BRSR Applicability FY 2026-27: Who Files, Who Must Get BRSR Core Checked, and Who Can Skip It

For FY 2026-27, the top 1,000 listed companies by market capitalisation must file a Business Responsibility and Sustainability Report (BRSR), and for the first time all 1,000 must also get their BRSR Core checked by a third party. Value chain disclosure stays voluntary. That is the short answer. The useful answer has three layers, because each test has its own legal source, and old guidance notes still mix them up.

This page was first published for FY 2025-26 and has been updated for FY 2026-27, using SEBI's LODR master circular of 30 January 2026 and the consolidated LODR Regulations.

Is BRSR applicable to my company for FY 2026-27? Three questions, one answer sheet

Ask three questions, in this order:

In FY 2025-26, layers one and two covered different populations: 1,000 and 500. In FY 2026-27 they cover the same 1,000 companies. So if you file a BRSR this year, you also need a BRSR Core provider. The gap that let companies ranked 501 to 1,000 file without external checking has closed.

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

Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR) puts the BRSR inside the annual report for the top 1,000 listed entities by market capitalisation. Other listed companies may file one voluntarily. Many do, usually because a lender, an index provider or a large customer has asked.

The format is not in the regulation. It sits in Section IV-B of SEBI's master circular for listed entities, now the version dated 30 January 2026. The BRSR format is Annexure 16, the guidance note is Annexure 17, and the BRSR Core format is Annexure 17A. In a board note, cite both: the regulation for who must file, and the master circular for what goes in.

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

BRSR Core is the smaller set of numbers inside the BRSR that a third party must check. It has key performance indicators under nine ESG attributes, such as greenhouse gas emissions, water, energy, waste, safety and gender pay. Our BRSR vs BRSR Core explainer lists them all.

The rollout followed the glide path set by SEBI's circular of 12 July 2023. Paragraph 2.4.2 of the master circular now states it:

FY 2026-27 is the last and largest step. About 500 companies, most of them mid-caps, are doing this for the first time. Many have no full-time sustainability team.

The type of check is the company's choice. Since SEBI's circular of 28 March 2025, the requirement reads "assessment or assurance". Paragraph 2.1 of the master circular defines assessment as a third-party assessment under standards developed by the Industry Standards Forum (ISF) in consultation with SEBI. The ISF is made up of ASSOCHAM, CII and FICCI, working under the stock exchanges.

In practice: a first-time company with thin data may pick assessment for FY 2026-27 and move to assurance once its numbers have been through one cycle. Record the reasoning in a board minute. Paragraph 4.1 of Section IV-B makes the board responsible for checking the provider's expertise.

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

SEBI's LODR FAQs answer this directly. Assessment or assurance of BRSR Core is profession agnostic, so the provider need not be a chartered accountant. The board must still be satisfied that the provider has sustainability expertise.

The independence rule is stricter than the credential rule. Paragraph 4.2 of Section IV-B says the provider and its associates must not sell products, or provide any non-audit, non-assessment or non-assurance service, to the listed entity or its group. The FAQs list examples that disqualify a provider:

• risk management and consulting
• project management
• investment advisory and investment banking
• design and implementation of information systems
• outsourced financial services, actuarial work, and accounting and bookkeeping

SEBI calls that list indicative, not complete. "Group" means the holding company, subsidiaries, associates and joint ventures. Third-party certifications, tax audit, system audit and tax filing can sit alongside the engagement if the company concludes there is no conflict.

Two answers are worth pinning to the wall:

• The internal auditor of the company or its group cannot be appointed.
• The statutory auditor can be, subject to the same competence and independence conditions.

SEBI does not prescribe one standard. The FAQs accept ISAE 3000, ISSA 5000 and ICAI's standards, including SSAE 3000 and SAE 3410 for greenhouse gas statements. The report must say which standard was used. One change is coming for the following year: ICAI issued SSA 5000 and a Framework for Sustainability Assurance Engagements in September 2026. SSA 5000 applies to assurance on sustainability information for periods beginning on or after 1 April 2027, and SSAE 3000 and SAE 3410 will be withdrawn once it takes effect. FY 2026-27 engagements are unaffected, but engagement letters for FY 2027-28 will need to name the new standard.

Layer 3: is value chain ESG disclosure mandatory in FY 2026-27?

No. Paragraph 3.4.1 of the master circular makes value chain ESG disclosure apply to the top 250 "on a voluntary basis from FY 2025-26". Paragraph 3.4.2 makes its assessment or assurance voluntary from FY 2026-27. SEBI's FAQs add that the relaxation continues unless a later circular or regulation changes it.

If you do disclose, the scope rules are precise (paragraphs 3.1 to 3.6):

• Value chain means upstream and downstream partners that each account for 2% or more of your purchases or sales by value.
• You may limit disclosure to partners covering 75% of purchases and sales.
• You must disclose the percentage of total sales and purchases your reported partners cover.
• In your first year, prior-year value chain figures are voluntary.

Key number: 2% — the share of your purchases or sales at which a single supplier or customer comes into scope for value chain disclosure.

Voluntary does not mean irrelevant. Lenders and large customers increasingly ask for supplier emissions data. A top-250 company that will not report should say so in one line, rather than leave the section blank.

How the market-capitalisation list is drawn

Regulation 3(2) of LODR sets the method. At 31 December each year, every stock exchange ranks listed companies by their average market capitalisation from 1 July to 31 December. This replaced the old single-day ranking as on 31 March, effective from the list prepared on 31 December 2024, as Business Standard reported when SEBI proposed it.

For FY 2026-27, the relevant list is the one prepared as on 31 December 2025.

Regulation 3(2)(b) sets the start date. A company that enters a threshold for the first time must comply from three months after 31 December (1 April) or from the start of the next financial year, whichever is later. Its proviso is specific to BRSR. A first-time company must put systems in place for the BRSR by that date. It then discloses the BRSR, and the assessment or assurance of BRSR Core, in the annual report for that financial year. So a company that entered the top 1,000 on the December 2025 list should already have its systems running, and will report on FY 2026-27.

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

Not straight away. This rule catches companies out. Regulation 3(2A) says market-cap-based obligations continue unless the company's rank keeps it outside the threshold for three consecutive years. Regulation 3(2B) then says the obligation ends at the end of the financial year after 31 December of that third year.

In practice: if you drop out of the top 1,000 on the December 2026 list, you still file. You stop only after you have stayed outside on three consecutive December lists, and only from the end of the following financial year. Dropping out starts a clock. It does not switch the obligation off.

When is BRSR due? It has no standalone deadline

There is no separate BRSR filing date. The BRSR is part of the annual report under Regulation 34(2)(f). Its timing follows your annual report and your AGM, not a quarterly results clock.

That sounds like relief, but it works the other way. The BRSR Core check has to be planned backwards from the date the annual report goes to print. For most Indian listed companies, that means provider field work in April and May 2027 on data your plants and offices are generating now. For FY 2026-27, half the data year is already over.

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

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

Start with a one-page applicability memo for the audit committee. It should state:

• your rank on the list prepared as on 31 December 2025, and where that rank came from
• whether you are inside the top 1,000 (BRSR and BRSR Core) and the top 250 (value chain)
• whether you chose assessment or assurance, and why

First-time BRSR Core companies (ranked 501 to 1,000) should, by the end of the 2026 calendar year:

• appoint a provider, after a written conflict check covering the whole group
• name the standard in the engagement letter, scoped against Annexure 17A
• build an attribute register: each KPI, its data owner, its source system and where the evidence is kept
• fix the reporting boundary so it matches Section A of the BRSR

Our BRSR Core FY 2026-27 checklist sets out the month-by-month timeline.

Company secretaries should 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 expect questions on the FY 2026-27 calls about whether the company assured or assessed its BRSR Core, and why. Teams already dealing with unsolicited ESG ratings and Regulation 30 will know the pattern: the market forms a view of your sustainability data whether or not you control the timing.

Sustainability heads in the top 250 can use the voluntary status of value chain disclosure as a preparation year. Identify your 2% partners, send a pilot data request, and see how many can answer at all.

Before the next audit committee paper

Keep the references in one file so it survives staff changes:

• SEBI LODR master circular, 30 January 2026: Section IV-B, paragraphs 2.4.2 (BRSR Core), 3.4.1 and 3.4.2 (value chain) and 4.1 and 4.2 (provider), with Annexure 17A
• Consolidated LODR Regulations: Regulation 34(2)(f) and Regulation 3(2), 3(2A) and 3(2B)
• SEBI's LODR FAQs: provider eligibility and standards
• ICSI's compendium on BRSR: the circular trail in one document

Then send the applicability memo to the statutory auditor and the BRSR Core provider at the same time, so all three agree which layers apply before anyone starts drafting.