Business Responsibility and Sustainability Reporting: Who Reports, What, and From When
The reporting obligation itself has been stable since 2022. What has not been stable is the verification layer sitting on top of it, the definition of the population it applies to, and the value chain requirement, all of which changed between May 2024 and March 2025. This guide sets out where each of those actually stands.
- The obligation, the format and the nine principles
- How the top one thousand population is determined since the 2024 change
- The nine core attributes subject to verification
- The glide path, year by year
What has to be reported
The report is mandated by regulation 34(2)(f) of the listing regulations, which requires the top one thousand listed entities by market capitalisation to include a business responsibility and sustainability report in the annual report. That wording was confirmed in the regulator's master circular of 30 January 2026, read at source. The report became mandatory from FY 2022-23, having been voluntary the year before.
It is structured in three sections. Section A carries general disclosures: entity details, products and services, operations, employees, corporate social responsibility details and complaints. Section B covers management and process disclosures, policy and process against the nine principles. Section C carries principle-wise performance disclosures, split between essential indicators, which are mandatory, and leadership indicators, which are voluntary.
The nine principles are those of the national guidelines on responsible business conduct, confirmed in the same master circular.
How the top one thousand is actually determined
This is where 2024-vintage content is wrong
Since the listing regulations were amended in May 2024, market-capitalisation based applicability has been determined using the average market capitalisation from 1 July to 31 December of the calendar year, rather than a 31 March snapshot. The stock exchanges prepare the ranking as at 31 December. Where a market-capitalisation based requirement applies to an entity for the first time, it applies after three months from 31 December or from the beginning of the immediately following financial year, whichever is later. For the report and its core, the entity must establish the necessary reporting systems and processes within that period and make the applicable disclosure in the annual report for that financial year. The amended basis took effect on 31 December 2024. The substituted regulation is 3(2), as put in place by the amendment regulations notified on 17 May 2024.
For an April to March financial year the operative systems deadline will ordinarily be 1 April. Within three months is not a filing deadline for the report itself, and is frequently misread as one.
There is also an exit: once a market-capitalisation based requirement becomes applicable it continues to apply until the entity has remained outside the relevant threshold for three consecutive years. Even then it ceases only at the time prescribed by regulation 3(2B), ordinarily at the end of the financial year following 31 December of the third consecutive year; for an entity whose financial year runs January to December, three months after that 31 December. Only the requirements whose applicability depends on market capitalisation cease. The rest of the listing obligations are unaffected.The same regulation 3(2) machinery is generic and drives the other market capitalisation tests in the listing regulations, including the independent woman director requirement and the risk management committee requirement, both also set at the top one thousand. So the reporting population and the risk committee population are determined the same way.
Core assessment or assurance uses that same ranking. There is no separate core list. The 2023 circular introduced the glide path by reference to the top listed entities by market capitalisation without creating a ranking method of its own, and the amended regulation 3(2) refers expressly to the report and its core. For FY 2026-27 the obligation applies to the top 1,000, fixed by the exchange ranking prepared as at 31 December 2025 on average market capitalisation from 1 July to 31 December 2025. For an April to March entity it applies from 1 April 2026 and the assessment or assurance accompanies the core disclosures in the FY 2026-27 annual report.
The three-year exit applies to the core obligation as well, because regulations 3(2A) and 3(2B) reach every provision whose applicability depends on market capitalisation and this is one. An entity already inside does not leave because its ranking fell below the threshold for a single year.
Nine attributes, and why they were chosen
The core is a subset of the report carved out for third-party verification, introduced by circular in July 2023. Its format was read at source during this build. The nine attributes are these.
| Attribute | What it measures |
|---|---|
| Greenhouse gas footprint | Scope 1, Scope 2 and intensity |
| Water footprint | Consumption, intensity, and discharge by destination and treatment level |
| Energy footprint | Total energy, share from renewable sources, and intensity |
| Embracing circularity, waste management | Plastic, electronic, bio-medical, construction and demolition, battery, radioactive and other hazardous and non-hazardous waste, with intensity, recovery and disposal |
| Enhancing employee wellbeing and safety | Spend as a share of revenue, lost time injury frequency rate, fatalities and permanent disabilities |
| Enabling gender diversity in business | Gross wages paid to females as a share of total, and complaints under the workplace harassment legislation |
| Enabling inclusive development | Input sourced from micro and small enterprises and small producers, and job creation in smaller towns |
| Fairness in engaging with customers and suppliers | Data breaches involving customer personal information, and days of accounts payable |
| Openness of business | Concentration of purchases and sales with trading houses, dealers and related parties, and related party transactions |
Source: the regulator's Annexure I format, read at source on 18 August 2026.
The choice is worth understanding, because it explains why the core is harder to report than the narrative sections. Every one of the nine is a quantitative attribute with a defined denominator. Intensity figures need a consistent revenue or production base. Days of accounts payable comes out of the ledger. Gross wages paid to females needs a payroll system that can produce it by gender. These are not sustainability team numbers; they come from finance, human resources and operations, and they have to reconcile to what those functions report elsewhere.
Year by year
| Financial year | Entities in scope for core verification | Value chain position |
|---|---|---|
| FY 2023-24 | Top 150 by market capitalisation | Not applicable |
| FY 2024-25 | Top 250 | The original comply-or-explain requirement for the top 250 was withdrawn. Industry standards on core reporting became mandatory from this year, and a green credits leadership indicator was introduced as a voluntary disclosure. |
| FY 2025-26 | Top 500 | Value chain disclosure voluntary for the top 250, on the redefined 2 per cent basis with a 75 per cent cumulative cap. Prior-year comparatives voluntary in the first reporting year. |
| FY 2026-27, the year in progress | Top 1,000. The first year the full reporting population is captured. | Value chain disclosure remains voluntary, and assessment or assurance of it is voluntary from this year. |
| FY 2027-28 onward | Top 1,000, subject to the three-year exit. The glide path is a phased expansion rather than something that expires: the top 1,000 is its final stage and continues until the regulator amends it, so no separate instrument for FY 2027-28 is needed. |
Nothing issued after the master circular of 30 January 2026 has deferred or relaxed the FY 2026-27 top-1,000 obligation. A relaxation notified in April 2026 concerns enforcement of minimum public shareholding and has nothing to do with this report or its core.
Industry standards on core reporting, formulated by an industry standards forum of the three major chambers under the aegis of the stock exchanges and in consultation with the regulator, were made mandatory for FY 2024-25 onward by circular of 20 December 2024. The March 2025 circular did not displace them: it defines an assessment by reference to standards developed by that same forum.
For scoping, the consequence is that applying the core format alone is not enough. The measures, definitions, calculations, documentation and the scope of the assessment or assurance all have to reflect the industry standards. Those reporting standards do not, however, replace the separate professional standard that governs how an assurance engagement is performed.
Where to go next
Environmental, Social, and Governance
Back to the main page: what we do, how an engagement is structured, and how to reach us.
Getting the Core Verified: Assurance, Assessment and the Independence Bar
The 2025 change from reasonable assurance to assurance or assessment, who may provide it, the conflict rules that decide which firm can do what, and the standards an engagement is conducted under.
Building an ESG Framework That Survives Contact With the Data
Why most sustainability programmes fail at the data layer rather than the policy layer, how to run a materiality assessment that is defensible, integrating sustainability into governance and risk, and what a first year should actually attempt.
Environmental Compliance: Producer Responsibility, Carbon Credits and Energy
The compliance obligations underneath the reporting: extended producer responsibility across plastic, electronic and battery waste, the carbon credit trading scheme, and the energy efficiency regime it sits alongside.
Reporting Beyond India: ISSB, CSRD, CBAM and What Buyers Are Asking
The international sustainability standards and India's position on them, the European reporting directive after it was cut back, the carbon border mechanism now in its definitive phase, and why the real pressure on Indian exporters comes through contracts rather than regulators.
Send an enquiry
If you are unsure whether you are in scope this year, send us your market capitalisation position across the second half of last calendar year. That is what the test now runs on.
Position as at 17 September 2026. Reviewed every six months.
This page is general information, not professional advice. Sustainability regulation is the fastest-moving area on this website and the one where published material ages worst. The securities regulator has softened its assurance requirement, made value chain reporting voluntary and redefined who counts as a value chain partner, all since 2024. The European Union has cut back the scope of its reporting directive and pushed out its dates. The climate disclosure task force was disbanded in 2023. Any advice in this area needs a date on it. Take professional advice before acting on anything on this page. We are happy to be that adviser, but we do not act on a web page, ours or anyone else's, without one.