Water is one of the three headline environmental KPIs in BRSR Core assurance, alongside GHG and energy. Yet water disclosures consistently generate the most revision rounds during data collection, partly because the format distinguishes between withdrawal, consumption, and discharge in ways that are easy to conflate, and partly because water data is often scattered across utility invoices, borewell logs, and ETP records that no single team maintains in one place. This guide walks through the calculation, the common mistakes, and a worked example.
The relevant BRSR indicators
Water disclosures appear in two Essential indicators and one Leadership indicator in Section C:P6-E3 requires total water withdrawal by source and total water consumption, along with water intensity (Essential). P6-E4 covers effluent generation and treatment (Essential). P6-L1 covers water discharge quality parameters (Leadership, required only for companies with three or more years of BRSR filing or in the top 1000).
Withdrawal vs consumption vs discharge: the distinction that matters
BRSR follows the Water Footprint Network and GHG Protocol water accounting approach. Water withdrawal is the total volume of water taken from all sources. Water consumption is the volume of water that does not return to the source catchment (it is incorporated into the product, evaporated, or otherwise not discharged). Water discharge is the volume of treated or untreated effluent released. The relationship is:
Water consumption = Water withdrawal minus Water discharged
Many first-time filers report only withdrawal and omit consumption, or conflate withdrawal with consumption. SEBI expects both figures. For Zero Liquid Discharge certified facilities, consumption equals withdrawal (no discharge), which simplifies the calculation.
Water sources to disclose
| Source | How to measure | Common mistake |
|---|---|---|
| Groundwater (borewells) | Flow meter readings on borewell pumps; monthly log maintained by EHS/facility | Omitting borewell volumes because they are not billed |
| Surface water (rivers/lakes) | Consent-to-Operate water allocation; flow meter at intake point | Using the allocation limit rather than actual withdrawal |
| Third-party supply (MIDC/municipal) | Monthly utility invoices (kL or m³) | Treating this as the only source and ignoring groundwater |
| Rainwater harvested | Volume stored in harvesting structures; maintenance records | Reporting capacity of the structure, not actual volume harvested |
| Seawater / desalinated water | Meter on intake or desalination plant output | Typically applicable only to coastal industrial units |
Unit conversions to get right
BRSR typically expresses water volumes in megalitres (ML). Utility invoices are often in kiloliters (kL) or cubic meters (m³). The conversions are: 1 ML = 1,000 kL = 1,000 m³ = 1,000,000 litres. Water intensity is typically expressed in kL per tonne of output (for manufacturing) or kL per ₹ crore of revenue (for services). Do not mix ML and kL in the same row of the BRSR disclosure.
The intensity denominator: SEBI's guidance
SEBI's guidance on the intensity denominator distinguishes by sector. For manufacturing companies, the preferred denominator is per unit of production (kL per tonne of steel, kL per metre of fabric). For services companies and for manufacturers where physical output is difficult to normalise (diversified conglomerates), turnover per ₹ crore is an acceptable alternative. If your client reports both a physical output intensity and a turnover intensity, that adds credibility and is worth recommending.
Assurers check whether the denominator is consistent with prior years
Worked example: a mid-size steel plant
Consider a mid-size steel plant producing 50,000 tonnes of finished steel per year. Annual water withdrawal data is as follows: groundwater (borewells): 90 ML; municipal supply (MIDC): 60 ML; rainwater harvested: 30 ML. Total withdrawal: 180 ML. Water discharged after treatment: 36 ML (20% of withdrawal recycled to the neighbouring industrial estate). Water consumed: 180 ML minus 36 ML = 144 ML. Water intensity: 180,000 kL divided by 50,000 tonnes = 3.6 kL per tonne of steel.
| Metric | Value | Unit |
|---|---|---|
| Total water withdrawal | 180 | ML |
| Groundwater | 90 | ML |
| Municipal supply | 60 | ML |
| Rainwater harvested | 30 | ML |
| Water discharged (treated) | 36 | ML |
| Water consumed | 144 | ML |
| Annual production | 50,000 | Tonnes of steel |
| Water intensity | 3.6 | kL per tonne of steel |
Key takeaways
- Disclose withdrawal, consumption, AND discharge separately. Consumption = withdrawal minus discharge.
- Collect groundwater borewell volumes proactively from EHS/facilities. They are not in any invoice.
- Use ML for volumes in the BRSR disclosure. Convert kL figures by dividing by 1,000.
- BRSR Core assurance will check whether the intensity denominator is consistent with prior years and whether it aligns with the ISF sector standard.
- ZLD-certified facilities: water consumption equals water withdrawal (no discharge). State the ZLD certification clearly.
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