BRSR value chain disclosure: voluntary now, mandatory from FY 2026-27

Value chain disclosure is the next major frontier in BRSR. After two years of building the internal BRSR reporting discipline, listed companies are now expected to extend that discipline to their key suppliers and customers. SEBI's March 2025 circular clarified the scope, timeline, and mechanics in ways that significantly affect how consultants should be advising clients this year.

The timeline: what changed in March 2025

Before SEBI's March 2025 circular, value chain ESG disclosures were expected to follow a "comply-or-explain" approach for FY 2024-25. The March 2025 circular changed this: value chain disclosure is now purely voluntary for FY 2025-26 and will become mandatory from FY 2026-27. This one-year extension gives listed companies time to prepare and gives their supply chain partners time to build ESG data collection capability before the mandatory deadline arrives.

Which value chain partners are in scope

SEBI's March 2025 circular provides a specific and important clarification on scope. Value chain partners are in scope if they individually account for 2% or more of the company's total purchases or sales. The aggregate coverage is capped at 75%: once you have identified enough partners to cover 75% of total purchases and sales, you stop even if there are more partners above the 2% threshold individually. You apply whichever of the two criteria results in the smaller number of partners.

This 2% threshold meaningfully narrows the scope compared to what was originally feared. For a large manufacturer, it typically captures between 8 and 20 key Tier-1 suppliers and the same number of large customers, not the entire supply chain.

Who collects the data

The listed company is responsible for collecting ESG data from its in-scope value chain partners and disclosing it in its own BRSR. This does not mean the listed company generates or certifies the partner's data: the partner provides the data, the listed company reports it (with a note on how it was collected and verified), and the listed company's assurer may review the collection methodology as part of the BRSR Core assurance engagement.

This creates a direct advisory opportunity. The listed company needs to brief its key suppliers on what data is required, in what format, and by what deadline. Suppliers who have never produced ESG data need hand-holding through the first collection cycle. That is consulting work.

The green credits addition from March 2025

SEBI's March 2025 circular added a P6 Leadership indicator requiring companies to disclose green credits generated by their top 10 value chain partners by procurement value. For companies that choose to disclose voluntarily in FY 2025-26, this indicator is part of the scope. For the consultant, this means identifying whether any key suppliers have earned green credits under India's Green Credit Programme (GCP) or the CCTS, and collecting that data as part of the value chain ESG exercise.

Why starting in FY 2025-26 (voluntarily) is worth advising

The companies that will struggle most with mandatory value chain disclosure in FY 2026-27 are those that do nothing in FY 2025-26 and then have to simultaneously identify in-scope partners, educate them on BRSR, build data collection workflows, chase submissions, and have the data reviewed by their assurer, all in one year. The companies that use FY 2025-26 to run a pilot with three to five key suppliers will enter FY 2026-27 with a tested workflow, educated partners, and a baseline dataset.

• In Q1 FY 2025-26: map your client's top suppliers and customers by purchase/sales value. Identify the 2% threshold partners.
• In Q2: brief those partners on what ESG data will be requested from FY 2026-27. Share a simple data request template.
• In Q3: run a voluntary pilot data collection with two or three willing partners to test the workflow.
• In Q4: use the pilot experience to refine the process for the mandatory FY 2026-27 run.

Key takeaways

• Value chain disclosure is voluntary in FY 2025-26 and mandatory from FY 2026-27 for BRSR Core companies.
• In-scope partners are those individually at 2% or more of purchases or sales, capped at 75% aggregate.
• Partners disclose against BRSR Core KPIs under the assessment framework, not the full 108-indicator BRSR.
• The listed company collects and reports the partner data in its own BRSR.
• Use FY 2025-26 as a voluntary pilot year to build the workflow before it becomes mandatory.