Principle 6 is the environmental heart of BRSR, and for most consultants it is the heaviest principle to answer and the one auditors examine most closely. It spans energy, water, greenhouse-gas emissions, waste, air pollutants, biodiversity and legal compliance: thirteen Essential indicators and four Leadership ones. It is also where BRSR Core reasonable assurance concentrates. This guide covers what each disclosure asks, how to answer the numeric ones, and which filings you can pull the data from.
Key takeaways
- 01Principle 6 carries the numbers auditors care about most: the GHG, energy, water and waste intensities that fall under BRSR Core reasonable assurance.
- 02Report absolute figures AND intensity per rupee of turnover, for the current and previous financial year, on every quantitative disclosure.
- 03Scope 1 and Scope 2 emissions (P6-E7) are Essential; Scope 3 (P6-L2) is a voluntary Leadership indicator.
- 04Much of the data already exists in filings your client submits: PAT returns, Pollution Control Board consents, and hazardous-waste manifests.
What Principle 6 asks
The Essential indicators are the ones every in-scope company must answer. Here is the full set, with the ICAI Background Material (2024) page for each so you can cite the source in your working papers.
| Disclosure | What it asks | ICAI page |
|---|---|---|
| P6-E1 | Total energy consumption (electricity + fuel + other) in joules, and energy intensity per rupee of turnover | 130 |
| P6-E2 | Whether any site is a Designated Consumer under the PAT scheme, and target achievement | 131 |
| P6-E3 | Water withdrawal by source and total consumption, with water intensity | 131 |
| P6-E4 | Water discharge by destination and level of treatment | 132 |
| P6-E5 | Whether a Zero Liquid Discharge mechanism is in place, and its coverage | 133 |
| P6-E6 | Air emissions other than GHG (NOx, SOx, particulate matter, VOCs) | 133 |
| P6-E7 | Scope 1 and Scope 2 GHG emissions and their intensity | 134 |
| P6-E9 | Waste generated by category, and how it is recovered or disposed | 136 |
| P6-E11 | Operations in or around ecologically sensitive areas and clearance compliance | 138 |
| P6-E13 | Compliance with the Water Act, Air Act and Environment Protection Act | 139 |
The four Leadership indicators add water use in water-stressed areas (P6-L1), total Scope 3 emissions (P6-L2), biodiversity impact in sensitive areas (P6-L3), and value-chain environmental measures (P6-L4). These are voluntary, but strong filers increasingly report them.
Where reasonable assurance concentrates
Principle 6 is where BRSR Core lives
How to answer the three big ones
Energy (P6-E1)
Add electricity, all fuels and any other energy sources, converted to a common energy unit (gigajoules). Fuels convert to energy using their calorific value; electricity is already in kWh (1 kWh = 0.0036 GJ). Then divide total energy by turnover in rupees for the intensity figure. Report both years.
Water (P6-E3 and P6-E4)
Withdrawal is every litre drawn, split by source. Consumption is what is used and not returned. Discharge is what is released, split by destination and treatment level. These are three separate disclosures, so do not merge them. Water intensity is total consumption per rupee of turnover.
GHG Scope 1 and 2 (P6-E7)
Scope 1 is fuel burnt on site or in owned vehicles, each quantity multiplied by its IPCC emission factor. Scope 2 is grid electricity multiplied by the CEA national grid factor (0.710 kgCO2 per kWh for FY 2024-25). Report absolute tonnes of CO2e plus intensity per rupee of turnover, and state the standard and GWP rates used.
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Common mistakes to avoid
- Reporting only intensity, or only absolute figures. Principle 6 asks for both, for two years.
- Mixing units: energy must be in joules, water in kilolitres, emissions in tonnes CO2e. Convert before you report.
- Forgetting fugitive and process emissions. Refrigerant leakage and process emissions are Scope 1 but are not fuel combustion; add them separately if material.
- Using a stale grid factor. The CEA republishes it each year, and an old factor mis-states every Scope 2 number.
- No evidence trail. An assured figure without a meter reading or invoice behind it will not survive the audit.
Best practice for Principle 6
When you advise a client on how to move beyond a bare disclosure, these are the recognised leading practices, in India and internationally.
- Implement Zero Liquid Discharge, rainwater harvesting and rooftop solar or renewable PPAs, and meet PAT scheme energy-saving targets.
- Set a board-approved energy- and water-intensity reduction roadmap with annual milestones.
- Measure Scope 1, 2 and 3 emissions to the GHG Protocol and set validated Science Based Targets (SBTi).
- Operate an ISO 14001 environmental management system and disclose through CDP (Climate and Water).
- Move waste up the hierarchy: recycling, co-processing and circular-economy diversion from landfill.
Where the data already lives
A great deal of Principle 6 can be pulled from filings your client already submits, rather than collected fresh. Energy comes from PAT returns; water and air come from the State Pollution Control Board consent-to-operate and water-cess returns; waste comes from hazardous-waste manifests (Form 3 and Form 10). Saaksh's gap analysis flags exactly which fields the existing filings already cover.
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