Question 1

What is BRSR and who must comply?

Accepted Answer

The Business Responsibility and Sustainability Report (BRSR) is mandated by SEBI for the top 1,000 listed companies by market capitalisation (SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023). BRSR Core (the subset requiring assurance) was made mandatory for top 150 companies from FY 2023-24, top 250 from FY 2024-25, and top 500 from FY 2026-27. BRSR Core metrics cover 9 KPIs across energy, water, GHG, waste, and supply chain sustainability.

Question 2

What assurance standard applies to BRSR Core?

Accepted Answer

SEBI requires "Reasonable Assurance" on BRSR Core KPIs — the highest level of assurance, equivalent to audit opinion. The ICAI has issued ISAE 3410 (Assurance Engagements on Greenhouse Gas Statements) and a separate BRSR assurance guidance. Only CAs with relevant competence (ICAI Certificate Course on Sustainability Reporting Assurance) can issue BRSR Core assurance. The assurance report is appended to the Annual Report.

Question 3

What GHG accounting framework applies in India?

Accepted Answer

The GHG Protocol (WRI/WBCSD) is the globally accepted framework — also used for BRSR. Scope 1: direct emissions (fuel combustion, company vehicles, fugitive emissions). Scope 2: indirect emissions from purchased electricity/heat. Scope 3: value chain emissions (upstream suppliers, downstream use of products) — not yet mandatory for BRSR Core but increasingly reported. GHG intensity is the BRSR Core metric — absolute emissions are disclosed but intensity per ₹ of turnover or per unit of output is the comparability measure.

Question 4

What are TCFD recommendations and how do they apply to Indian companies?

Accepted Answer

The Task Force on Climate-related Financial Disclosures (TCFD) recommendations (2017) structure climate disclosures around: (1) Governance — Board oversight of climate risk; (2) Strategy — climate risks/opportunities and financial impact; (3) Risk Management — processes for identifying and managing climate risk; (4) Metrics and Targets — GHG emissions, water, energy. BRSR is modelled on TCFD principles. SEBI has aligned BRSR E&S disclosures with TCFD recommendations for financial materiality.

Question 5

Can a CA firm provide ESG rating or advisory services?

Accepted Answer

CA firms can provide: (1) GHG inventory computation and verification; (2) BRSR Core assurance under ISAE 3410; (3) ESG strategy advisory — materiality assessment, target setting, framework alignment (GRI, SASB, TCFD, ISSB S1/S2); (4) supply chain ESG audit; (5) green/sustainable finance advisory (IFC Green Bond Principles, SEBI Green Bond Framework). ESG ratings (quantitative scoring of a company's ESG profile) are a SEBI-regulated activity under the ESG Rating Providers framework — only SEBI-registered ERPs can issue ratings.

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