Mandatory ESG Reporting in India: A 2025 Checklist for BRSR Compliance for Foreign-Owned Companies

The ESG Tipping Point

In 2025, a multinational subsidiary in India found itself excluded from a major government procurement contract—not because of product quality, but due to weak ESG disclosures. Around 73% of global investors now evaluate companies on ESG metrics before committing capital. With Securities and Exchange Board of India (SEBI)'s revamped Business Responsibility and Sustainability Reporting (BRSR) framework moving from optional to mandatory, foreign-owned companies working in India face a new reality: non-disclosure is no longer an option, but a tangible business risk. Sensible planning now is vital to maintain access to investor capital, export markets and regulatory thresholds.

Why BRSR Matters for Foreign-Owned Entities

India's ESG disclosure landscape has rapidly matured. Since FY 2022-23, the top 1,000 listed companies by market capitalization have been required to submit BRSR reports. For FY 2025-26 onwards, SEBI's sharper "Core" format will apply to the next wave of companies—including foreign-owned enterprises operating as Indian subsidiaries—requiring third-party verification and value-chain disclosures. The core pain-points for foreign-owned companies are threefold: (a) lack of prior ESG data capture in India, (b) difficulty aligning global ESG frameworks with Indian formats, and (c) lacking assurance infrastructure locally. To address these, immediate steps include establishing ESG-data systems, aligning your global parent-company disclosures with India's format and contracting a verified auditor in India. Doing this proactively ensures your transition is seamless, avoids last-minute chaos and positions you as a credible partner for global investors seeking ESG-ready exposure in India.

Dissecting BRSR Core — What You Must Comply With

The BRSR Core format divides ESG KPIs around nine principles derived from the National Guidelines for Responsible Business Conduct (NGRBC). Key statistics: the report covers approximately 140 questions—98 mandatory indicators and 42 voluntary "leadership" indicators. For example, in April 2025 SEBI approved green-credits disclosure under Principle 6 and allowed companies to choose "assessment or assurance" rather than only full assurance.

Case Study — Siemens Limited: Early Adopter and Assured BRSR Reporting
Siemens Limited (the Indian subsidiary of Siemens AG) publicly disclosed BRSR Core indicators ahead of SEBI's deadlines, publishing a full Business Responsibility & Sustainability Report that includes reasonable assurance on core metrics and a mapped structure for Scope 1 & 2 emissions and value-chain disclosures. The company treated BRSR as an operational tool — integrating its global DEGREE sustainability framework with India-specific reporting — and used local assurance to boost investor confidence.

Implementation Roadmap & What Comes Next

Your implementation roadmap should begin with an ESG kick-off in India by Q4 2025. The first milestone: capture FY 2024-25 baseline data before the deadline for FY 2025-26 reporting. Next: engage a local assurance or assessment provider and secure your board's sign-off by Q2 2026. Challenges include multi-jurisdictional parent-company ESG alignment, limited Indian assurance capacity and value-chain partner readiness—77% of Indian suppliers still lack formal ESG metrics. Forward-looking insights: as India aligns with global standards like the Corporate Sustainability Reporting Directive (CSRD) and the International Sustainability Standards Board's ISSB disclosures, early-movers will benefit. At CrossVentura Advisory we support foreign-owned companies by helping set up local ESG architecture—from entity registration to assurance pathways—ensuring you're ready as BRSR Core moves toward universal applicability across listed and large unlisted companies.this is slightly more regulatory-accurate, since SEBI hasn’t formally declared it “non-optional” for unlisted foreign subsidiaries yet, though the direction is clear

Guide Section: Quick-Start Checklist for Foreign-Owned Companies

For foreign-owned companies preparing for mandatory ESG reporting under BRSR Core in India, the following checklist provides a clear roadmap to ensure full compliance by FY 2025-26.

1. Establish your data-capture architecture: Appoint an ESG lead in India and begin mapping the 98 mandatory KPIs under the BRSR Core format (part of the total 140 indicators). Start collecting FY 2024-25 baseline data now, as it forms the foundation for your first reporting year.
2. Engage an assurance or assessment provider: Under SEBI's 2025 framework, companies may opt for third-party assurance or independent assessment. Engage a qualified firm—such as your statutory auditor or an accredited sustainability assurance provider—by Q1–Q2 2026 to ensure timely validation before your FY 2025-26 filing deadline.
3. Align your value-chain partners: Identify suppliers and customers that individually represent 2 percent or more of your purchases or sales, and begin collecting their ESG data. SEBI's latest guidance requires reporting for value-chain partners covering the top 75 percent of total value-chain spend, ensuring transparency across upstream and downstream operations.
4. Prepare for green-credit disclosures: From FY 2024-25, companies must disclose any generation or procurement of green credits under Principle 6 of the BRSR Core. This includes renewable-energy credits, carbon offsets, or verified emission reductions that contribute to your decarbonisation strategy.
5. Build your board and investor narrative: Integrate your global ESG strategy with India's BRSR Core framework. Develop an investor-ready disclosure narrative that connects your Indian entity's performance with global sustainability targets, enabling consistency across jurisdictions and strengthening investor confidence.

FAQs

Q1: Does this apply only to listed companies?
No—currently the mandatory scope covers top listed companies. However, subsidiaries of listed foreign groups will increasingly be required to assist parent-company disclosure and value-chain reporting.

Q2: Can we use global ESG frameworks instead of BRSR?
While global frameworks (GRI, TCFD) are useful, BRSR has unique Indian-specific indicators and timelines; aligning the two is strongly recommended.

Q3: What happens if we miss the FY 2025-26 reporting?
Beyond regulatory risk, poor ESG disclosure may reduce access to global capital—in 2024, 42% of deals globally screened for inadequate ESG metrics.

Recent Notifications/Updates

In March 2025, SEBI issued a circular allowing entities to choose between "assessment or assurance" for BRSR Core disclosures and introduced green-credit disclosures under Principle 6 from FY 2024-25. In December 2024, SEBI deferred mandatory value-chain disclosures to FY 2025-26 and refined VCP thresholds to vendors representing ≥ 2% of purchase/sales.

Future-Proofing Your India Entry with ESG

As India's ESG regulatory tide rises, foreign-owned companies must treat BRSR compliance not as a burden but as a strategic differentiator. Early adaptation gives you a distinct advantage—support from CrossVentura ensures you don't just comply, but lead. Stay tuned for our next piece