GENERAL OBSERVATIONS & GUIDELINES ON FILING OF BUSINESS RESPONSIBILITY AND SUSTAINABILITY REPORT (“BRSR”)

NSE vide its Circular Ref No. NSE/CML/2024/11 dated May 10, 2024, has issued General Observations, FAQs and Guidelines for the filing of Business Responsibility and Sustainability Report (“BRSR”)

BRSR: The BRSR framework is a mandatory disclosure mechanism for Top 1,000 listed companies based on market capitalization to report their performance on Environmental, Social and Governance (ESG) aspects and demonstrate their commitment to responsible business practices.

Key highlights of the NSE circular are as follows :

1. Top one thousand listed Companies based on market capitalization shall mandatorily submit BRSR in the format as specified by the SEBI. The list for the top 1000 listed entities as on March 31, 2024 is provided in the circular.
2. Listed Companies which were falling under top 1000 listed Companies based on market capitalization as on March 31, 2023, or March 31, 2022 and which no longer meet the market capitalization criteria for March 31, 2024, shall continue to comply the reporting requirements.
3. Companies not among the top one thousand listed companies, including those on the SME Exchange, may voluntarily submit BRSR.
4. If the listed Company is in the top one thousand market capitalization list on any Exchange, then the listed Company is required to file BRSR with both the Exchanges.
5. Top 150 listed entities based on market capitalization are required to mandatorily obtain reasonable assurance of BRSR Core. Also, a copy of Reasonable Assurance Certificate is mandatorily to be attached along with the BRSR while submitting BRSR PDF & Annual Report with the Exchanges.
6. BRSR PDF and XBRL shall be submitted on the same day of submission of Annual Report with the Exchanges.
7. Listed companies that prepare and disclose sustainability reports (as part of annual report) based on internationally accepted reporting frameworks such as GRI, SASB, TCFD, Integrated Reporting can provide cross reference of those disclosures in the BRSR. Thus, a Company need not disclose the same information twice in the annual report.  However, the Company should specifically mention the page number of the annual report or sustainability report where the information sought under the BRSR format is disclosed.

The NSE Circular also provides for principles and illustrations for inconsistencies observed in BRSR filings.

These guidelines issued by NSE are for guidance only. The directions / instructions issued in the provision of Law, Regulation, SEBI, and Exchange circular are referred to in these guidelines are final for decision making in the matter.

Please refer below the links for the respective circular issued by the NSE in this regard:
https://nsearchives.nseindia.com/web/sites/default/files/inline-files/NSE_Circular_10052024_1.pdf

DISCLAIMER: –  The summary information herein is based on NSE’s Circular on FAQs & General Observations/ Guidelines for filing of BRSR. While the information is believed to be accurate, we make no representations or warranties, express or implied, as to the accuracy or completeness of it. Readers should conduct and rely upon their own examination and analysis and are advised to seek their own professional advice. This note is not an offer, advice or solicitation. We accept no responsibility for any errors it may contain, whether caused by negligence or otherwise or for any loss, howsoever caused or sustained, by the person who relies upon it.

PDF version is attached:  FAQs & Guidelines for filing of business responsibility and sustainability report