Market regulator SEBI has specified a “glide path” for the mandatory “reasonable assurance” of Core Business Responsibility and Sustainability Reporting (BRSR Core), which is a novel ESG reporting framework.

From financial year 2023-24, the top 150 listed companies by market capitalisation would have to subject their BRSR Core to “reasonable assurance”, SEBI said in a circular issued on Wednesday.

In financial year 2024-25, the top 250 listed entities would have to adhere to this “reasonable assurance” norm; in 2025-26, it would be the top 500 listed entities; and by 2026-27 it would be the top 1,000 listed companies, SEBI has stipulated.

It may be recalled that SEBI had recently brought in changes to its listing obligations and disclosure requirement (LODR) regulations to empower itself to specify the date on which this mandatory assurance norm will come into effect and the manner in which such assurance must be obtained from time to time.

The SEBI move to stipulate a glide path for reasonable assurance of ‘BRSR Core’ is expected to provide comfort to investors, regulators and various ESG rating agencies.

Put simply, BRSR Core brings out the critical elements of BRSR and mandates 49 parameters for ESG reporting.  BRSR is intended to ensure quantitative and standardised disclosures on environment, social and governance (ESG) parameters to enable comparability across companies, sectors and time. Such disclosures will aid investment decisions.

Disclosures

SEBI has updated its BRSR format and incorporated the BRSR Core’s new key performance indicators (KPIs). From financial year 2023-24, the top 1,000 listed entities (by market capitalisation) would have to make disclosures as per the updated BRSR format.

ESG disclosure for value chain

SEBI has now stipulated that ESG disclosures for value chain would be applicable to the top 250 listed entities (by market capitalisation) on a comply-or-explain basis from financial year 2024-25. The limited assurance on this would be applicable on a comply-or-explain basis from FY 2025-26.

Assurance provider

SEBI has now directed the boards of listed companies to ensure there is no conflict of interest with the assurance provider appointed for BRSR Core. 

For instance, it must be ensured that the assurance provider or any of the associates do not sell its products or provide any non-audit or non assurance service, including consulting services, to the listed entity or its group entities.

Thumbs up from ICAI

SEBI has taken a path-breaking step by mandating reasonable assurance of BRSR Core, Aniket Sunil Talati, President, ICAI, said.

“The SEBI circular on reasonable assurance is a testimony to the commitment of India towards ESG goals. ICAI worked very closely with SEBI on BRSR Core and ensuring that reasonable assurance is made mandatory to avoid green washing,” Talati said.

Through the Sustainability Reporting Standards Board, ICAI is ensuring that sufficient capacity is built in the chartered accountancy profession to undertake BRSR assurance, he added.

Priti Savla, Chairperson, Sustainability Reporting Standards Board, said that ICAI is leading by example in the mission towards sustainability and is committed to ensuring that chartered accountants contribute significantly to the cause.

EXPERT TAKE

Madhu Sudan Kankani, Partner, Deloitte India, said that the SEBI Circular on BRSR Core Framework for Assurance and ESG Disclosures for Value Chain signifies a significant step forward in improving the quality of ESG reporting in India.

He said that the clear glide path for disclosure and assurance ensures that the top 1000 listed entities (by market capitalization), starting from the top 150, will be required to comply with the BRSR Core framework over the next few years.

This will create a more standardized and comprehensive approach to ESG disclosures, leading to increased transparency and comparability across companies, Kankani added.

“Overall, these developments in ESG reporting and assurance will contribute to building trust among stakeholders, promoting sustainable practices, and facilitating informed decision-making in the Indian business landscape”, he said.

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