What SEBI asks, verbatim
Details of safety related incidents, in the following format
For employees and workers separately: Lost Time Injury Frequency Rate (LTIFR) per one million-person hours worked, Total recordable work-related injuries, Number of fatalities, High consequence work-related injury or ill-health (excluding fatalities). Disclose for current and previous FY.
Quoted from the SEBI BRSR Format as amended March 2025, with measurement guidance from the ICAI Background Material on BRSR, Revised Edition 2024, page 114.
In plain English
Report how many safety incidents happened in the last two years. For each year, give the lost‑time injury rate per million hours, the total recordable injuries, the number of deaths, and the number of serious injuries or illnesses that were not fatal. Use the company’s own safety records to fill in these numbers.
What a complete, assurance-ready answer contains
A complete, assurance‑ready answer lists the LTIFR per million person‑hours for employees and workers separately, the total number of recordable injuries, fatalities, and high‑consequence incidents for each FY, with a clear table showing current and prior year figures. Assurers look for the underlying calculation methodology, the source of person‑hour data, and evidence that the data were verified against payroll and incident logs. A common gap is failing to separate employee and worker categories or to provide the raw person‑hour totals that underpin the LTIFR.
Describes the completeness and granularity an assurer expects. No company figures are named.
Where the data comes from
Usually found in payroll and HR records. Forward this section to your People 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 P3-E11 ask for?
Report how many safety incidents happened in the last two years. For each year, give the lost‑time injury rate per million hours, the total recordable injuries, the number of deaths, and the number of serious injuries or illnesses that were not fatal. Use the company’s own safety records to fill in these numbers.
Is BRSR P3-E11 an Essential or a Leadership indicator?
P3-E11 is an Essential indicator, so it is mandatory for every BRSR filer. It sits under Principle 3, Employee Wellbeing.
Who inside the company holds the data for P3-E11?
HR / People team. Usually found in payroll and HR records. Forward this section to your People team.
What unit does P3-E11 use?
count / rate. 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 P3-E11 look like?
A complete, assurance‑ready answer lists the LTIFR per million person‑hours for employees and workers separately, the total number of recordable injuries, fatalities, and high‑consequence incidents for each FY, with a clear table showing current and prior year figures. Assurers look for the underlying calculation methodology, the source of person‑hour data, and evidence that the data were verified against payroll and incident logs. A common gap is failing to separate employee and worker categories or to provide the raw person‑hour totals that underpin the LTIFR.
Other disclosures under Principle 3
Well-being measures for employees and workers (health insurance, accident cover, etc.; % covered)
Retirement benefits offered (PF, gratuity, ESI) for this year and last year
Are your premises accessible to differently-abled staff? (Yes/No + steps)
Do you have an equal-opportunity policy? (Yes/No + web link)
Return-to-work and retention rates after parental leave
Do you have a grievance mechanism for employees and workers? (Yes/No + details)
See P3-E11 against a real client
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