Resolve missing ESG records without hiding estimates
Updated: Oct 7
Keep a missing record visible until it has been recovered, replaced with suitable evidence or addressed through an explicitly permitted and documented estimation method. Record the decision and its effect on the result. Never turn “we do not have the evidence” into a reported zero.
This guide is for reporting preparers and reviewers dealing with gaps in energy, water, waste or other ESG inputs. The decision sequence is a suggested workflow. Whether an estimate is acceptable depends on the indicator, reporting framework, purpose and available evidence.
Identify what is actually missing
A missing PDF is different from missing activity data. A lost invoice may be recoverable from a supplier portal; meter readings may still exist. Conversely, a full folder of invoices may contain no physical quantity or may cover the wrong site.
Describe the gap using five facts: the metric, entity/site, period, expected record and what remains available. Give it an owner and follow-up date. Keep these states distinct:
Record missing: expected evidence is absent or inaccessible.
Value unavailable: no supportable value has yet been established.
Estimated: a stated method has produced a provisional or approved estimate.
Reported zero: evidence supports no quantity for the defined metric and period.
Not applicable: the requirement does not apply, with a documented reason.
Work through the recovery options
Recover the original. Check the authorised source system, record owner, supplier copy or archive. Keep the retrieval reference.
Check alternative evidence. Compare coverage, timing, units and reliability. A calibrated meter record and a payment receipt answer different questions.
Check the applicable method. Establish whether it permits estimation for this indicator and situation, and what disclosure or approval is needed.
Evaluate a candidate estimate. Document inputs, assumptions, calculation, uncertainty and why the missing period is comparable to the reference data.
Decide the reporting treatment. The responsible reporting owner should resolve acceptance, further work or an explicit limitation before release.
For BRSR Core, SEBI requires disclosure of methodology changes and industry-specific adjustments or estimates. That disclosure requirement is not blanket permission to use any convenient estimate. Source: SEBI master circular, chapter IV-B, paragraph 2.2.
The BRSR Core Industry Standards Note, part B, attribute 1 gives specific conditions for spend-based electricity estimation where measurable data are absent, including restricted initial use and disclosure of the factor source and suitability. Check those conditions; do not replace an established quantity-based process with a spend proxy simply because collection is inconvenient.
A hypothetical gap where an average is the wrong answer
Fictional example, not a Nitium client case. Five days of generator fuel-consumption logs are missing. The runtime record shows 40 hours. Two reference periods suggest 12 litres per hour at one load and 20 litres per hour at another. Multiplication produces 480 litres or 800 litres, but the team cannot establish the load during the missing period.
Choosing the midpoint, 640 litres, would hide the unresolved operating assumption. The 480–800 figures are alternative scenarios, not a measured range or a statistical confidence interval. The reporting owner keeps the estimate unapproved and asks maintenance and stores for other evidence.
The team then recovers reliable records for the generator's dedicated day tank: opening stock 100 litres, deliveries 650 litres and closing stock 130 litres. For this example, it confirms there were no transfers, returns, losses or other uses. The reconstructed consumption is 100 + 650 − 130 = 620 litres.
The decision record identifies the recovered records and the stock-balance method. It explains why the unsupported runtime-rate estimate was rejected. If the rest of the period contains 10,000 litres of supported consumption and there is no overlap, the revised period total is 10,620 litres. The underlying stock measurements and assumptions still need the checks required by the applicable method; the arithmetic alone does not validate them.
Keep an estimation decision note
Gap identifier, metric, period and boundary
Recovery attempts and alternative records examined
Applicable method and why the proposed treatment is allowed
Input values, original units, source locators and formula
Assumptions, uncertainty and reasons the proxy could fail
Owner, reviewer, decision and approval date
Required disclosure and affected downstream calculations
Replacement plan and correction record when better evidence arrives
Do not give an estimate a confidence percentage unless there is a defensible method for it. A narrow-looking range can be just as misleading as an unsupported single number. Where no credible route is available, retain the gap and escalate its reporting consequence.
Use the Missing data and estimation decision log to record recovery attempts, proposed estimates, method review and the reporting decision. Its editable fields help preserve the basis and next action for each gap, including the distinction between recovered actual evidence and an approved estimate.
Before accepting the resolved item
Ask whether another reviewer can distinguish recorded data from the estimate, reproduce the calculation and understand why it was used. Check that the final disclosure reflects any material limitation, and that the gap has not been closed merely because a number now occupies the cell.
Our BRSR evidence-file guide shows how the decision connects to source records and approvals. Nitium's ESG data-trail and readiness support can help identify gaps and prepare the questions that need resolution. Discuss a reporting-data gap or email contact@nitium.in with a non-confidential outline.
Sources checked 5 October 2026. This guide does not approve a specific estimation method, establish compliance or provide an independent assessment or assurance conclusion. Specialist input may be needed for technical measurements and material judgements.
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