What SEBI asks, verbatim
Details of fines / penalties / punishment / award / compounding fees / settlement amount paid in proceedings (by the entity or by directors / KMPs) with regulators / law enforcement agencies / judicial institutions, in the financial year
Disclose monetary (Penalty/Fine, Settlement, Compounding Fee) and non-monetary (Imprisonment, Punishment) actions with NGRBC Principle mapped, name of regulatory body, amount in INR, brief of case, and whether appeal preferred. Based on materiality per Regulation 30 of LODR.
Quoted from the SEBI BRSR Format as amended March 2025, with measurement guidance from the ICAI Background Material on BRSR, Revised Edition 2024, page 85.
In plain English
You must list every fine, penalty, punishment, award, compounding fee or settlement that the company or its directors or key management personnel paid to regulators, law‑enforcement agencies or courts during the year. Include the amount in rupees, the name of the regulator, a brief description of the case, and whether an appeal was filed. The information usually comes from the company’s legal or compliance department and the financial statements.
What a complete, assurance-ready answer contains
A complete, assurance‑ready answer lists every fine, penalty, settlement or compounding fee paid by the entity or its directors/KMPs during the year, with each entry showing the regulatory body, the NGRBC principle, the monetary amount in INR, a concise case description, and the appeal status. Assurers look for the data to be presented at the individual transaction level, aggregated by principle and regulator, and verified against audited financial statements or regulator filings. A common gap is omitting non‑monetary sanctions such as imprisonment or other punitive actions, which are required for a full materiality assessment.
Describes the completeness and granularity an assurer expects. No company figures are named.
Where the data comes from
Usually found in board records and compliance registers. Forward to your Company Secretary or Legal team.
Much of what BRSR asks for already exists in filings the company makes elsewhere, such as Pollution Control Board consents, PAT returns, hazardous-waste manifests and EPR registrations. The free gap analysis cross-references those filings against all 108 fields and shows which are already covered.
Frequently asked questions
What does BRSR P1-E2 ask for?
You must list every fine, penalty, punishment, award, compounding fee or settlement that the company or its directors or key management personnel paid to regulators, law‑enforcement agencies or courts during the year. Include the amount in rupees, the name of the regulator, a brief description of the case, and whether an appeal was filed. The information usually comes from the company’s legal or compliance department and the financial statements.
Is BRSR P1-E2 an Essential or a Leadership indicator?
P1-E2 is an Essential indicator, so it is mandatory for every BRSR filer. It sits under Principle 1, Ethics & Transparency.
Who inside the company holds the data for P1-E2?
Company Secretary / Legal. Usually found in board records and compliance registers. Forward to your Company Secretary or Legal team.
What unit does P1-E2 use?
INR (monetary); count (non-monetary). Reporting in the wrong unit, or switching the denominator of an intensity ratio between years, is one of the more common reasons a figure has to be restated.
What does a complete answer to P1-E2 look like?
A complete, assurance‑ready answer lists every fine, penalty, settlement or compounding fee paid by the entity or its directors/KMPs during the year, with each entry showing the regulatory body, the NGRBC principle, the monetary amount in INR, a concise case description, and the appeal status. Assurers look for the data to be presented at the individual transaction level, aggregated by principle and regulator, and verified against audited financial statements or regulator filings. A common gap is omitting non‑monetary sanctions such as imprisonment or other punitive actions, which are required for a full materiality assessment.
Other disclosures under Principle 1
% of board, KMPs, employees and workers trained on the ESG principles this year
Of those fines, which have been appealed (case details)
Do you have an anti-corruption / anti-bribery policy? (Yes/No + web link)
Number of directors, KMPs, employees or workers disciplined for bribery / corruption
Number of conflict-of-interest complaints
Any corrective action taken on the above fines or corruption cases
See P1-E2 against a real client
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