India

Yes.

Set out below are the key legislative and regulatory sources governing ESG disclosure requirements in India, along with details in relation to their applicability and scope.

1. The Indian securities market regulator - the Securities and Exchange Board of India (SEBI) - has, pursuant to an amendment to the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015, mandated the top 1,000 publicly listed companies (by market capitalisation) to make annual ESG disclosures under the Business Responsibility and Sustainability Report (BRSR) framework. The structure of the BRSR is segregated into essential (mandatory) and leadership (voluntary) indicators. Disclosures on the company’s value chain are voluntary.
   
   SEBI also introduced an additional subset of BRSR disclosures, namely the BRSR Core (as defined below), which covers the following nine key ESG reporting parameters: GHG footprint, water footprint, energy footprint, embracing circularity, enhancing employee wellbeing and safety, enabling gender diversity in business, enabling inclusive development, fairness in engaging with customers and suppliers, and openness of business (BRSR Core). As part of the BRSR Core framework, SEBI introduced a dedicated ‘value chain’ disclosure framework (Value Chain Framework), requiring the top 250 publicly listed companies (by market capitalisation) to make ESG disclosures for their value chain. Further detail on BRSR Core is set out in section A.3 below.
2. On 5 June 2025, SEBI issued the “Framework for Environment, Social and Governance (ESG) Debt Securities (other than green debt securities)” (ESG Debt Securities Framework), setting out disclosure and verification requirements for debt instruments labelled as ‘Social Bonds’, ‘Sustainability Bonds’, or ‘Sustainability-linked Bonds’. The ESG Debt Securities Framework supplements the SEBI (Issue and Listing of Non-Convertible Securities) Regulations 2021, which recognises ESG Debt Securities (a term that encompasses ‘Green Debt Securities’ as well as other ESG-labelled instruments) as a distinct class of debt instruments.
   
   While ‘Green Debt Securities’ are separately governed under Chapter IX and IX-A of SEBI’s Master Circular for issue and listing of Non-convertible Securities, Securitised Debt Instruments, Security Receipts, Municipal Debt Securities and Commercial Paper, dated 22 May 2024, the ESG Debt Securities Framework specifically governs the other ESG-labelled instruments, namely ‘Social Bonds’, ‘Sustainability Bonds’, and ‘Sustainability-linked Bonds’. Across all categories of ESG Debt Securities, SEBI has mandated certain disclosure requirements, which include: (i) disclosure of environmental and/or social objectives or rationale for issuing such bonds in the offer documents, (ii) ongoing performance disclosure, and (iii) verification of the utilisation of proceeds through an independent external review.
3. SEBI has mandated mutual funds to disclose their ESG policies and practices in their offer documents.
4. ESG disclosures are not currently mandated for private companies, public unlisted companies, limited liability partnerships, partnership firms, and other types of entities.

The disclosure requirements under the BRSR (save for the voluntary leadership indicators) are mandatory for the top 1,000 publicly listed companies (by market capitalisation).

SEBI introduced BRSR Core through its circular titled “BRSR Core – Framework for Assurance and ESG Disclosures for Value Chain”, dated 12 July 2023 (BRSR Core Circular), as a subset of the broader BRSR framework. BRSR Core focuses on nine key ESG performance indicators and, except for “value chain” disclosures, apply on a mandatory basis to the top 1,000 publicly listed companies (by market capitalisation).

A key element of the BRSR Core framework is the Value Chain Framework, which initially required the top 250 publicly listed companies (by market capitalisation) to report ESG data relating to their value chain on a comply-or-explain basis from financial year (FY) 2024–25. The term ‘value chain’ was defined to include the in-scope company’s top upstream and downstream partners, cumulatively accounting for 75% of its purchases or sales by value. A limited assurance requirement for value chain disclosures was to apply, also on a comply-or-explain basis, from FY 2025–26.

However, SEBI subsequently recalibrated the Value Chain Framework through its circular titled “Measures to facilitate ease of doing business with respect to framework for assurance or assessment, ESG disclosures for value chain, and introduction of voluntary disclosure on green credits”, dated 28 March 2025 (Revised BRSR Core Circular). While the Value Chain Framework continues to apply to the top 250 publicly listed companies (by market capitalisation), the timeline and nature of the disclosure obligation has been revised: value chain disclosures are now to be made on a voluntary basis from FY 2025–26, with the corresponding assessment or assurance obligation applying, also on a voluntary basis, from FY 2026–27. There is currently no indication as to when these requirements will be upgraded from a voluntary to comply-or-explain basis.

The Revised BRSR Core Circular has also narrowed the definition of ‘value chain’ to only include an in-scope company’s significant upstream and downstream partners — i.e., those that individually account for 2% or more of the company’s purchases or sales by value (Significant Value Chain Partners). In-scope companies may further limit disclosures to those Significant Value Chain Partners that, together, comprise up to 75% of their total purchases or sales.

Separately, issuers of ESG Debt Securities in India are mandatorily required to appoint an independent third-party reviewer or certifier. For ‘Green Debt Securities’, ‘Social Bonds’, and ‘Sustainability Bonds’, the reviewer will evaluate the project selection process and verify the use of proceeds. For ‘Sustainability-linked Bonds’, the reviewer will assess the selected key performance indicators, sustainability performance targets, any related structural features, and the issuer’s performance against such parameters.

The BRSR-mandated disclosures focus on all ESG tenets, including energy and water consumption, GHG emissions, waste management, extended producer responsibility, environmental impact assessments undertaken by the reporting companies, and general disclosures relating to the environmental impact of the in-scope companies’ operations. 

The nine key ESG reporting parameters under BRSR Core have been mentioned above.

Although India has not presently adopted international standards such as the ISSB Standards, the BRSR and BRSR Core have evolved in accordance with global best practices, and several disclosure requirements have been mapped against global reporting frameworks, such as the GRI, UN Sustainable Development Goals, TCFD, Carbon Disclosure Project (CDP) and SASB.

The BRSR and BRSR Core frameworks by SEBI adopt a double materiality approach, requiring disclosures on both the financial impact of ESG issues on the in-scope company and such company's impact on the environment and society. The BRSR and BRSR Core frameworks mandate detailed reporting on ESG risks, opportunities, and their financial implications, as well as the company’s broader environmental and social impacts, such as GHG emissions, resource usage, labour practices, and community engagement.

BRSR mandates in-scope companies to disclose Scope 1 and Scope 2 GHG emissions, with Scope 3 reporting required only on a voluntary (leadership indicator) basis.

Separately, the top 250 publicly listed companies (by market capitalisation) that voluntarily report under the Value Chain Framework must disclose the Scope 1 and Scope 2 emissions of their Significant Value Chain Partners, to the extent attributable to their commercial relationship with the reporting company – thereby triggering a limited Scope 3 reporting obligation on the reporting company under the BRSR Core.

The BRSR Core framework stipulates that GHG emissions may be measured in accordance with the GHG Protocol (though this is not a strict requirement). Additionally, in December 2024, SEBI adopted the ‘Industry Standards on Reporting of BRSR Core’ (Industry Standards) to provide further guidance on the methodology and disclosure of GHG emissions, with the aim of ensuring consistency and clarity in BRSR Core reporting.

Yes. SEBI has introduced a mandatory requirement for publicly listed companies to undertake either an assessment or assurance of their BRSR Core disclosures, which is being implemented through a phased glide path. The requirement presently applies to the top 500 publicly listed companies (by market capitalisation) for FY 2025-26, and will be extended to cover the top 1,000 publicly listed companies (by market capitalisation) from FY 2026-27 onwards.

For the top 250 publicly listed companies (by market capitalisation) that choose to make disclosures pursuant to the Value Chain Framework, they may choose to obtain an assessment or assurance for such disclosures on a voluntary basis.

Notably, the Revised BRSR Core Circular substitutes the earlier requirement of obtaining an ‘assurance’ for BRSR Core disclosures and ‘Value Chain’ disclosures with the more flexible requirement of obtaining either an ‘assurance’ or an ‘assessment’. ‘Assessment’ refers to a profession-agnostic evaluation process that may be conducted by a broader range of third-party service providers. Unlike ‘assurance’, ‘assessment’ does not typically imply reliance on formal professional credentials, such as those held by auditors or chartered accountants – thus allowing in-scope companies to engage not only traditional assurance providers but also other qualified assessors, provided that the evaluation is conducted in accordance with the methodologies prescribed under the Industry Standards.

Yes. In our experience, we see companies aligning their disclosures under international reporting frameworks and making voluntary ESG disclosures.

Several publicly listed companies that are not mandatorily required to make ESG disclosures are opting to voluntarily make such disclosures. Similarly, many unlisted companies and multinational companies also make such disclosures on a voluntary basis given investor sentiment and stakeholder expectations. Companies are making voluntary ESG disclosures as customary practice owing to increasing requirements from investors, lenders etc. Such requirements are now also being hardwired in contractual arrangements for better optics from stakeholders’ perspective.

The (Indian) Department of Economic Affairs has, on 7 May 2025, released a ‘Draft Framework of India’s Climate Finance Taxonomy’ (Draft Taxonomy), which aims to identify and standardise climate-aligned economic activities and guide sustainable investments and finance in India. However, the Draft Taxonomy has not yet been adopted, and as such, India does not presently have a comprehensive local taxonomy on sustainable activities akin to the EU taxonomy, and it is currently unclear whether the Draft Taxonomy will have mandatory application once adopted.

In parallel, India continues to broaden its sustainable finance ecosystem through initiatives such as the BRSR, BRSR Core, the Carbon Credit Trading Scheme 2023 (CCTS) and Green Credit Programme, etc.

The Indian regulatory framework for ESG Debt Securities expressly links disclosure and eligibility requirements to a set of internationally recognised principles and taxonomies. Under the ESG Debt Securities Framework, issuers are permitted to label their instruments as ‘Social Bonds’, ‘Sustainability Bonds’, or ‘Sustainability-linked Bonds’ if the use of proceeds aligns with the following standards: the International Capital Market Association Principles, Climate Bonds Standard, ASEAN Standards, or European Union frameworks. Additionally, issuers are required to disclose the global or domestic taxonomies and methodologies referenced in structuring their bonds. Specifically, issuers of ‘Green Debt Securities’ are required to align their disclosure regime with the updated ‘Green Bond Principles’ recognised by IOSCO.

SEBI has clarified that while undertaking BRSR disclosures, companies already preparing and disclosing sustainability reports based on internationally accepted reporting frameworks (e.g. GRI, Integrated Reporting Framework and TCFD) may refer to disclosures made under these frameworks. For instance, many companies in India follow the CDP disclosure system on a voluntary basis, and CDP questionnaires are, to some extent, aligned with the environment-based questions in the BRSR.

In our experience, we see companies aligning their disclosures with international reporting frameworks (including CDP and TCFD) and therefore, they report on climate change-related aspects under BRSR / BRSR Core accordingly.

The draft guidelines on “Disclosure framework on Climate-related Financial Risks 2024” (Draft Climate Disclosure Framework) issued by the Reserve Bank of India (RBI), the apex bank of India, indicates the development of a climate disclosure framework, divided into four thematic areas: governance, strategy, risk management, and metrics and targets, which is in line with IFRS S2, though not as granular or comprehensive. See section A.12 below for more detail.

India’s ESG regulatory framework has, in the past year, signalled a deliberate shift toward purposeful and grounded implementation that balances ambition with practical feasibility. Recent revisions to the BRSR Core framework signal SEBI’s intent to preserve disclosure integrity while easing early compliance burdens, especially for complex ‘Value Chain’ data and assurance-related costs.

Similarly, the release of the Draft Taxonomy, which was open for consultation until 25 June 2025, marks a meaningful step towards defining green investments in a manner consistent with Indian national development priorities and reinforcing the broader intent of building a robust and locally grounded ESG system.

Regulators may adopt a truncated form of the BRSR called BRSR Lite, which may be used by unlisted companies or large public companies on a voluntary basis to begin reporting on sustainability-related issues. We also expect to see an increase in voluntary disclosures as investor interest in their portfolio companies increases. Further, we expect more alignment with global climate-related disclosures in the future, including that of ISSB.

Based on the RBI’s Draft Climate Disclosure Framework, entities within scope of the framework will be required to disclose information about their climate-related financial risks and opportunities for the users of financial statements. It is proposed that the framework will apply to the following entities:

1. scheduled commercial banks (excluding local area banks, payments banks and regional rural banks);
2. tier-IV primary (urban) co-operative banks;
3. all-India financial institutions (i.e. EXIM Bank, NABARD, NaBFID, NHB and SIDBI); and
4. top and upper layer non-banking financial companies.

We understand that the RBI is in the process of finalising the framework.

Although India issued a Zero Draft National Action Plan on Business and Human Rights in 2018, there have been no official developments on the plan since then and no current proposals to introduce any mandatory human rights and/or environmental due diligence obligations on businesses.