BRSR Core: A Practical Guide for Procurement — What Indian Mid-Cap Manufacturers Are Preparing

BRSR Core (Business Responsibility and Sustainability Reporting Core) is a mandatory disclosure framework established by India's securities regulator SEBI in 2023. What fundamentally sets it apart from traditional self-reported disclosures is its requirement for "reasonable assurance" — verification by an audit firm — covering nine Leadership Indicators. Simply filling in numbers on a disclosure form is not enough; the calculation basis and boundary definitions behind those numbers are also subject to assurance.

BRSR vs. BRSR Core — The Full Framework Picture

BRSR is the name of the overall non-financial information disclosure framework required of listed companies in India. SEBI mandated it in 2021, with phased expansion beginning from the top 500 companies. In 2023, a subset of stricter, verified disclosure items called "BRSR Core" was added to the BRSR framework.

Of the nine BRSR principles (business ethics, employee welfare, environment, consumer protection, etc.), nine specific items from the selective Leadership Indicators have been designated as BRSR Core — and only these require reasonable assurance.

The nine BRSR Core metrics are: 1. Greenhouse gas (GHG) emissions intensity 2. Water consumption intensity 3. Energy consumption intensity (including renewable energy ratio) 4. Waste generation intensity 5. Value chain disclosure (voluntary → direction toward future mandatory) 6. Occupational health and safety metrics 7. Gender pay gap 8. Community development expenditure 9. Effectiveness of grievance redressal mechanisms

For manufacturing procurement professionals, the three most critical metrics are GHG emissions intensity (1), energy consumption intensity (3), and value chain disclosure (5).

What Happens in FY26-27 — Phased Rollout Schedule and Target Companies

SEBI is expanding BRSR Core applicability in phases, starting from the highest market-cap companies.

Starting with the top 150 companies in FY23-24, this schedule expands to the top 1,000 in FY26-27. Indian listed mid-caps frequently transacting with Japanese companies — manufacturers in the roughly $360 million to $1.8 billion range (₹3,000–₹15,000 crore) — are heavily concentrated among companies entering scope for the first time in this final phase. Even before mandatory compliance, an increasing number of companies are receiving ESG supplier questionnaires from major Western export customers ahead of schedule, meaning regulatory and market demands are converging simultaneously.

Three Axes That Matter for Manufacturing Procurement Among the Nine Attributes

BRSR Core covers nine attributes, but in the context of procurement evaluation for manufacturing, the practical weight narrows to three key areas.

On third-party assurance for Scope 1 & 2: the granularity of energy data at the factory level is a critical requirement. Even if electricity consumption can be tracked from utility invoices, whether energy intensity can be calculated in relation to production output is a separate question. Before attempting emissions calculations, the practical foundation is whether energy metering is in place for each manufacturing line.

Leading Companies vs. Those Still Preparing — A Wide Gap in Field Readiness

Even within the listed mid-cap universe, readiness speed varies significantly by export orientation and sector.

Export-oriented leaders include Sundram Fasteners (approximately $720 million, auto components, ~40% export ratio) and Bharat Forge (approximately $1.8 billion, forging, Europe/US export). Sundram is advancing its SBTi certification application and has begun tracking Scope 3 value chain emissions. Early CBAM-related data requests from European customers have driven accelerated action. Bharat Forge has continued CDP responses and has experience obtaining third-party assurance. There are confirmed cases of EcoVadis scores being shared with European Tier 1 customers.

In contrast, companies like RACL GearTech (gear components, mid-size) are managing compliance through their corporate planning teams rather than dedicated sustainability staff. The challenge is less about data granularity and more about prioritizing which metrics to calculate first. Cosmo Films (approximately $300 million, film packaging, Europe/US export), while not a direct CBAM target given its packaging materials character, is closely monitoring changes in its European customers' ESG questionnaire requirements.

BRSR Core Reasonable Assurance — What Is Required in Practice

Reasonable assurance is a higher level of assurance than "limited assurance," approaching the level required in financial auditing. In practice, the following are required:

Documentation of calculation basis: Documenting the formulas, emission factors used, and aggregation boundaries for emissions and energy consumption data so that assurance providers can trace them.

Metering infrastructure: Actual electricity consumption readings must be obtained via factory-level meters. In some cases, proportionally allocated values from multi-tenant buildings cannot support assurance.

Selection of third-party assurance providers: Major firms including KPMG, Deloitte, and Bureau Veritas offer services, as do independent environmental consultants within India. Costs vary by company size and number of metrics, with initial engagements typically in the range of ¥1–5 million.

How to Integrate Into Supplier Evaluation — A Three-Point Screening Approach

Companies that satisfy all three of these criteria can be assessed as having built a substantive disclosure infrastructure ahead of the FY26-27 mandatory deadline. Conversely, companies near their applicable phase without CDP or EcoVadis response histories are likely to face urgency around data preparation over the next 12 to 18 months. Asking suppliers "when do you plan to obtain assurance?" from the procurement side is a key lever for avoiding reactive supply chain risk.

Note that value chain reporting was changed to voluntary status for FY25-26 under SEBI's March 2025 circular. While not mandatory, leading customers are already requiring suppliers to submit Scope 3 data in their questionnaires. This can be easily overlooked if one tracks only the regulatory mandatory schedule.