Integrated Reporting in India: What It Is, Whether It's Mandatory and How to Start One

Type "integrated reporting" into a search box in India and the suggestions tell you what people want to know: what it is, whether it's mandatory, how it differs from an annual report, what the six capitals are, and where the SEBI circular is. Most of the answers online were written before 2022, when the framework changed hands, or by firms that would like to sell you the report. This is the explainer we wanted to point clients to and couldn't find, so we wrote it, with the source documents linked.

What an integrated report is

The definition is in paragraph 1.1 of the International <IR> Framework, and it's worth reading in full because every other idea in the Framework hangs off it:

"An integrated report is a concise communication about how an organization's strategy, governance, performance and prospects, in the context of its external environment, lead to the creation, preservation or erosion of value over the short, medium and long term."

Three things in that sentence do most of the work. "Concise" is a requirement, not a hope. "Creation, preservation or erosion of value" means the report is supposed to say when value is being lost, not only when it's being made; the word "erosion" was added in the 2021 revision precisely because most reports only described creation. And "over the short, medium and long term" means the time horizon is longer than the financial year the report covers.

The Framework also says who the report is for. "The primary purpose of an integrated report is to explain to providers of financial capital how an organization creates, preserves or erodes value over time." That's the investor and the lender. Other stakeholders benefit, but they aren't the audience the document is written for, which is the cleanest way to separate it from a sustainability report.

The idea behind the report is integrated thinking: "the active consideration by an organization of the relationships between its various operating and functional units and the capitals that the organization uses or affects." A company that runs its strategy, risk, finance and sustainability functions in one conversation will find the report easy to write. One that doesn't will find the report exposes the gap.

Is integrated reporting mandatory in India? No, and here's the paper trail

SEBI's circular of 6 February 2017 (SEBI/HO/CFD/CMD/CIR/P/2017/10) is the document people are looking for when they type "sebi circular on integrated annual report". It is four pages long and it is advisory throughout. Paragraph 7 is the operative part:

"a. Integrated Reporting may be adopted on a voluntary basis from the financial year 2017-18 by top 500 companies which are required to prepare BRR. b. The information related to Integrated Reporting may be provided in the annual report separately or by incorporating in Management Discussion & Analysis or by preparing a separate report (annual report prepared as per IR framework). c. In case the company has already provided the relevant information in any other report prepared in accordance with national/international requirement / framework, it may provide appropriate reference to the same in its Integrated Report so as to avoid duplication of information. d. As a green initiative, the companies may host the Integrated Report on their website and provide appropriate reference to the same in their Annual Report."

"May", four times. The circular reproduces the IIRC's seven guiding principles and six capitals, links to the 2013 Framework, and asks nothing to be filed. The "top 500" was the Business Responsibility Report population of the time under Regulation 34(2)(f); that population became the BRSR top 1,000 in 2021, but the integrated reporting advice was never re-pegged to it.

What has happened since is the part most explainers miss. SEBI consolidates its LODR circulars into a master circular, most recently on 30 January 2026, and paragraph 4 of that document says the circulars listed in its appendix "shall stand rescinded to the extent they relate to compliance with" the LODR Regulations. The 2017 integrated reporting circular is item 17 in that appendix. The body of the master circular, 291 pages, has no integrated reporting chapter. The phrase appears once, in the BRSR section at paragraph 1.5:

"The listed entities already preparing and disclosing sustainability reports based on internationally accepted reporting frameworks (such as GRI, SASB, TCFD or Integrated Reporting) may cross-reference the disclosures made under such framework to the disclosures sought under the BRSR."

So the position in October 2026 is this. Integrated reporting is voluntary. There is no SEBI format for it, no filing, no assurance requirement and no penalty. The 2017 circular's guidance on where to put it (annual report, MD&A or separate report) is the last word SEBI has given, and its formal status is now that of a consolidated circular whose content wasn't carried forward. What is mandatory is everything around it: the annual report under Regulation 34, the BRSR for the top 1,000, and BRSR Core assessment or assurance on the glide path we covered in our FY 2026-27 checklist.

Key number: 0 — the number of integrated reporting provisions in the body of SEBI's January 2026 LODR master circular. The 2017 circular sits in the appendix of rescinded circulars; the BRSR cross-referencing clause is the only mention.

None of this makes the report less useful. It means the reason to do one is the investor and the Board, not the regulator. Long-term investors want to know whether the business will still be making money in five years, which the financial statements can't tell them on their own. Lenders and rating agencies want to see how risks are managed. And writing the report forces the Board and management to agree what the business model is, which issues matter most and how they'll be measured.

Don't confuse it with "integrated filing"

Search results now mix two unrelated things. SEBI's circular of 31 December 2024 (SEBI/HO/CFD/CFD-PoD-2/CIR/P/2024/185) introduced Integrated Filing under Regulation 10(1A): a single quarterly submission to the exchanges that bundles the statement on investor grievances and the corporate governance compliance report (Integrated Filing (Governance), within 30 days of quarter-end) and the related party transaction disclosure, loan default statement and financial results (Integrated Filing (Financial), within 45 days, or 60 for the last quarter). It is a compliance mechanism, it is mandatory, and it has nothing to do with the integrated report. If your query is "integrated corporate governance report due date", that's the document you want.

Who maintains the Framework now

The 2017 circular refers to the International Integrated Reporting Council, and many Indian reports still do. The IIRC no longer exists as a separate body. It merged with the Sustainability Accounting Standards Board in 2021 to form the Value Reporting Foundation, and the Value Reporting Foundation was consolidated into the IFRS Foundation in August 2022. Since then the International Accounting Standards Board and the International Sustainability Standards Board have been jointly responsible for the Framework, which is why it now lives at ifrs.org.

The current text is the January 2021 revision. In April 2024 the two boards "reaffirmed their support of the Integrated Reporting Framework", decided not to start a dedicated standard-setting project on integration in reporting for now, and pointed to the IASB's management commentary work as a stepping stone. That work is now finished: the IASB issued the revised IFRS Practice Statement 1 Management Commentary in June 2025. For a preparer that means the Framework is stable, it isn't being converted into a standard, and a report that follows it today won't need rewriting next year. It also means the correct attribution on an "About the Report" page is the IFRS Foundation. Hindustan Zinc's FY 2025-26 report describes the Framework as "now part of the IFRS Foundation"; Infosys's still credits the IIRC. Small thing, but it's the kind of thing a reader who knows the subject notices on page 2.

The six capitals

The capitals are the Framework's way of saying that a company runs on more than money. The 2017 SEBI circular lists them as the IIRC did:

Two habits separate reports that use the capitals from reports that decorate with them. The value creation model on the opening pages should carry numbers for inputs and outcomes per capital, not icons. Bharti Airtel's FY 2025-26 report does this with actual figures for towers, base stations, equity and net debt (our review). And the report should say something about trade-offs between capitals, because that is the point of having six. Hindustan Unilever's "Interplay of Capitals" grid, thirty cells each describing how one capital feeds another with an example, is the best treatment we've seen in an Indian report (our review).

The eight content elements are questions, not sections

Paragraph 4.1 of the Framework lists eight content elements. Paragraph 4.3 says they are "stated in the form of questions rather than as checklists of specific disclosures", and paragraph 4.2 says they "are not intended to serve as a standard structure". Companies that treat them as chapter headings produce reports that pass a checklist and read like one. The questions, as the Framework puts them:

• Organizational overview and external environment: what does the organization do and what are the circumstances under which it operates?
• Governance: how does the organization's governance structure support its ability to create value in the short, medium and long term?
• Business model: what is the organization's business model?
• Risks and opportunities: what are the specific risks and opportunities that affect the organization's ability to create value over the short, medium and long term, and how is the organization dealing with them?
• Strategy and resource allocation: where does the organization want to go and how does it intend to get there?
• Performance: to what extent has the organization achieved its strategic objectives for the period and what are its outcomes in terms of effects on the capitals?
• Outlook: what challenges and uncertainties is the organization likely to encounter in pursuing its strategy, and what are the potential implications for its business model and future performance?
• Basis of preparation and presentation: how does the organization determine what matters to include in the integrated report and how are such matters quantified or evaluated?

Read as questions, the weak spots in most Indian reports are obvious. Performance is usually answered for financial capital and asserted for the rest. Outlook is usually a paragraph of macro optimism rather than the "challenges and uncertainties" the question asks for. Basis of preparation is often the best page in the report, because it's the one the Framework specifies most closely: period, boundary, frameworks used, materiality process, assurance, and a statement from those charged with governance. HDFC Bank's and Hindustan Zinc's versions are the models (HDFC Bank review, Hindustan Zinc review).

The seven guiding principles govern how the content is presented: strategic focus and future orientation, connectivity of information, stakeholder relationships, materiality, conciseness, reliability and completeness, and consistency and comparability. The 2017 SEBI circular reproduces them word for word from the IIRC. Conciseness is the one that Indian reports most visibly fail; several of the reports we reviewed this month run past 500 printed pages, and the integrated section is where the length usually comes from.

In practice: if the "About the Report" page can't state the reporting boundary for non-financial data in one sentence, the report isn't ready. Every strong Indian integrated report we've read gets this page right; most weak ones don't have it at all.

Integrated report, annual report, sustainability report, BRSR

People search "integrated report vs annual report" more than almost any other phrasing, and the answer in India is that they're usually the same document.

The annual report is the statutory object: financial statements under the Companies Act, Board's report, MD&A and corporate governance report under LODR, the BRSR as an annexure for the top 1,000. An integrated report is a way of presenting that object. In practice, Indian companies put an integrated front section (typically 60 to 150 pages: about the report, value creation model, strategy, capitals, materiality, risk, governance overview) ahead of the statutory sections and title the whole thing "Integrated Annual Report". Of the ten large-cap reports we reviewed for FY 2025-26, eight use that title; ICICI Bank calls its document an annual report and ITC calls its "Report and Accounts", and both still carry most of the content elements.

A sustainability report under GRI, or the BRSR, is different in audience and in form. It's written for all stakeholders and it's mostly standardised metrics. The integrated report is written for providers of capital and it's mostly narrative that connects the metrics to strategy. The BRSR cross-referencing clause in the master circular is the formal bridge between the two: a company can answer a BRSR question by pointing to the page of the integrated report where it's already covered. The best reports go the other way as well, pulling BRSR Core numbers into the natural and human capital pages with the assurance provider named.

The other document people compare is the investor presentation, which is a quarterly selling document with no framework and no assurance. An integrated report is the annual, Board-approved version of the same story, with the trade-offs left in.

How Indian companies actually do it

Because nothing is prescribed, practice varies, and the variation is informative. From the first ten reports we reviewed:

• Every one that calls itself integrated has an "About the Report" page. The good ones (HDFC Bank, Hindustan Zinc, HUL, TCS, Airtel) name the Framework, the period, the boundary, the other standards used (GRI, TCFD, SDGs, BRSR) and the assurance arrangements. Airtel adds a Board and management "Accountability Statement", which is what the Framework's paragraph on responsibility asks for and few provide.
• Value creation models range from a graphic with icons to a two-page spread with inputs and outcomes per capital in numbers. Airtel and HUL are at the numeric end.
• Materiality is where BRSR and integrated reporting now meet. Hindustan Zinc's double materiality assessment, 21 topics from more than 200 candidates with a financial threshold for each, is the most rigorous we've seen in India; HDFC Bank's separates impact and financial materiality per topic.
• Scores in our seven-criterion card, which includes "integrated thinking and the capitals" as one criterion, ranged from 30 of 35 (Hindustan Zinc) to 21 (ITC). The full comparison is in the table at the end of each review, for example in the TCS review.

There is no official count of Indian companies producing integrated reports, and any number you see quoted is a survey estimate. What's observable is that the practice is concentrated in the top 100 by market capitalisation, that it's spreading in banks and IT services, and that the 2017 circular's "top 500" population was never the real adopter base.

Starting one: what to decide before you brief the agency

A first integrated report is a governance decision before it's a design job. The questions worth settling early:

• Placement, per the 2017 circular's paragraph 7(b): an integrated front section in the annual report is the Indian norm and the cheapest route. A separate integrated report doubles the work and rarely gets read.
• Boundary: which entities and which sites are inside the non-financial data, and does that match the BRSR boundary? Say it on the About the Report page.
• The value creation model: agree the inputs and outcomes per capital as numbers with the finance, HR, operations and sustainability leads before anyone draws it.
• Materiality: one assessment, used for both the integrated report and the BRSR. Two assessments with different topic lists is a finding waiting to happen.
• Cross-referencing: decide which BRSR questions will point to the integrated section, and make the page references real.
• Sign-off: a sentence from the Board or a Board committee confirming it has reviewed the report and considers it presented in accordance with the Framework. The Framework asks for it; the better Indian reports include it.
• Length: set a page budget for the integrated section and hold it. Conciseness is a guiding principle, and it's the one nobody enforces.

What changes for your teams

The first year is more work, and the work starts earlier. The design is the smallest part of it.

• Finance stops being the only team with numbers in the report. It still owns the financial statements, but now also helps put numbers on the other five capitals and checks that the front section, the MD&A and the BRSR quote the same figures. Expect to keep one register of key numbers that every section draws from.
• Company secretarial keeps every statutory section it has today. What's new is the governance story: how the Board oversees strategy and risk, in plain language rather than attendance tables. The CS usually also coordinates the Board's responsibility statement.
• Investor relations usually becomes the editor: it leads the integrated section, shapes the strategy and business model pages, runs the agency and makes sure the Chairman's letter, the strategy pages and the MD&A tell one story.
• Sustainability moves closer to the centre, because ESG data that used to live only in the BRSR now appears in the front section, linked to strategy, and has to be ready and checked earlier.
• HR, operations and business heads become contributors rather than data providers: why people were trained, what the new plant changed, what the plan is for the risks the report names.
• The Board agrees the business model, the material issues and the risks before drafting starts, and signs off the integrated section at the end.

The second year is much easier. The value creation model, the material-issue list and the data flows already exist, and you update them instead of building them.

A first-year timeline

For a company with a 31 March year end, plan for one full reporting cycle:

Our guide to starting the annual report has the statutory calendar this fits into.

Common mistakes in a first integrated report

• A brochure instead of a report. Big claims and photography with no numbers behind them. Investors notice.
• No bad news. The Framework's definition says "creation, preservation or erosion of value". A year in which nothing went wrong isn't believable, and it makes the rest of the report less so.
• Two stories in one book. The front section says one thing, the MD&A another, and the BRSR has different numbers. One register of numbers prevents it.
• Too long. Conciseness is a guiding principle. The good long reports help readers find the important parts fast; most don't.
• The wrong rulebook. Crediting the IIRC, or citing the 2013 Framework, signals on page 2 that nobody checked.

Should you move?

Three questions decide it. Do your investors, lenders or Board want to understand the business better than the current report lets them? That's the strongest reason. Can the company agree internally on its business model, its material issues and how it will measure them? If not, the report will expose it, and it may be worth doing that internal work first. And is there time for a cross-team project that starts in October? If this year is too tight, start smaller: a business model page, a materiality page and a sharper strategy section in the current report, then complete the move next year.

The Framework is free to download and shorter than most annual reports' governance section. The place to start is paragraph 4.1: eight questions. If the company can answer them honestly in a Board meeting, it can publish an integrated report. If it can't, the report will show it, which is rather the point.