Most BRSR filings submitted to SEBI contain avoidable errors - from inconsistent data across sections to missing emission calculations and undocumented policies. With SEBI tightening scrutiny and BRSR Core assurance expanding to the top 500 companies by FY 2026-27, companies that do not fix these mistakes now risk regulatory flags, investor skepticism, and failed audits.
The Business Responsibility and Sustainability Report (BRSR) is mandatory for the top 1,000 listed companies in India by market capitalization. It covers over 140 ESG indicators across three sections. Yet an estimated 83% of companies still rely on spreadsheets for ESG data collection - a setup that practically guarantees inconsistencies, version control issues, and last-minute scrambles.
This guide walks through the 10 most common BRSR reporting mistakes we see in filings, explains why each one matters, and gives you a concrete fix for every problem.
Why BRSR Data Quality Matters
BRSR is no longer a box-ticking exercise. Three forces are raising the stakes for data quality:
- SEBI scrutiny is increasing. SEBI has progressively tightened disclosure requirements since mandating BRSR in 2021. The regulator reviews filings for completeness, consistency, and comparability. Incomplete or contradictory data draws attention - and follow-up queries.
- Assurance requirements are expanding. BRSR Core assurance is already mandatory for the top 150 listed companies and will expand to the top 500 by FY 2026-27. Assurance providers will reject data that lacks documentation, audit trails, or internal consistency. Companies that have been filing low-quality reports face a steep correction when assurance kicks in.
- Investors use BRSR data. Institutional investors, ESG rating agencies, and proxy advisory firms increasingly rely on BRSR disclosures to assess ESG risk and compare companies. Poor-quality data undermines your ESG ratings, affects capital allocation decisions, and can even influence your cost of capital.
"Enhanced disclosures on ESG parameters and assurance thereof would bring in more transparency and enable better decision making by investors." - SEBI Consultation Paper on BRSR Core, 2023
The 10 Most Common BRSR Reporting Mistakes
1. Treating BRSR as a copy-paste from last year
Many companies duplicate the previous year's BRSR report with minimal updates - changing a few numbers and resubmitting. This leads to outdated policy descriptions, stale narratives that do not reflect actual operations, and sometimes even references to the wrong financial year.
How to fix it: Treat each BRSR filing as a fresh disclosure exercise. Assign section owners across departments who must review and update their respective indicators against current-year data, policies, and initiatives. Cross-reference every narrative against the current reporting period.
2. Inconsistent data across Section A, B, and C
The BRSR has three interconnected sections: Section A (general disclosures), Section B (management and process disclosures), and Section C (principle-wise performance). Companies frequently report different employee counts, revenue figures, or energy consumption numbers across these sections because different teams fill them out independently.
How to fix it: Create a single source of truth - a master data sheet with all base figures (headcount, revenue, energy, water, waste, emissions) that every section references. Run a reconciliation check before submission to catch discrepancies.
3. Missing or incorrect Scope 1 and Scope 2 emission calculations
Emission calculations are among the most error-prone indicators. Common problems include using wrong emission factors, confusing Scope 1 (direct) with Scope 2 (indirect from purchased electricity), omitting fugitive emissions, or applying outdated conversion factors. For a detailed breakdown, see our guide on Scope 1, 2, and 3 emissions.
How to fix it: Adopt a standardized calculation methodology (GHG Protocol or ISO 14064-1). Document which emission factors you use, their source, and the reporting boundary. Have your sustainability team or an external consultant validate the calculations before filing.
4. Ignoring leadership indicators in Section C
Section C of the BRSR includes both "essential" and "leadership" indicators for each of the 9 NGRBC principles. Many companies report only the essential indicators - either leaving leadership indicators blank or marking them as "not applicable" without justification. SEBI expects progressive adoption of leadership indicators, and investors specifically look at them to differentiate leaders from laggards.
How to fix it: Conduct a materiality assessment to identify which leadership indicators are relevant to your business. Even if you cannot report fully on all leadership indicators, provide qualitative disclosures and a roadmap for future reporting. Blank fields with no explanation are worse than partial disclosures with context.
5. No documented policies for all 9 NGRBC principles
Section B requires companies to confirm whether they have policies covering each of the 9 National Guidelines on Responsible Business Conduct (NGRBC) principles - from ethics and transparency to environment, stakeholder engagement, and human rights. Many companies report "Yes" to having policies but cannot produce the actual documents when questioned by assurance providers or investors.
How to fix it: Conduct a policy gap analysis against all 9 NGRBC principles. Draft and formally approve any missing policies. Ensure each policy is board-approved, dated, publicly available (or at minimum, internally accessible), and reviewed within the past two years.
6. Poor stakeholder engagement documentation
BRSR requires disclosure of stakeholder identification, engagement mechanisms, and how stakeholder concerns influenced business decisions. Many companies provide generic, templated responses - listing "customer surveys" or "annual general meetings" without describing actual outcomes, frequency, or how feedback was integrated into decision-making.
How to fix it: Maintain a stakeholder engagement register that logs each engagement activity, the stakeholder group involved, key concerns raised, and the company's response or action taken. This register becomes your evidence trail for BRSR and is essential for BRSR Core assurance.
7. Not preparing for BRSR Core assurance
BRSR Core is a subset of key quantitative KPIs from the full BRSR that requires reasonable assurance from a qualified auditor. Companies in the top 150 by market capitalization are already subject to this requirement, and it is expanding to the top 500 by FY 2026-27. Companies that have never undergone ESG assurance often discover - too late - that their data collection processes lack the rigor and documentation an auditor requires.
How to fix it: Conduct an internal readiness assessment against BRSR Core KPIs at least 6 months before filing. Identify gaps in data trails, calculation methodologies, and evidence documentation. Run a mock assurance engagement with an internal audit team or external consultant to surface issues early. Read our detailed guide on BRSR Core assurance.
8. Incomplete value chain data
BRSR asks about ESG practices and performance across the value chain - including suppliers and downstream partners. Most companies struggle with this because they have limited visibility into supplier-level emissions, labor practices, or environmental compliance. The result is either blank fields or vague qualitative statements that do not satisfy the disclosure requirements.
How to fix it: Start with your tier-1 suppliers. Develop a simple ESG questionnaire covering the key BRSR value chain indicators and distribute it as part of your annual supplier assessment process. Build value chain data collection into your procurement workflows rather than treating it as a standalone sustainability exercise.
9. Last-minute rush - starting too late
BRSR data collection requires inputs from finance, HR, operations, EHS, legal, and supply chain teams. When companies start the process only weeks before the filing deadline, they get incomplete data, no time for cross-checks, and a report full of errors. With 140+ indicators to populate, a rushed filing almost always contains mistakes.
How to fix it: Begin data collection at the start of Q3 of the financial year (October). Assign indicator-level ownership to specific team members with clear deadlines. Use a project management tool or ESG data platform to track completion status. Build in at least 4 weeks for internal review and reconciliation before submission.
10. Not aligning BRSR with other frameworks (GRI, CDP, CSRD)
Many companies report to multiple ESG frameworks - GRI, CDP, TCFD, and increasingly EU CSRD - but treat each as a separate exercise. This leads to duplicated effort, inconsistent numbers across reports, and missed opportunities to leverage data collected for one framework in another.
How to fix it: Map BRSR indicators to equivalent GRI Standards, CDP questions, and CSRD/ESRS datapoints. Build a unified data collection process that captures data once and maps it to multiple frameworks. Our ESG glossary can help you understand the terminology overlap. If you export to the EU, aligning BRSR with CSRD requirements is especially critical - read our guide on choosing an ESG consultant who can handle multi-framework reporting.
Section A: Verify company details, employee count, revenue, and operations data match your annual report exactly.
Section B: Confirm all 9 NGRBC principle policies exist, are board-approved, and are current. Document the policy review date.
Section C - Essential: Complete all essential indicators with quantitative data. Provide YoY comparisons. Use consistent units and reporting boundaries.
Section C - Leadership: Report on all material leadership indicators. Where not applicable, provide a clear justification.
Emissions: Use GHG Protocol methodology. Document emission factors and sources. Separate Scope 1 and Scope 2 clearly. See emissions guide.
Value chain: Include tier-1 supplier ESG data. Document your data collection methodology.
Assurance readiness: If subject to BRSR Core assurance, run a mock audit. Ensure all KPIs have documented evidence trails. See assurance guide.
Cross-check: Reconcile all figures across Sections A, B, and C before submission. A single inconsistency undermines the entire report.
For a detailed step-by-step checklist, see our BRSR Checklist.
Getting BRSR Right
The common thread across all 10 mistakes is the same: companies treat BRSR as a compliance burden rather than a structured data exercise. The fix is equally consistent - invest in process, documentation, and cross-functional coordination.
Start early. Assign ownership. Build a single source of truth. Prepare for assurance before it is mandated. And align your BRSR data with the other ESG frameworks your stakeholders care about.
The companies that get BRSR right are not the ones with the most resources - they are the ones with the most disciplined processes. For a comprehensive overview of the BRSR framework itself, read our guide on what BRSR reporting is and who needs to file. For professional support, explore our BRSR reporting services.
Frequently Asked Questions
The most common BRSR mistakes include treating the report as a copy-paste from the previous year, inconsistent data across Sections A, B, and C, missing or incorrect Scope 1 and 2 emission calculations, ignoring leadership indicators in Section C, and starting the filing process too late. These errors invite SEBI scrutiny and reduce investor confidence in your disclosures.
The BRSR framework covers over 140 ESG indicators across three sections - Section A (general disclosures), Section B (management and process disclosures covering all 9 NGRBC principles), and Section C (principle-wise performance disclosures with both essential and leadership indicators). BRSR Core, which requires assurance, covers a subset of key quantitative KPIs.
BRSR Core assurance is being phased in by SEBI. It is already mandatory for the top 150 listed companies by market capitalization and is expanding to the top 500 companies by FY 2026-27. Reasonable assurance from a qualified auditor on select BRSR Core KPIs will be required, so companies should start preparing well in advance.
Improve BRSR data quality by establishing a centralized ESG data management system instead of relying on spreadsheets, documenting data collection methodologies for each indicator, cross-checking figures across all three BRSR sections for consistency, starting data collection at least 6 months before the filing deadline, and conducting an internal dry-run audit before final submission.
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