Value Chain ESG Reporting for Indian Businesses
Updated: Oct 19
Value chain ESG reporting uses information from relevant suppliers, customers and other business partners to support a defined sustainability disclosure. Start by deciding what information is needed, from whom and for which reporting purpose.
For Indian businesses, the answer may involve SEBI reporting requirements, a customer's information request or a voluntary sustainability report. Define that purpose before sending data requests.
Check the reporting requirement
Under SEBI's revised BRSR Core framework, value-chain disclosures are voluntary for the top 250 listed entities by market capitalisation from FY2025–26; assessment or assurance of those disclosures is voluntary from FY2026–27. These provisions are separate from the entity's own BRSR Core requirement. Confirm entity-specific applicability and the reporting period. SEBI circular of 28 March 2025
For these BRSR value-chain disclosures, relevant upstream and downstream partners individually account for 2% or more of the listed entity's purchases or sales by value, respectively. Coverage may be limited to 75% of purchases and sales respectively. Document the coverage and assumptions. A greenhouse gas inventory has its own boundaries and methodology; these thresholds should not be transferred automatically. SEBI LODR master circular, chapter IV-B
Those provisions also address KPIs attributable to the entity's business with each partner and disclosure of actual purchase and sales coverage. A partner's whole-company total should not be substituted without the relevant methodological review.
Receiving a buyer questionnaire does not by itself establish that the supplier has the buyer's statutory filing obligation.
Write a brief before agreeing the work
Use the following six decisions to define the engagement. Record open questions rather than treating a broad request for “value-chain ESG support” as an agreed output.
Purpose and audience: name the disclosure, customer request or internal decision the work will support, and its requirement basis.
Population: identify entities, upstream/downstream partners, selection method, period and any sites or products requiring separate treatment.
Information: specify indicators, units, definitions, calculation methods and the evidence expected.
Work and deliverables: agree whether the scope includes request design, coordination, evidence review, calculations, a coverage summary or draft disclosure.
Responsibilities: identify who provides the partner list, contacts suppliers, resolves technical questions, approves sharing and signs off the output.
Limits and acceptance: state exclusions, review criteria, unresolved-gap treatment, dependencies and the handover date.
Distinguish a data-collection assignment from a complete Scope 3 inventory or a wider due diligence process. If independent assessment or assurance is needed, agree the provider's separate scope and applicable independence requirements. Advisory preparation should not be presented as the independent opinion.
Build a manageable data request
List the selected suppliers and customers, the required indicators and the reporting period. Ask only for information that serves the agreed purpose. Explain definitions, units, deadlines and the supporting records needed so partners can respond consistently.
Use a simple register containing:
Partner name, contact and reporting coverage
Indicator, unit and period covered
Data owner and reviewer
Supporting record or calculation
Missing information, estimates and follow-up actions
Start with a small sample to test whether the questions are understandable. Revise ambiguous requests before approaching the full reporting group. Agree how confidential business information will be handled and who may access it.
Keep evidence and limitations visible
Check unusual changes, inconsistent units and differences between reporting periods. Separate reported figures from estimates, and record the method behind each estimate. A missing response should remain an identified gap rather than silently becoming a zero.
For a practical way to connect reported figures with records, calculations and approvals, see our BRSR evidence file guide.
Where the objective is value-chain emissions accounting, use the relevant categories and methods in the GHG Protocol Corporate Value Chain Standard. A supplier questionnaire alone does not establish a complete Scope 3 inventory.
Before publication, explain coverage, exclusions and limitations. Assign a reviewer to check that narrative claims match the underlying records. Any reduction target needs a baseline, defined boundary, measurement method and timeframe.
Hypothetical manufacturing example
This example is hypothetical and does not describe a Nitium client or completed project.
A packaging manufacturer preparing a customer response maps twelve material suppliers and eight transport providers. It identifies the requested indicators and assigns internal data owners. The agreed first phase is a partner request, response register, evidence-gap review and customer-response draft for the specified period. It could request electricity records and relevant operating data, log incomplete responses and review calculation assumptions before sharing the results.
The scope does not describe those outputs as a completed product footprint, full Scope 3 inventory or independent assurance. Those would need their own methods, boundaries and engagement decisions. Material-supplier and transport questions are tailored to the information actually needed.
The team pilots one specified indicator with four of the twenty partners. Three provide evidence accepted for that indicator's agreed scope; one remains unresolved. That is 3 ÷ 4 = 75% accepted within the pilot and 3 ÷ 20 = 15% of the planned partner population. Neither measure is purchase-value coverage, emissions coverage or SEBI's 75% value-chain provision.
The handover states which four partners were tested, the indicator, review criteria, unresolved record and changes needed before wider collection. It does not call the full twenty-partner dataset 75% complete.
If the business later sets a reduction target, it would first establish the relevant baseline and decide how progress will be measured. This example makes no claim about achieved reductions, customer growth or supplier performance.
Request the approved scope, partner population and selection rationale, issued questions, returned-file index, reviewed calculations where included, coverage definitions, open-item list and exact draft version. Each unresolved item should identify its consequence, owner and next evidence needed.
Make the next cycle easier
After reporting, review the gaps with procurement, operations and finance. Give each improvement an owner and a deadline. A repeatable process with traceable evidence is a useful foundation for future reporting and any separately scoped assessment or assurance.
Need support with value-chain disclosures? For help defining partner coverage, organising supplier responses or reviewing evidence gaps, discuss your value-chain reporting requirements with Nitium. You can also explore our supplier and customer ESG support.
Sources and substantive additions checked 16 October 2026. This guide supports preparation and scoping; it does not establish entity-specific legal applicability, certification or independent assurance.
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