Assign BRSR data owners who can resolve the handover

Updated: Oct 6
Assign ownership to a defined metric and decision, rather than sending every ESG question to a department mailbox. Name who can settle the definition, who supplies each input, who prepares the schedule, who checks it and who approves its use in the report. Then test the handover with one real reporting task.
This guide is for finance, sustainability and compliance teams coordinating BRSR preparation. It assumes the reporting brief and applicability have already been established. The roles and working fields below are Nitium's suggested operating arrangement, not a prescribed SEBI organisation chart.
Separate metric ownership from reporting oversight
BRSR asks about the authority responsible for business-responsibility policies and sustainability decision-making. Those governance disclosures are distinct from an internal list of people compiling figures. Use the actual governance arrangements for the report. Source: SEBI master circular, Annexure 16, section B, questions 8–10.
For day-to-day collection, use five explicit responsibilities:
Metric owner: agrees the operational definition, commissions the necessary inputs and resolves or escalates questions.
Input owners: supply the source records and explain their coverage. A metric can need several input owners.
Preparer: assembles the inputs, documents calculations and flags exceptions.
Checker: tests the agreed coverage, sources, arithmetic and explanations before handover.
Reporting approver: authorises the disclosure for the reporting process within the company's governance arrangements.
One person may hold several roles in a small business. Record that fact and arrange an additional check for significant judgements or manual calculations where practicable. Calling someone a checker does not make the work independent assurance.
Write a handover agreement for each difficult metric
Start with metrics that cross departments or repeatedly return with questions. On one row, record:
The disclosure reference, metric definition, unit, population and period
The metric owner and each required input owner
The source schedule each input owner will supply
The preparer, checker and reporting approver
The dependency order and agreed dates
The minimum evidence needed to accept an input
The person who decides unresolved methodology or coverage issues
A backup contact and handover location
Be precise about the deliverable. “HR data by Friday” is difficult to review. “The agreed year-end employee population, with category definitions, source-extract reference, exclusions and the HR review recorded” tells the preparer what they can expect. Keep detailed personal records in the appropriate controlled system.
A fictional energy-intensity handover
Hypothetical example, not a Nitium client case. A reporting team needs an energy-intensity schedule. Facilities can explain electricity meters. Finance holds invoices and the financial denominator. EHS prepares the energy schedule. The reporting manager approves the disclosure.
The metric owner assigns the work as follows:
Facilities confirms the meter list, relevant consumption periods and non-electricity energy sources with the plant team.
Finance checks invoice coverage and supplies the approved denominator with its unit, period and boundary.
EHS prepares the energy schedule, records conversions and calculates the requested intensity using the applicable definition.
The checker traces selected inputs, checks the completeness reconciliation and verifies numerator and denominator coverage.
The reporting manager reviews the schedule, open questions and proposed disclosure before approval.
Facilities then identifies a shared meter serving an adjacent tenant. The preparer leaves the affected line queried. The metric owner asks facilities for the meter coverage and finance for the supporting arrangement, then obtains the appropriate treatment decision. Finance is not asked to guess a physical allocation from the bill value.
The handover is complete only when the decision, evidence and revised schedule reach the checker. A message saying “facilities confirmed” is insufficient unless it records what was confirmed and where the evidence can be found.
Use statuses that describe the next action
Distinguish requested, received, queried, checked and approved for reporting. A received spreadsheet may still have the wrong period. A checked calculation may still need a management decision. Record the reason when an item moves backwards after a correction.
When an input is late, first identify whether the obstacle is access, definition, missing records or a decision. Escalate that specific issue to the named person. Copying more people into an email does not settle who can resolve it.
Test the ownership map
Can the metric owner describe the exact reporting need?
Does each input owner know the required evidence and coverage?
Can the preparer identify which input is still blocking the calculation?
Can the checker return an issue to someone with authority to resolve it?
Are backups and absences covered?
Does the reporting approver receive limitations as well as the final number?
Use the BRSR evidence-file guide to connect these handovers to individual sources. Nitium's BRSR reporting support includes disclosure mapping, data requests and gap tracking. Discuss a reporting-data handover with the period and the metrics causing repeated delays, or email contact@nitium.in.
Sources checked 5 October 2026. This workflow does not decide legal applicability, replace management's responsibilities or provide independent assessment or assurance. Adjust the roles to the organisation and agreed reporting requirements.
For a working version of this handover process, use the departmental data request and ownership tracker.



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