BRSR Applicability FY 2025-26: Who Files, Assures and Can Skip It

Three separate thresholds decide what your BRSR applicability for FY 2025-26 looks like, and they no longer move together. BRSR, the Business Responsibility and Sustainability Report, is the sustainability disclosure that the top 1,000 listed entities must publish inside the annual report under Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR). SEBI's circular of 28 March 2025 rewrote two of the three tests: BRSR Core can now be assessed rather than assured, and value chain ESG disclosure has dropped to a voluntary basis for the top 250. If the compliance calendar still carries a single line item called "BRSR applicability", it's wrong for FY 2025-26.

Is BRSR applicable to my company for FY 2025-26? Why it is really three questions

Most explainers answer it once and stop. There are three stacked tests, each with its own population and its own legal source: whether you file a BRSR at all, whether the carved-out BRSR Core has to go through an external assurance or assessment engagement, and whether ESG disclosure extends into your value chain.

A company can sit inside layer one and outside the other two. A company in the top 250 sits inside all three, though only the first two carry compulsion this year. Reading the layers as a single obligation is how audit committees end up over-scoping an assurance engagement, or discovering in July that nobody appointed a provider.

Layer 1: who has to file a BRSR under Regulation 34(2)(f)?

The base requirement sits in Regulation 34(2)(f) of the LODR Regulations, which places the BRSR inside the annual report for the top 1,000 listed entities by market capitalisation. Entities below that line may report voluntarily, and a fair number do, usually because a lender, an index provider or a customer has asked.

The reporting format does not live in the regulation. It travels through SEBI's master circular for listed entities, and the operative material here is Section IV-B of the master circular dated 11 November 2024, which SEBI's own LODR FAQs identify as the home of the BRSR Core requirements. When you cite your obligation in a board note, cite both: the regulation for applicability, the master circular for content.

Layer 2: does BRSR Core apply to us, and is it assurance or assessment?

BRSR Core is the smaller set of key performance indicators carved out of the BRSR for external verification. Its rollout follows the glide path first set in SEBI circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023, and restated in the March 2025 circular:

FY 2025-26 is the year the population doubles from 250 to 500. For roughly 250 companies, this is the first annual report cycle in which a third party has to put its name to part of the sustainability numbers.

What changed on 28 March 2025 is the nature of that engagement. SEBI circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, issued under Regulation 101 of the LODR Regulations, recast the relevant paragraphs of the master circular so that the heading now reads "Assessment or Assurance Provider". The entity chooses. Assessment means a third-party assessment carried out against standards developed by the Industry Standards Forum in consultation with SEBI, as SEBI's LODR FAQs confirm. The Industry Standards Forum is made up of ASSOCHAM, CII and FICCI working under the aegis of the stock exchanges, and the standards are published on the industry association and exchange websites.

One drafting point catches teams out. The format of BRSR Core for assessment or assurance is set out at Annexure 17A to the March 2025 circular, so work from that annexure rather than a 2023-vintage template carried over in a consultant's working file.

Who can sign the BRSR Core report, and which conflicts disqualify a provider?

SEBI's FAQs are unusually direct here. Assurance or assessment of BRSR Core is profession agnostic; the provider need not be a Chartered Accountant, though the board must satisfy itself that the provider has the necessary expertise in sustainability.

The independence rules bite harder than the credential rules. If a provider sells products or offers non-audit, non-assurance or non-assessment services to the listed entity or its group entities, it isn't eligible, and SEBI says this applies whether the product or service is financial or non-financial. For this purpose "group" means the holding company, subsidiaries, associates and joint ventures. Risk management, project management, consulting, investment advisory, investment banking, design and implementation of information systems, outsourced financial services, actuarial work, and accounting and bookkeeping are all listed as activities a BRSR Core assurance provider cannot also be doing, and SEBI describes that list as indicative rather than exhaustive. Third-party certifications, tax audit, system audit and tax filing can sit alongside the engagement if the entity concludes there is no conflict.

Two specific answers are worth pinning to the wall. The internal auditor of the listed entity or its group entities cannot be appointed. The statutory auditor can be, subject to the same competence and independence conditions.

On standards, SEBI does not mandate one. The FAQs name ISAE 3000, ISSA 5000, and the ICAI standards, including the Standard on Sustainability Assurance Engagements (SSAE) 3000 and SAE 3410 on greenhouse gas statements, as acceptable choices, with the standard used to be disclosed.

Layer 3: is value chain ESG disclosure mandatory for the top 250 this year?

This is the layer that has moved most, and the layer where old guidance notes are still circulating. For FY 2025-26, ESG disclosures for the value chain apply to the top 250 listed entities by market capitalisation "on a voluntary basis", in the words of the March 2025 circular as quoted in SEBI's FAQs.

Two follow-up answers matter as much as the headline. If a listed entity does choose to disclose value chain ESG data, third-party assurance or assessment of that data is not required; both the disclosure and the verification are voluntary. And SEBI has said the relaxation is not a first-year concession. It applies from the first year of applicability and continues unless SEBI modifies it through a later circular or regulation.

If you do disclose, the scoping rules are precise. Value chain covers the top upstream and downstream partners individually accounting for 2% or more of purchases and sales by value respectively, and the entity may limit disclosure to cover 75% of purchases and sales. Where disclosure is given, the percentage of total sales and purchases covered by the partners reported on must itself be disclosed. SEBI's FAQs work through a numeric illustration of both the supplier and customer side, which is the clearest official worked example available on this point.

The same circular introduced a voluntary disclosure on green credits, as its title records and as Business Standard reported at the time. A green credit line is the kind of disclosure that becomes sticky once made, so treat the first year's wording as a template you'll have to live with.

How the market-capitalisation list is drawn

All three layers run off market capitalisation rankings, and the basis for those rankings changed. Ranking used to be computed on market capitalisation as on 31 March, as Business Standard reported when the methodology was revised after representations that single-day computation was adding to compliance burden. The revised approach uses an average over the six months from 1 July to 31 December, effective from 31 December 2024, as summarised in commentary on the amendment.

For FY 2025-26 BRSR Core, that means the relevant ranking is the top 500 determined on the six-month average ending 31 December 2024. Practitioner commentary on the transition reads the rules as giving entities entering the bracket for the first time a window to put systems in place, running to three months or the next financial year, whichever is later, with the BRSR Core disclosure then made in the annual report for FY 2025-26 (analysis). Check your own entry date against the exchange-published ranking before relying on that reading.

Regulation 3(2): can a company stop filing BRSR after falling out of the list?

This is the trap that costs companies a non-compliance letter. Falling out of the top 500 or the top 1,000 in a subsequent ranking does not automatically end the obligation. Under Regulation 3(2) of the LODR Regulations, threshold-based requirements continue to apply once triggered, and the exit is conditional rather than automatic. Dropping out of the list does not switch the obligation off; it only starts a clock.

One caveat. The consolidated LODR text on SEBI's site was not reachable when we checked, so the precise exit condition, generally understood to require the entity to stay below the threshold for three consecutive years, should be verified against the regulation as currently in force before anyone acts on it. The direction of the rule is settled; the arithmetic of when you may stop reporting is worth confirming in writing.

When is BRSR due? It has no standalone deadline

There is no separate BRSR filing deadline to diarise. The BRSR forms part of the annual report under Regulation 34(2)(f), and the March 2025 circular likewise frames value chain ESG disclosure as something given as part of the annual report. BRSR timing is therefore governed by your annual report timetable and your AGM, not by a quarterly results clock.

Dropping out of the list does not switch the obligation off; it only starts a clock.

That sounds like relief. In practice it works the other way, because an assurance or assessment engagement on BRSR Core has to be planned backwards from the date the annual report goes to print, which for most Indian listed companies means field work in April and May on data that operating sites finish generating on 31 March. Companies entering the top 500 this year will be doing that with energy, water, waste and safety data that has never been tested by anyone outside the organisation.

What does BRSR applicability mean for CFOs, company secretaries and IR teams?

Start with a one-page applicability memo for the audit committee stating, separately, the entity's rank on the six-month average ending 31 December 2024, and whether it is inside the top 1,000 for BRSR, the top 500 for BRSR Core, and the top 250 for value chain. Record where the ranking came from. That memo is what you'll be asked for if a rank is later disputed.

Decide assurance versus assessment early and document the reasoning: cost, provider availability, and what peers and index providers expect. The choice now sits with the entity, which makes it a board-level judgement. Run the conflict-of-interest screen against the full group (holding company, subsidiaries, associates, joint ventures) and get written confirmation from the provider covering non-audit services and product sales.

For company secretaries, move BRSR inside the annual report workflow on the compliance calendar, with internal cut-offs for data freeze, provider field work and management representation. IR teams should prepare for the question that will come on the FY 2025-26 call: whether the company assured or assessed its BRSR Core, and why. Teams already handling unsolicited ESG ratings and the Regulation 30 intimation duty will recognise the pattern, since the market forms a view on your sustainability data whether or not you control the timing. We'd expect investors comparing two companies side by side to read a difference in rigour between the assurance and assessment routes, even though SEBI treats them as alternatives.

Sustainability heads should use the voluntary status of value chain disclosure as a year of preparation. Identify your 2% partners, run a pilot data request, and find out how many can answer at all. That response rate will tell you what a mandatory year would cost far better than any gap assessment will.

Before the next audit committee paper

Pull the three circular references into one place so the file survives staff turnover: the July 2023 BRSR Core circular, the 28 March 2025 circular, and the SEBI (LODR) (Amendment) Regulations, 2025 notified the same day. SEBI's LODR FAQs answer the provider questions in more detail than most paid guidance, and ICSI's compendium on BRSR gathers the trail into one document.

Then send the applicability memo to the statutory auditor and to the assurance or assessment provider at the same time, so all three of you agree on which layers apply before anyone starts drafting.