BRSR has never been static. Each year SEBI refines the format, and FY 2025-26 brought the most significant changes since BRSR replaced the old BRR format in 2022. If you are preparing a client's filing this year, three things demand your immediate attention.

1. BRSR Core is mandatory for the top 500

BRSR Core is a sub-set of 42 Key Performance Indicators drawn from BRSR Essential. For FY 2025-26, SEBI has made reasonable assurance on these 42 KPIs compulsory for the top 500 listed companies by market capitalisation. The top 1000 companies join the Core assurance requirement from FY 2026-27.

What 'reasonable assurance' means in practice

A SEBI-registered independent assurance provider (typically a practising CA firm or a specialist ESG assurer) must review the 42 Core KPIs and issue a reasonable assurance report. This is a higher bar than the limited assurance many companies are used to from financial audits of ESG data.

The 42 Core KPIs span all 9 BRSR principles, but lean heavily on P6 (Environment) and P3 (Employees). For your clients, this means the GHG, water, energy, and workforce data must be audit-grade, with documented methodologies, conversion factors cited by version, and a clear data trail.

2. Value-chain disclosures are voluntary now, expected by FY 2026-27

SEBI's BRSR format includes a Section on value-chain disclosures (Principle 2, Leadership indicators). For FY 2025-26 these remain voluntary, but SEBI has signalled that the top 250 listed companies will be required to report them from FY 2026-27. If your client is in the top 250, now is the year to start mapping their supply chain and briefing 2-3 key Tier-1 suppliers.

Identify the suppliers that account for 2% or more of purchases by value.
Check if those suppliers file BRSR themselves or have any ESG data available.
Start a Scope 3 Category 1 (purchased goods) screening, even a high-level estimate establishes a baseline.
Document the methodology, because the assurer will ask.

3. SEBI's March 2025 amendments

SEBI issued a circular in March 2025 clarifying several long-debated points in the BRSR format. The key clarifications relevant to consultants:

Reporting period is the financial year (April-March), not the calendar year.
Absolute figures must be reported alongside intensity ratios, not instead of them.
For P6-E1 (GHG), both Scope 1 and Scope 2 are required; Scope 3 remains voluntary.
The "well-being" disclosures in P3 must cover all workers, not just permanent employees.
Section A disclosures updated to include the company's BRSR contact person and their designation.

What to tell your clients this year

Brief the board early. Reasonable assurance on the Core KPIs is not a box-ticking exercise; it requires an assurance provider to spend time with your data team, and that takes planning. Companies that wait until Q3 find themselves racing the September deadline with incomplete data and an assurer who has no time to issue a clean report.

Saaksh checks BRSR Core applicability automatically

When you generate a readiness report in Saaksh, it detects whether your client falls in the top 500 or top 1000 and flags the Core KPIs that require assurance. The engagement timeline generator can set milestones around the assurance window.

Frequently asked questions

Is BRSR Core mandatory for all listed companies in FY 2025-26?

No. For FY 2025-26, BRSR Core reasonable assurance is mandatory only for the top 500 listed companies by market capitalisation. The top 1000 companies join from FY 2026-27. All top 1000 companies still file the full BRSR Essential format.

What is the filing deadline for BRSR for FY 2025-26?

BRSR is filed as part of the Annual Report, which must be submitted within 60 days of the AGM. For most listed companies, this means by late September or October 2026. The exact deadline depends on your client's AGM date.

If my client is outside the top 500, do they still need BRSR Core?

Companies ranked 501-1000 must file BRSR Essential (the full format) but do not need BRSR Core reasonable assurance in FY 2025-26. They should prepare for it by FY 2026-27, when Core assurance becomes mandatory for all top 1000 companies.

When do value-chain disclosures become mandatory?

Value-chain ESG disclosures are voluntary for FY 2025-26 and FY 2026-27 is when SEBI expects the top 250 companies to begin reporting them. The scope covers partners who individually account for 2% or more of total purchases or sales, capped at 75% in aggregate.

What did SEBI's March 2025 amendments actually change?

The March 2025 circular clarified several grey areas: the reporting period is April to March (not a calendar year), absolute GHG figures are required alongside intensity ratios, the well-being disclosures in P3 must cover all workers including contract workers, and Section A now requires the company's designated BRSR contact person.

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