BRSR Assurance

SEBI circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated July 12, 2023 mandates assurance on BRSR Core KPIs for the top 150 listed entities by market cap from FY 2023-24, the top 250 from FY 2024-25, and the top 500 from FY 2025-26. The requirement flows from Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR), which requires the BRSR to form part of the Annual Report.

Reasonable assurance requires the practitioner to issue a positive-form conclusion that BRSR Core indicators are free from material misstatement and involves more extensive evidence-gathering; limited assurance results in a negative-form conclusion (nothing came to our attention) with lighter procedures. SEBI has phased in reasonable assurance for higher market-cap cohorts from FY 2024-25 per the July 2023 circular. Both engagement types are conducted under ISAE 3000 (Revised) as adapted by ICAI in its Technical Guide on Sustainability Assurance Engagements (2023).

The assurance must be performed by a Chartered Accountant holding a valid Certificate of Practice, as SEBI has not yet recognised non-CA sustainability assurers for listed-entity BRSR. The engagement partner must demonstrate competence in sustainability reporting and maintain independence under the ICAI Code of Ethics 2020. ICAI guidance recommends applying ISAE 3000 (Revised) and documenting specific capability — generalist audit experience alone is insufficient.

BRSR Core KPIs include Scope 1 and Scope 2 GHG emissions (reported in tCO2e using IPCC AR6 GWP values), energy intensity (GJ per rupee of turnover), water withdrawal by source (kilolitres), waste generated by type, and number of value-chain partners assessed on ESG criteria. Evidence examined includes utility bills, fuel purchase records, emission-factor workings, board-approved measurement methodologies, and ERP data. All KPIs are disclosed under Section C (Principle-wise Performance) of the BRSR format appended to the SEBI LODR circular.

The engagement runs in three phases: planning (materiality assessment, risk identification per KPI, engagement letter), fieldwork (document review, walkthroughs with sustainability and operations teams, data testing against source records, site visits for material KPIs), and reporting (issuance of the assurance report for inclusion in the Annual Report filed under Regulation 34(2) of SEBI LODR). For a mid-size top-500 company, the process typically takes 4-6 weeks from data readiness to signed report. Early engagement — ideally in Q4 of the financial year — avoids compressed timelines before the Annual Report deadline.