affairs | Stakeholder groups, engagement mechanisms, CSR policy |
| P5 (Human rights) | HR / Legal | Gender wage ratio, maternity/paternity, equal-opportunity policy, POSH data |
| P6 (Environment) | EHS / Plant / Energy Manager | Fuel consumption, electricity units, water withdrawal, waste, air emissions |
| P7 (Policy advocacy) | Company Secretary / Government Affairs | Trade association memberships, advocacy positions |
| P8 (Inclusive development) | CSR Team | CSR spend, programmes, beneficiaries, social impact data |
| P9 (Responsible consumption) | Plant / EHS / Customer service | Complaints about products, returns, environmental impact of products |
Why generic spreadsheet requests fail
The standard approach of sending one large Excel spreadsheet with all 108 BRSR fields to "whoever handles compliance" rarely works. The person who receives it does not know which fields they own, the context for why each number is needed, or what unit SEBI expects. The spreadsheet sits in an inbox for two weeks, then comes back with ten fields filled and eighty-eight blank, requiring multiple follow-up rounds.
Send one focused request per team, not one giant spreadsheet to everyone
What to put in the HR request
HR typically owns P3 (workforce) and P5 (human rights). A good HR request asks for: permanent employees and workers, segmented by male/female and differently-abled; contract employees and third-party contractor headcount (this is often missed because staffing-agency workers are not in the HRMS); wages paid to permanent employees by gender (total annual payroll, not per-person average); training hours per employee per year; occupational health and safety incidents including fatalities, injuries, and cases of occupational disease; turnover rate for permanent employees.
Specify the reporting period (April 2025 to March 2026 for FY 2025-26) explicitly. HR teams sometimes default to the calendar year or the most recent quarterly data they have available.
What to put in the EHS/Plant request
EHS and plant managers own P6, which is the most data-intensive section of BRSR. Ask for: fuel consumption by type (diesel in litres, LPG in kg, coal in tonnes, furnace oil in kL) with monthly breakdowns; grid electricity purchased in kWh, with separate figures for each site; water withdrawal by source (groundwater borewell, surface water, municipal supply, rainwater harvesting) in kiloliters or megalitres; water discharged (volume and treatment method); hazardous waste generated and disposed by route (landfill, incineration, recycling); non-hazardous waste totals; air emissions for large stacks (if any consent-to-operate requires monitoring); any environmental fines or regulatory notices received during the year.
The EHS manager will typically have this data in their CPCB/SPCB compliance registers. Offer to extract it yourself if they share the registers, this is faster than waiting for them to compile a summary.
What to put in the Company Secretary request
The Company Secretary typically holds the Board-level governance data: policies adopted for each of the 9 BRSR principles (yes/no, policy document), the process for identifying stakeholders, the list of pending regulatory investigations or fines, memberships in trade associations or chambers of commerce (P7 policy advocacy), and the CSR annual report (which is already a statutory document and contains most of P8 data directly).
Setting deadlines and sending reminders
Give each team a specific deadline that is three to four weeks before your own internal deadline for producing the draft BRSR. Build in two reminder touchpoints: one at the midpoint and one five days before the deadline. The reminder at the midpoint is the most valuable one; it catches teams that have not started yet while there is still time to recover.
- Use a named point of contact in each team (not the generic info@ or compliance@ mailbox).
- Reference the exact BRSR indicator code in each request so the team knows where the data appears.
- For top-500 companies requiring BRSR Core assurance, note which fields will be independently verified. This raises the perceived urgency.
- Follow up by phone or WhatsApp if email reminders go unanswered for more than three business days.
Key takeaways
- Map BRSR principles to internal teams before sending any request. The department map above is a starting point.
- Send focused, team-specific requests rather than one large spreadsheet. Include context and source hints for each field.
- Ask HR for contractor headcount separately from HRMS data. It is almost always missed otherwise.
- Ask EHS for monthly utility data, not annual summaries, so you can verify the totals.
- Build reminders into your project timeline, not as afterthoughts.
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