When we created our first BRSR report for a mid-cap company with 45 project sites, the framework felt overwhelming: 58 pages, three sections, nine principles, Essential vs. Leadership indicators. Here’s how to navigate it all.
The Big Picture: 3 Main Functions
Three Main Sections:
- Section A: General Disclosures (20% effort – company basics)
- Section B: Management & Process (30% effort – policies/governance)
- Section C: Principle-wise Performance (50% effort – quantitative ESG data)
Total: 300+ disclosure points
Key insight: Section C is where companies struggle—it’s quantitative, requires 3-year trends, and needs third-party assurance for BRSR Core.
Section A: General Disclosures
What It Covers
Corporate identity, business operations, products/services, workforce details.
Quick Breakdown
Corporate Identity (10 points)
- CIN, name, address, stock listings
- Paid-up capital, contact details
Easy win: Pull from existing ROC filings
Products & Services (10 points)
- Business activities with NIC codes
- Markets served (local/national/international)
- Geographic locations
Pro tip: Link NIC codes to sustainability impact for materiality assessment
Employees & Workers (20 points)
- Permanent, temporary, contractual employees
- Manufacturing/operational workers
- Gender breakdown, differently-abled employees
Critical mistake: BRSR defines “employees” vs. “workers” differently than HR systems:
- Employees = Managerial/administrative
- Workers = Manufacturing/operational
- Recalculate using BRSR definitions.
Holding/Subsidiary Companies (5 points)
- List all group entities
- Whether they participate in BRSR
Section B: Management & Process
What It Covers
ESG governance, policies, processes, stakeholder engagement across 9 principles.
Time-saver: If policies don’t exist, create Board-approved versions NOW. Policy existence = compliance checkbox.
Principle 1: Business Ethics
- Anti-corruption policy
- Conflict of interest mechanisms
- Ethics training programs
Principle 2: Product Lifecycle
- % products with sustainable sourcing
- % products recyclable/reusable
Reality check: Most score low here Year 1. Report current state + targets.
Principle 3: Employee Well-being
- Employee benefits details
- Health & safety systems
- Training hours per employee
- Performance review processes
Data source: HR systems (requires aggregation)
Principle 4: Stakeholder Engagement
- Stakeholder identification process
- Feedback channels
- Material issues identified
Key: Document your materiality assessment process
Principle 5: Human Rights
- Human rights policy
- Value chain due diligence
- Complaint mechanisms
Common gap: Start value chain assessment with Tier 1 suppliers, expand over time
Principle 6: Environment
- Environmental management systems
- Impact assessments
- Reduction targets
Strategy: Set realistic targets. Better to achieve modest goals than miss ambitious ones.
Principle 7: Policy Advocacy
- Trade association memberships
- Public policy positions
Usually straightforward—limited activity for most companies
Principle 8: Inclusive Growth (Unique to India)
- CSR spending details
- Impact assessments
- Preferential procurement from disadvantaged groups
Principle 9: Customer Value
- Customer complaint mechanisms
- Data privacy & cyber security
- Product recalls (if any)
Data source: Customer service, IT security, legal teams
SECTION C: Principle-wise Performance (170+ Points)
The Heavy Lifting
Quantitative ESG data. Each principle has:
- Essential Indicators: Mandatory ✓
- Leadership Indicators: Advanced (recommended but optional)
BRSR Core: Several indicators require third-party assurance.
Principle 3: Employees (45 indicators – LARGEST)
Essential disclosures:
- Employees/workers by gender, category, employment type
- Differently-abled representation
- Fatalities (aim: zero)
- Lost Time Injury Frequency Rate (LTIFR)
- Training hours by gender
- Performance reviews % (M/F)
- Median remuneration (M/F) – Pay equity disclosure
- Return to work rate post-parental leave
- Working condition complaints
Data sources: HR, HSE, training platforms
Critical: Pay equity data is sensitive—needs CFO/CEO sign-off
BRSR Core: Multiple metrics need assurance
Principle 6: Environment (50+ indicators – SECOND LARGEST)
Essential disclosures:
- Energy consumption (renewable/non-renewable)
- Water withdrawal by source
- Water discharge details
- Air emissions (NOx, SOx, PM)
- GHG emissions – Scope 1 and Scope 2 ✓
- Scope 3 emissions (supply chain—most challenging)
- Waste generated (hazardous/non-hazardous)
- Waste recycling %
- Environmental impact assessments
Data sources: Operations, facility management, EHS teams
BRSR Core: Energy, water, emissions, waste need assurance
Common challenges:
- No meters at all sites
- Scope 3 data from suppliers (rarely available)
- Historical gaps (3-year trend required)
Solution: Report measured data, estimate conservatively for gaps, commit to improvement.
Principles 1, 2, 4, 5, 7, 8, 9 (Combined: 75 indicators)
Key highlights:
- Ethics: Training coverage, disciplinary actions
- Products: Sustainable sourcing %, consumer complaints
- Stakeholders: Input from disadvantaged suppliers
- Human Rights: Minimum wage compliance, training
- Policy Advocacy: Anti-competitive conduct (usually minimal)
- Inclusive Growth: CSR expenditure breakdown
- Customers: Data breaches, product recalls, satisfaction %
Your 20-Week Action Plan
Week 1: Map requirements to data sources
- Which departments own which data?
- Available vs. needs creation?
Week 2-4: Section A (build momentum)
- Corporate identity, workforce data
- Easiest section—quick wins
Week 5-8: Section B (policies)
- Create Board-approved policies if missing
- Document existing processes
Week 9-20: Section C (marathon)
- Start with Principles 3 & 6 (most intensive)
- Focus Essential indicators first
- Accept Year 1 gaps + improvement plan
Critical: Engage assurance provider early—they’ll specify evidence requirements.
Three Key Lessons
1. Don’t chase perfection Year 1
- 70-80% accuracy with transparency > 100% delayed
- Report current state, acknowledge gaps, show improvement plan
2. Technology is non-negotiable
- Excel fails at 300 points × 3 years = 900 data elements
- ESG platform investment pays off Year 2
3. Cross-functional ownership essential
- One person can't own 300 disclosures
- Create BRSR task force across departments
Need Help?
We’ve guided 50+ companies through all 300+ BRSR disclosures.
Free 30-min consultation: Readiness assessment + customized roadmap
foresttwin@fusionpact.com | Linkedin | www.foresttwin.com
Based on real experience creating complete BRSR covering all 300+ points for mid-cap company with 45 project sites.