Thinking · Disclosure

Assessment or assurance: what SEBI actually changed in BRSR Core.

Abhijith Magal · 2 September 2026 · 9 min read

This page is India-specific. It reads two circulars from the Securities and Exchange Board of India, SEBI, which regulates what listed Indian companies disclose.

A lot of what is still written about BRSR Core describes the rule as it stood in July 2023. Pages still live today say the top 1,000 need reasonable assurance and that value chain disclosure covers the partners making up 75 per cent of purchases and sales, on a comply-or-explain basis. Both statements were superseded on 28 March 2025. The circular that did it is four pages long. Here is what it changed, line by line, and then the more useful question: what a company now has to hold itself, because the external check moved.

What did SEBI change in March 2025?

The headline change is the check itself. The circular let listed entities choose between a third-party assessment and an assurance engagement for BRSR Core, where the 2023 circular had required reasonable assurance. It deferred value chain disclosure by a year, made it voluntary and redefined who counts as a value chain partner. It added a Principle 6 leadership indicator on green credits. The circular, SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, applied from the date of issue unless a provision said otherwise.

Both circulars have since been folded into SEBI's master circular for LODR compliance dated 30 January 2026, which consolidates circulars issued up to 30 December 2025 and supersedes the November 2024 version. The amendment to the LODR Regulations notified in January 2026 dealt with high value debt listed entities and investor services. A team checking its obligations should read the 2026 master circular, and the two circulars below explain how the text got there.

Is assessment a softer check than assurance?

SEBI did not say so. The circular states its reasons plainly: to decrease cost and effort for listed entities and their value chain partners, and to make verification profession agnostic. That last phrase matters. The word assurance ties the check to one profession's engagement standards. Assessment opens it to a third party working under standards the Industry Standards Forum developed in consultation with SEBI. The KPIs being checked are the same Annexure 17A set either way.

So the instrument differs and the question does not. Both look at the same nine attributes and the same indicators beneath them. Both need an evidence chain behind each number. A company that picks assessment because it expects less scrutiny has misread the circular, and it will find out during the first engagement, when the evidence request arrives in exactly the shape it would have under assurance.

The report now prints which check you bought. Anyone reading it can see the choice, and ask why.

What did the value chain change remove, and what did it keep?

It removed the obligation and kept the design. A top-250 company no longer has to disclose value chain ESG data, and no longer has to have it checked. If it chooses to disclose, the partners in scope are those that individually make up 2 per cent or more of purchases or sales, it may cap coverage at 75 per cent, and it must state the share of purchases and sales its disclosure actually covers.

Voluntary does not mean unwatched. A voluntary disclosure goes into the annual report under the company's name like any other line, and a figure that later proves wrong damages credibility more than an absent one, because nobody made the company publish it. The coverage figure is the safeguard SEBI built in. A company that discloses on 40 per cent of its purchases says so, and the reader weighs the number accordingly.

Where does the burden sit now?

Inside the company. When the external check was one mandated form, the provider's methodology did a lot of the work of deciding what counted as evidence. With a choice of instrument, the company has to decide what standard its own records meet before it picks a provider, and it has to be able to defend that choice in public.

The health indicators are where this bites first. The BRSR Core attribute on enhancing employee wellbeing and safety carries the spend on wellbeing measures as a share of revenue and the safety incident counts for employees and workers. Those numbers are assembled from HR, finance and site registers that were never designed to be tested together. The boundary failures that sink them, and the four questions to put to every wellbeing number, are set out in BRSR Core and the health and climate disclosures most companies under-report. This page will not repeat them.

The pressure also arrives from outside SEBI. A subsidiary of a group reporting under European or ISSB-aligned standards can be asked for workforce and health data on the parent's terms, whatever the Indian floor requires, and that request does not wait for an Indian deadline. Head office has a climate-health mandate covers what a defensible answer to that request contains.

How should a company choose between assessment and assurance?

Start from the evidence, not the price. These questions settle most cases.

• Who else relies on itIf a parent, a lender or an index provider will take your BRSR Core numbers into their own reporting, ask what grade of check they accept before you commission one. Finding out afterwards means paying twice.
• Which numbers you would defendPick the two or three KPIs you would stand behind on a stage. Build their evidence to the strictest standard any reader applies, whichever instrument you choose.
• What you will disclose voluntarilyIf you intend to publish value chain data or a climate-and-health line nobody requires, decide whether it gets checked before you publish it, not after a question arrives.

Then pick the instrument that fits the evidence you have. The circular gave companies a choice, and a choice made on the evidence reads well in the report. A choice made on cost alone reads well until someone asks.

What comes after the glide path?

The glide path finishes this financial year. From FY 2026-27 the top 1,000 are all inside BRSR Core, and the circular sets no further step. What grows from here is the voluntary layer: value chain data, green credits, and whatever a company chooses to say about how climate is reaching its workforce and the people its programmes serve. No BRSR indicator asks that last question yet. The companies that answer it voluntarily, with a coverage figure and a check they chose on purpose, will be setting the terms of the disclosure before anyone mandates it. The standard-by-standard reference sits in the BRSR explainer, and the argument for why the question matters is in climate change is a healthcare story.

Questions worth asking after this

Is reasonable assurance of BRSR Core still mandatory?

No. Since SEBI's circular of 28 March 2025, listed entities in the glide path must obtain a third-party assessment, under standards developed by the Industry Standards Forum in consultation with SEBI, or an assurance engagement. One of the two is still mandatory.

Who needs BRSR Core assessment or assurance in FY 2026-27?

The top 1,000 listed entities by market capitalisation. The glide path set in July 2023 and restated in March 2025 runs from the top 150 in FY 2023-24 to the top 250, the top 500, and the top 1,000 from FY 2026-27. The circular sets no further step after that.

Is value chain ESG disclosure mandatory under BRSR?

No. For the top 250 listed entities it is voluntary from FY 2025-26, and its assessment or assurance is voluntary from FY 2026-27. A company that does disclose must cover partners that individually make up 2 per cent or more of its purchases or sales, may cap coverage at 75 per cent, and must state the share it covers.

Abhijith Magal

Founder, Syntropy Earth. Nine years across two global pharmaceutical multinationals in patient access and commercial roles, with health-equity work alongside the WHO-Foundation and UNICEF. He works on climate-access: where climate disruption breaks the link between patients and care. More about Abhijith →

This page describes the SEBI circulars as published. It is not assurance, assessment or legal advice, and reporting decisions should be taken with your provider.

Last updated: 24 September 2026