The senior director had recently cleared the ESG Director Certification Program under one of the best Gurus that India has. He was coming to grips with BRSR. He realised that quite a few treated ESG as an annexure, something that belonged to the sustainability team, not the board pack.
But by the end of financial year 2026, that assumption no longer survived contact with reality. India’s BRSR framework has moved from disclosure exercise to governance test, and the companies that still see it as an annual filing are already falling behind the ones building systems, controls, and accountability around it.
The story began more than a decade earlier, when India’s reporting journey started with the old Business Responsibility Reporting regime and then matured into BRSR, mandated for the top 1,000 listed entities from FY 2022-23. That first year was largely about learning the language of ESG in a structured form. Energy, emissions, diversity, ethics, labor, water, waste, and governance all had to be translated into a common framework rooted in the National Guidelines on Responsible Business Conduct.
Many companies did what responsible organizations do when a new law lands on their desks. They assembled data, checked boxes, and filed. But the senior director could see that filing a report and building a reporting engine were not the same thing.
The next step came when SEBI introduced BRSR Core in 2023, a focused set of high-priority KPIs designed to push companies beyond broad narrative disclosure and toward verifiable data. By FY 2023-24, the top 150 companies were already being asked to report under this tighter lens, with the scope expanding gradually toward the top 1,000 by FY 2026-27. Then the March 28, 2025 amendment added flexibility by allowing either reasonable assurance or assessment, while also reshaping value-chain disclosure requirements and making the framework more practical without weakening its intent. In the boardroom, that felt like a line being drawn. Sustainability could no longer live on trust alone. it now had to stand up to scrutiny.
What this has exposed is not merely a reporting gap but a systems gap. A 2024 CFA Institute, NSE, and CFA Society India study of 300 companies found progress in reporting coverage and quality, but also persistent inconsistencies in data quality, definitions, units, and comparability.
The senior director tried to get deeper into this area. One function held the emissions data, another held the supplier records, finance held the cost allocation, HR held workforce data, and legal held the policy language. The annual report looked polished, but the underlying operating model was fragmented. That is why BRSR has become so important. It is forcing companies to confront whether they have governance architecture or merely presentation skills.
The best Indian companies have already understood this. They are centralizing ESG data across locations, embedding internal controls, documenting evidence as events happen, and aligning sustainability metrics with finance and risk functions instead of leaving them in isolated sustainability spreadsheets. Some are going further, obtaining third-party assurance on environmental and social KPIs even where the rules are still evolving, because they know investor trust is built on reliability, not rhetoric. In sectors with high resource use or complex supply chains, this discipline is becoming part of operational excellence. The companies that treat ESG as a management system, rather than a publication exercise, are better positioned for institutional capital, export relationships, and resilient supply chains.
Yet most players are still not there. Many continue to rely on year-end scrambles, manual consolidation, and retrospective document gathering. Others have not yet solved the harder issue of value-chain visibility, which SEBI has now made part of the future of BRSR through disclosures covering significant upstream and downstream partners, with the latest framework allowing coverage of entities representing 75% of purchases and sales by value.
That matters because the board is no longer judged only by its own factory gates. It is increasingly judged by the conduct of suppliers, logistics partners, and customers. In governance terms, this is a profound shift. Stewardship now extends beyond the corporate perimeter.
Where India is ahead is in ambition and regulatory design. BRSR is more structured, more quantitative, and more board-relevant than many disclosure regimes in emerging markets. It has created a common national language for ESG, and that alone is a major achievement. India is also ahead in regulatory sequencing. Broad disclosure first, then tighter assurance, then value-chain transparency, then third-party verification architecture.
Where India still has room to improve is in consistency, sector-specific relevance, and the operational maturity needed to convert disclosures into decisions. Global peers in Europe and parts of the UK have moved further on double materiality, supply-chain due diligence, and integrated climate-risk governance, and Indian boards will increasingly need to learn from that maturity while preserving India’s pragmatic, cost-conscious approach.
This is where a quiet but important service industry is emerging in India. A growing ecosystem of consultants, assurance providers, ESG data specialists, and governance advisers are helping companies build meaningful BRSR systems, not just reports. The senior director sees the opportunity clearly. Just as India became a global services powerhouse in IT decades ago, it can build an exportable ESG reporting and assurance capability for the world. If Indian professionals can help thousands of organizations structure data, strengthen controls, and produce assurance-ready disclosures, India can turn a compliance burden into a global service advantage. That would be a genuine extension of India’s knowledge economy.
The true expectation from regulators is not perfection on day one. It is honesty, traceability, and continuous improvement. SEBI’s direction is unmistakable. Less greenwashing, more evidence. Less narrative padding, more measurable performance. Less annual panic, more built-in governance. Boards must respond by making ESG a standing governance item, assigning clear ownership, linking incentives to data quality, and asking whether the organization can defend every number it publishes.
The senior director’s final realization is simple but hard-earned. BRSR is not a sustainability report about the company. It is a report about the company’s system of truth.
And that is the deepest lesson of FY 2026 in India. The companies that will lead are not the ones that can write the best ESG story at year-end, but the ones that can live it every day through disciplined controls, transparent supply chains, and board-level stewardship. BRSR began as a disclosure framework, but its real purpose is far larger. It is teaching Indian business how to make responsibility measurable, auditable, and strategic. In that shift lies both the challenge of the present and the promise of India’s next great service-led export story.
