India’s Business Responsibility and Sustainability Reporting (BRSR) framework is at a critical crossroads. According to a new Observer Research Foundation (ORF) brief, while the framework has advanced corporate transparency, it currently suffers from limited international comparability. To unlock global capital and reduce the duplicative reporting burden on Indian multinationals, the authors advocate for a strategic shift toward global interoperability.
The challenge of dual reporting:
Currently, many globally integrated Indian companies are forced to file parallel disclosures—meeting BRSR requirements for domestic regulators while simultaneously adhering to international frameworks for foreign investors. This compliance complexity increases costs and creates data inconsistencies. The ORF brief notes that global investors are increasingly seeking standards like the International Sustainability Standards Board (ISSB) to address data gaps across jurisdictions, especially as sustainable investing is forecast to drive over $40 trillion in global growth by 2070.
Adopting a global baseline:
The research suggests that the BRSR should evolve from a static compliance exercise into a strategic coherence framework. A primary recommendation is for SEBI to adopt ISSB (IFRS S1 and S2) as the baseline for financial materiality and the Global Reporting Initiative (GRI) for impact materiality. By embedding these as the foundation, supplemented by India-specific overlays, the BRSR can achieve deemed compliance status, where international standards are recognized as fulfilling domestic mandates.
“The challenge and opportunity lie in strengthening interoperability while reflecting India’s context and ensuring disclosures remain both feasible for companies and decision-useful for investors,” write authors Lavanya Mani and Ajay Tyagi. “Together, these reforms would enhance BRSR’s credibility, interoperability, and effectiveness in advancing sustainability and investment outcomes.”
Expanding the regulatory horizon:
The brief further recommends expanding mandatory BRSR coverage beyond the top 1,000 listed firms to include large unlisted companies, using a revenue- or emissions-based lens rather than just market capitalization. By aligning reporting boundaries between financial and sustainability statements—adopting a consolidated group-level approach—India can provide the transparency required to attract the diversified, cheaper capital necessary for its net-zero 2070 goals.
Recommendations:
To position the BRSR as a global benchmark, the authors outline several structural reforms:
- Sector-Specific Standards: Moving away from a “sector-agnostic” approach to create templates for high-impact industries like steel and cement.
- Unified ESG Data Architecture: Linking BRSR data with the RBI, MCA, and domestic carbon market systems to ensure a single version of truth for emissions and risk.
- Proportionality for MSMEs: Implementing a nudge and support model for smaller firms, utilizing easy-to-use digital templates linked to government incentives like the Z (zero defect, zero effect) scheme.
- Governance Mandates: Requiring board-level oversight and signatures on sustainability reports, mirroring the accountability of audited financial statements.
