BRSR, GRI and ISSB: match reporting to its purpose

Divya Khatwani

Jun 10

3 min read

Updated: 4 days ago

Sustainability reporting works best when the audience, applicable requirements and supporting evidence are clear. For Indian businesses, a practical priority is understanding how different reporting approaches fit together without assuming that one report satisfies every obligation.

The following areas offer a useful starting point for planning a reporting cycle. Confirm current requirements for the relevant entity, jurisdiction and reporting period before preparing a formal statement of compliance.

Establish the Indian reporting baseline

SEBI requires the Business Responsibility and Sustainability Report (BRSR) from the top 1,000 listed entities by market capitalisation, subject to applicable rules. BRSR Core is a subset of indicators under nine ESG attributes. Its phased assessment-or-assurance requirement reaches the top 1,000 for FY2026–27. Confirm the entity's applicability and reporting period, and distinguish the Core requirement from the wider BRSR report. SEBI LODR master circular, chapter IV-B

Create a disclosure checklist that records the required indicator, source record, data owner, review step and reporting deadline. Keep voluntary disclosures and customer information requests clearly identified alongside regulatory requirements.

The BRSR evidence file guide provides a worked example of tracing an electricity figure through source records, a correction and approval.

Match standards to the reporting purpose

GRI Standards focus on an organisation's impacts on the economy, environment and people. Determine material topics and check the requirements for the intended GRI statement of use. “In accordance with” and “with reference to” have specific meanings. GRI 1 Foundation 2021

The ISSB's IFRS S1 and IFRS S2 address sustainability-related financial information for investors. The ISSB also maintains and enhances SASB Standards, which provide industry-based disclosure topics and metrics. These approaches have different purposes and should not be presented as interchangeable labels. IFRS Foundation on SASB Standards

For a group operating across markets, record where each requirement applies and whether it arises from law, a listing requirement, a contract or a voluntary choice. Do not assume IFRS S1 and IFRS S2 are mandatory for every Indian company.

Put TCFD in its current context

TCFD disbanded in October 2023, and its recommendations are incorporated into IFRS S1 and IFRS S2. The recommendations remain useful and may still be relevant to particular reporting requirements. IFRS S2 includes additional requirements, so existing TCFD-based disclosures need a gap review before a company claims full IFRS S2 compliance. IFRS Foundation on TCFD

Start by checking whether responsibilities, climate-related risks, relevant metrics and targets are supported by documented processes. Avoid adding technical disclosure language that the underlying analysis cannot support.

Connect reporting with business decisions

The Integrated Reporting Framework is jointly the responsibility of the IFRS Foundation's IASB and ISSB. It can help organise an explanation of how strategy, governance, performance and prospects relate to value creation over time. IFRS Foundation on integrated reporting

Practical connections might include explaining how resource constraints affect operations or how a capital project relates to a stated environmental target. Keep the explanation specific to the business and its evidence.

Strengthen controls before adding technology

Use software to organise records, flag missing fields and track reviews. Define units, reporting boundaries, approval responsibilities and version control first. Automation can reproduce an incorrect assumption quickly; human review remains important.

Keep social and governance information subject to the same discipline as environmental data. Explain definitions, coverage and limitations rather than relying on policy statements alone.

Prepare for review early

Maintain an evidence trail throughout the year and record unresolved gaps. Where an external assessment or assurance engagement is needed, confirm scope, expertise and independence requirements before appointment. Clear records make the report easier to examine and help the team distinguish supported progress from future plans.