ESG Advisory for Indian Companies: Policies, Data and Reporting
Listed companies now report on environment, social and governance (ESG) matters every year, and their bigger customers are starting to ask suppliers for the same data. We help you write the policies, set up data collection and draft the disclosures, including the SEBI BRSR. We do not issue assurance; that stays with an independent provider.
What it is
ESG stands for environment, social and governance. Put simply, it covers how your business handles energy, water and waste, how it treats employees, customers and the community, and how it is run. ESG advisory means getting these facts written down, measured and reported in a form that regulators, lenders and customers accept.
In India the main reporting rule is the Business Responsibility and Sustainability Report (BRSR), required under Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. SEBI introduced it by circular dated 10 May 2021, built on the nine principles of the National Guidelines on Responsible Business Conduct. Corporate social responsibility under Section 135 of the Companies Act, 2013 sits alongside it.
Who it applies to
Top 1000 listed companies
Since FY 2022-23, the top 1000 listed entities by market capitalisation must file a BRSR with the annual report. Other listed companies may file one voluntarily.
Suppliers and customers of large listed companies
Under BRSR Core, the top 250 listed entities may report ESG data for their value chain from FY 2025-26. Any partner forming 2% or more of their purchases or sales can expect data requests.
Companies with a CSR obligation
A company with net worth of ₹500 crore or more, turnover of ₹1,000 crore or more, or net profit of ₹5 crore or more in the preceding year must spend on CSR and report it in the Board’s report.
Why it matters
Regulators read it
The BRSR goes to the stock exchanges with the annual report. Weak or inconsistent numbers are visible to SEBI, investors and analysts.
Customers and lenders are asking
Large buyers need supplier data for their own value chain disclosures. Some banks and investors send ESG questionnaires before funding.
Measure it to cut it
Measuring energy, water and waste every month shows where the leaks are. You cannot cut what you have never counted.
What we do, and what we don’t
We do
- Gap check against the BRSR format and the nine principles
- Board-approved ESG policies drafted for your review
- Monthly data templates for energy, water, waste and people
- BRSR and CSR annual report drafting
- Answers to customer ESG questionnaires
We work with
- Your plant, HR and finance teams for the source data
- Environmental consultants for emission calculations where needed
- Your statutory auditor and company secretary
We don’t
- Issue assessment or assurance on BRSR Core
- Give ESG ratings
- Certify carbon credits or green credits
- Run lab tests or energy audits ourselves
Documents required
Company records
- Latest annual report and Board’s report
- List of plants, offices and warehouses
- Existing policies (code of conduct, POSH, whistle-blower, CSR)
Environment data
- Electricity bills and fuel purchase records
- Water bills or meter readings
- Waste disposal records and pollution board consents
People data
- Headcount by gender and category
- Wages, PF and ESI data from your payroll and labour records
- Safety incident and training records
How it works
Map where you stand
We read your annual report and current policies against the BRSR format and list what is missing: policies, data points and owners.
Draft the policies
We prepare policies for each of the nine principles in plain language. Your board reviews and approves them; they are your policies, not ours.
Set up the data flow
We give each plant and department a simple monthly template, with a named owner for every number. Take a forging unit that has never metered water separately: we start with the bills, and add a meter reading once it is installed. Without this step, year-end reporting turns into guesswork.
Draft the report
At year end we compile the data, calculate intensity ratios and draft the BRSR or the ESG section of your report for management review.
Hand over to the assurance provider
If you fall under BRSR Core, we organise the working papers so your independent assessment or assurance provider can test them quickly.
Timelines
BRSR
Filed as part of the annual report for each financial year. In practice, drafting should start soon after 31 March, when the year’s data closes.
Value chain
For the top 250 listed entities, value chain disclosures are voluntary from FY 2025-26, and their assessment or assurance is voluntary from FY 2026-27.
Unspent CSR
Unspent CSR money for an ongoing project goes to an Unspent CSR Account within 30 days of the year end. Other unspent amounts go to a Schedule VII fund within six months.
What happens if you get it wrong
CSR penalties
Under Section 135(7), failing to transfer unspent CSR money attracts a penalty of twice the amount or ₹1 crore, whichever is less. Each officer in default faces one-tenth of the amount or ₹2 lakh, whichever is less.
Listing compliance
A BRSR is part of the annual report under the LODR Regulations. A missing or careless report is a listing compliance failure, which SEBI and the exchanges can act on.
Lost business
Here is the catch: a supplier that cannot answer a large customer’s ESG questionnaire may lose the order to one that can.
Frequently asked questions
What does an ESG advisor actually do for a company?
An ESG advisor helps you write the policies, collect the data and draft the reports. In practice, that means checking your gaps against the BRSR format, drafting policies on the nine NGRBC principles, setting up monthly data templates and writing the BRSR or ESG report. The advisor does not certify the report. If you are under BRSR Core, an independent assessment or assurance provider does that.
Is ESG reporting mandatory in India?
Yes, for the top 1000 listed companies by market capitalisation. Under Regulation 34(2)(f) of the SEBI LODR Regulations, they must file a BRSR with the annual report, and this has been mandatory since FY 2022-23. Other listed companies may file one voluntarily. Unlisted companies have no general ESG reporting duty, but many still need the data because customers and lenders ask for it.
We are an unlisted MSME. Why are customers asking us for ESG data?
Because large listed companies may now report ESG data about their value chain. SEBI’s BRSR Core framework covers upstream and downstream partners that each make up 2% or more of the listed company’s purchases or sales. For the top 250 listed entities, this is voluntary from FY 2025-26. Picture a Faridabad auto-parts maker supplying a listed carmaker. The questionnaire asks for electricity used, waste sent out and the share of women employees. A basic data template answers most of it.
Does Taxhint provide BRSR assurance?
No. BRSR Core assessment or assurance must come from an independent provider, and SEBI asks the board to make sure that provider has the expertise and no conflict of interest. Our role is advisory: policies, data systems and drafting. Keeping the two apart protects the credibility of your report. We can prepare the working papers so the provider’s review goes faster.
What are the nine principles we need policies for?
They are the nine principles of the National Guidelines on Responsible Business Conduct. In short: ethics and transparency, sustainable products, employee wellbeing, stakeholder interests, human rights, the environment, responsible public policy advocacy, inclusive growth, and responsible customer engagement. Section B of the BRSR asks whether you have a board-approved policy for each. We draft them to fit how your business runs, not as copy-paste text.
How is ESG linked to CSR?
CSR is one part of the social side of ESG. Section 135 of the Companies Act, 2013 requires companies with net worth of ₹500 crore or more, turnover of ₹1,000 crore or more, or net profit of ₹5 crore or more to spend at least 2% of average net profits of the last three years on CSR. Your BRSR then reports CSR alongside other social data. If you route the money through an NGO, it needs CSR-1 registration.
What data do we need to start?
Start with twelve months of electricity, fuel and water bills, waste disposal records, and headcount data by gender and category. Add your existing policies and the latest annual report. Most of this already sits with your accounts, admin and HR teams. It just has not been pulled into one place.
How long does the first ESG report take?
The policies and gap check usually come first, and the data set-up takes a few months of monthly collection. For a company starting from scratch, it is sensible to begin early in the financial year so a full year of data is ready when the annual report is drafted. Once the templates run, later years take far less effort.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
There is no government fee for BRSR or ESG advisory. If you need BRSR Core assessment or assurance, that is a separate fee charged by the independent provider you appoint.
Ready to begin?
Tell us whether you are listed, a supplier to a listed company, or simply getting ready. We will tell you what to build first.