CORAA
Resources · BRSR Core · FY 2026-27 mandatory

BRSR Core Assurance Playbook.

A practitioner playbook for the SEBI BRSR Core 9-KPI reasonable assurance engagement. From 1 April 2026 (FY 2026-27), reasonable assurance on BRSR Core is mandatory for the top 1000 listed entities by market capitalisation — bringing roughly 750 new engagements into the market versus the FY 2025-26 top-500 perimeter.

Phased applicability — who and when

SEBI introduced BRSR Core via circular dated 12 July 2023. Applicability is phased by market capitalisation as on 31 March of the financial year immediately preceding the reporting year.

Effective fromTop X listed (by market cap)Status
FY 2023-24Top 150Completed
FY 2024-25Top 250Completed
FY 2025-26Top 500Current cycle
FY 2026-27Top 1000Starts 1 April 2026 — ~750 new engagements

The standards stack

ICAI
SAE 3000
Assurance Engagements Other than Audits or Reviews of Historical Financial Information. The overarching framework for non-historical-FS assurance — applies to BRSR Core, sustainability reports, and similar attestations.
ICAI
SAE 3410
Assurance Engagements on Greenhouse Gas Statements. Specific guidance for the GHG / Scope 1+2 KPI in BRSR Core — quantification, measurement, and verification of emissions data.
IAASB (2024)
ISSA 5000
International Standard on Sustainability Assurance — General requirements for assurance on sustainability information. IAASB issued the final standard in late 2024; ICAI is in the convergence phase.
SEBI
SEBI LODR Reg 34(2)(f)
The disclosure obligation: the BRSR forms part of the Annual Report and includes the BRSR Core with the assurance provider's report. Disclosure of assurer name, fees, and methodology.

The 9 BRSR Core KPIs — evidence matrix

Each KPI below shows the metric, numerator and denominator definition, evidence to gather, and common pitfalls. Use this as a starting checklist; finalise the work programme against the BRSR Core data points in the specific entity’s reporting framework.

1. Greenhouse Gas (GHG) emissions intensity
Environment
tCO₂e / ₹ crore of turnover (or per unit of physical output)
Numerator
Sum of Scope 1 (direct emissions from fuel combustion, fugitive) + Scope 2 (purchased electricity / steam / heat) GHG emissions, expressed in tCO₂e using GHG Protocol or ISO 14064-1
Denominator
Annual turnover (₹ crore) — adjusted for activity if applicable
Evidence to gather
  • Fuel consumption ledger reconciled with purchase invoices (Scope 1)
  • Electricity bills reconciled with sub-meter readings (Scope 2)
  • Emission factors source — CEA grid factor for India electricity, IPCC AR6 for fuels
  • Reconciliation of physical output / financial turnover with audited financial statements
  • Quality control records of measurement instruments (calibration certificates)
Common pitfall
Using outdated CEA grid emission factor; including Scope 3 in the intensity (BRSR Core requires Scope 1+2 only); inconsistent treatment of solar / wind PPAs across reporting periods.
2. Water consumption intensity
Environment
KL withdrawn / ₹ crore of turnover
Numerator
Total water withdrawn from all sources (surface, ground, third-party supply, sea, rainwater harvested) in KL
Denominator
Annual turnover (₹ crore)
Evidence to gather
  • Municipal water bills + sub-meter readings
  • Borewell metering / tanker delivery records
  • STP / ETP output records (for recycled water)
  • CGWA / state pollution control board permissions
Common pitfall
Mixing "withdrawal" with "consumption" (different metrics); not segregating recycled water from total withdrawal; ignoring fugitive losses; treating tanker water as zero-cost (still must be metered).
3. Waste recycled or recovered (% of waste generated)
Environment
% — (waste recycled + recovered) / total waste generated
Numerator
Sum of waste recycled (sent to authorised recyclers) + recovered (energy recovery, co-processing)
Denominator
Total waste generated — hazardous + non-hazardous + plastic
Evidence to gather
  • Hazardous waste manifests (Form 10) under HWMR 2016
  • Authorised recycler invoices + Form 13 returns
  • EPR (Extended Producer Responsibility) certificates for plastic packaging
  • Co-processing certificates from authorised cement plants
Common pitfall
Counting waste sent for "disposal" as "recovery"; double-counting EPR credits; missing the plastic-waste 4-bucket disclosure under PWMR.
4. Renewable energy (% of total energy)
Environment
% — renewable energy / total energy consumption
Numerator
Renewable energy from rooftop solar + open-access RE PPA + REC purchases (subject to consumption-side verification)
Denominator
Total energy consumption (GJ) — across electricity, fuels, steam, heat
Evidence to gather
  • PPA contracts + open-access permissions
  • REC purchase certificates from CERC-empanelled registry
  • Rooftop solar generation meter readings
  • Energy conversion factors (GJ) per source
Common pitfall
Treating REC purchases without contracted-quantity disclosure as renewable; not adjusting for PPA delivery shortfalls; mixing electricity-side renewable with fuel-side (fuels are Scope 1, electricity is Scope 2 — separate disclosures).
5. Energy intensity (incl. Scope 1 + 2 sources)
Environment
GJ / ₹ crore of turnover
Numerator
Total energy consumption across fuels, electricity, heat in GJ
Denominator
Annual turnover (₹ crore)
Evidence to gather
  • Fuel and electricity purchase ledger + sub-meter readings
  • GJ conversion factors per source (per Bureau of Energy Efficiency)
  • Reconciliation with audited turnover
Common pitfall
Inconsistent denominator (sometimes net sales, sometimes gross revenue); excluding captive consumption; not normalising for activity changes year-over-year.
6. Air, water and land pollutant discharge (within statutory limits)
Environment
% of CPCB / SPCB consent limits
Numerator
Measured discharge concentrations
Denominator
CPCB / SPCB consent-to-operate limits per parameter
Evidence to gather
  • Online Continuous Emission Monitoring System (OCEMS) data — uploaded to CPCB / SPCB portal
  • ETP / STP outlet sampling reports by NABL-accredited laboratory
  • Stack monitoring records, ambient air-quality reports
Common pitfall
Not reconciling OCEMS uploaded data with sampling lab reports; missing exceedance notifications; conflating intermittent vs continuous discharge; treating zero-liquid-discharge claims without verification.
7. Gender diversity — % female employees + workers
Social
% — by category (KMP, BOD, senior management, middle, junior, workers)
Numerator
Female headcount by category
Denominator
Total headcount by category
Evidence to gather
  • HR master + payroll system reconciliation
  • Board composition disclosure under SEBI LODR Reg 17(1)
  • PF / ESI registrations for workers
  • Manpower agency contracts for contract workers
Common pitfall
Counting only permanent employees (BRSR requires permanent + non-permanent); inconsistent treatment of contract workers; missing Differently-Abled disclosure (separate BRSR principle).
8. Wages — gender pay parity by category
Social
Median female remuneration / Median male remuneration (%) by category
Numerator
Median female remuneration in each category
Denominator
Median male remuneration in same category
Evidence to gather
  • Payroll system data (Form 16 / 16A summary)
  • Reconciliation with audited employee-benefits expense per Schedule III
  • Minimum wages notification by state government for compliance check
Common pitfall
Using mean instead of median (BRSR Core specifies median); excluding variable pay / bonuses; not separating across categories (KMP / senior / middle / junior / workers).
9. CSR + employee wellness spend (₹ + % of net profit / payroll)
Social
CSR ₹ / net profit (Sec 198) AND wellness ₹ / total payroll
Numerator
Section 135 CSR spend + employee wellness (insurance, health checks, training, women safety, etc.) ₹
Denominator
Average net profit (Section 198) for CSR; total payroll for wellness
Evidence to gather
  • CSR-2 disclosure + ongoing-project transfer to special account
  • Schedule VII activity-wise spend reconciliation
  • Employee benefits ledger — insurance premiums, training cost, health-check vendor invoices
  • Section 135 calculation per Section 198 net profit
Common pitfall
Conflating mandatory CSR (Section 135) with voluntary social contribution; counting CSR admin overheads (capped at 5% of CSR spend) into program spend; missing the wellness-spend ratio.
How CORAA helps

BRSR Core data ingestion + working-paper pack

For CA firms taking on BRSR Core engagements in FY 2026-27, CORAA’s Reconciliation and Working Papers modules accept the same evidence pack auditors collect (meter readings, vendor invoices, payroll exports, lab reports) and generate the calculation working papers per KPI — denominator reconciliation against the audited financial statements, year-over-year variance flagging, and the assurance-report-ready evidence index per SAE 3000 / SAE 3410.

See Reconciliation module →Working Papers →Trust Centre

Engagement-acceptance checklist

  1. Independence test. Confirm the firm is not the statutory auditor (Section 144 / ICAI Code of Ethics). Test relationships with the client’s parent / subsidiary / associates.
  2. Competence test. Does the team have GHG quantification expertise (SAE 3410)? If not, plan to engage an auditor’s expert under SA 620 — typically an ISO 14064 verifier.
  3. Scope letter. Issue an engagement letter under SAE 3000 (read alongside SA 210 principles) covering the 9 KPIs, reasonable-assurance form, deliverable (assurance report), management responsibilities, period covered.
  4. Materiality. Set quantitative materiality per KPI (e.g., ±5% on GHG, ±10% on waste) plus qualitative considerations. Document in the planning memorandum.
  5. Risk assessment. Identify ROMM at the KPI level — measurement uncertainty for emissions, completeness risk for waste / scope boundaries, classification risk for the renewable energy KPI.
  6. Site visit plan. For multi-location entities, design site selection: typically risk-based + statistical sampling. Document the basis (similar to SA 530 sampling).
  7. Evidence gathering. Per the KPI matrix above — source data, calculation methodology, conversion factors, period coverage, completeness.
  8. Management representation letter. Specific to BRSR Core — coverage of all reporting units, no excluded source, consistency of methodology, completeness of disclosure.
  9. Reasonable-assurance conclusion. Positive-form conclusion in the assurance report — “In our opinion, the BRSR Core data of <entity> for the year ended 31 March is fairly presented in all material respects in accordance with the SEBI BRSR Core framework.” Sign with UDIN.
  10. Working paper archive. Per SA 230 — assemble final audit file within 60 days of report date. Retain 7 years.

Frequently asked questions

What is BRSR Core?+
BRSR Core is a subset of the SEBI Business Responsibility and Sustainability Report (BRSR) covering 9 KPIs across Environment, Social and Governance pillars that require REASONABLE ASSURANCE by an independent assurance provider. The full BRSR has ~1,000+ data points; BRSR Core is the assured subset. SEBI introduced BRSR Core via circular dated 12 July 2023.
Who needs BRSR Core assurance and from when?+
Phased rollout based on market capitalisation: top 150 listed entities — FY 2023-24; top 250 — FY 2024-25; top 500 — FY 2025-26; top 1000 — FY 2026-27 (1 April 2026 onwards). The "top X by market cap" is determined as on 31 March of the FY immediately preceding.
Reasonable vs Limited assurance — what's the difference?+
Limited assurance (~negative form) reduces engagement risk to a level acceptable in the circumstances; the conclusion is in negative form ("nothing has come to our attention…"). Reasonable assurance (~positive form) reduces engagement risk to acceptably low level; the conclusion is positive ("we report that the BRSR Core data is fairly presented in all material respects"). BRSR Core requires REASONABLE ASSURANCE — the higher-rigour engagement.
Which standards govern BRSR Core assurance engagements?+
ICAI: SAE 3000 (Assurance Engagements Other than Audits or Reviews of Historical Financial Information) — overarching framework. SAE 3410 (Assurance Engagements on Greenhouse Gas Statements) — for GHG / Scope 1+2 attestation. ISSA 5000 (recently issued, broader sustainability assurance) is the international convergence point and ICAI guidance will reflect it. Read alongside Standards on Auditing where audit-quality concepts apply.
Who can provide BRSR Core assurance?+
SEBI LODR Reg 34(2)(f) read with the BRSR Core framework permits "independent assurance providers" — practising Chartered Accountants under ICAI, Cost Accountants under ICAI-Cost, Company Secretaries under ICSI (subject to limitations), and certain notified specialised firms. The assurer must not be the statutory auditor of the entity (independence concern).
Are non-ICAI providers (e.g., BIS, BSI) acceptable?+
For technical / GHG-specific assurance, accredited certification bodies (ISO 14064 verifiers) may be engaged, but the BRSR Core report itself must be signed by a SEBI-recognised assurance provider. Most listed entities engage a CA firm that subcontracts GHG verification to a specialist firm under SA 620 / SAE 3000-equivalent reliance.
What is the typical assurance fee?+
Fees vary significantly by entity complexity, manufacturing footprint, scope and the assurance provider tier. For mid-cap manufacturers, BRSR Core reasonable assurance engagements typically range from ₹10 lakh to ₹50 lakh per year. The fee is disclosed in the assurance report and in the BRSR Core disclosure.
What evidence does the assurance provider gather?+
For each of the 9 KPIs, the provider tests source data (meter readings, lab reports, payroll), the calculation methodology, period coverage, completeness (no source excluded), conversion factors used, and the entity's internal controls. For high-risk KPIs (GHG, water, waste), physical site visits and sampling of sub-meters is typical.
Can the statutory auditor provide BRSR Core assurance?+
No — Section 144 of the Companies Act 2013 and ICAI Code of Ethics prohibit the statutory auditor from rendering "any other services to the same client". BRSR Core assurance counts as an "other service" in the broader interpretation. Practical solution: engage a separate firm or a separate engagement team within a network firm subject to firm-level independence controls.
Is the BRSR Core report signed under UDIN?+
Yes — for CA assurers, the BRSR Core assurance report is signed with a UDIN under the ICAI UDIN Guidelines. The UDIN is included in the report and verifiable on the ICAI portal.

Run BRSR Core engagements on CORAA.

The same Data Room, Reconciliation, Vouching and Working Papers modules used for statutory + tax audit handle BRSR Core evidence — meter readings, vendor invoices, payroll exports, lab reports.

Talk to CORAAPricingWorking Papers module