Thinking · Disclosure

BRSR Core and the health and climate disclosures most companies under-report.

Abhijith Magal · 20 September 2026 · 10 min read

What does BRSR require on health? Less than most teams assume, and in a different place. Health sits almost entirely under Principle 3, which covers the wellbeing of employees and workers, including the contract workforce. Climate sits under Principle 6. A listed company can file a complete, assured Business Responsibility and Sustainability Report and disclose nothing at all about the thing that is actually happening on its sites, which is a warming operating environment steadily degrading the health of the people it depends on. Our BRSR reference page sets out what the standard asks for line by line. This page is about where it stops asking.

The timing makes it worth attention now. FY 2026-27 is the first year in which the entire top 1,000 sits inside BRSR Core, so several hundred sustainability teams are about to have numbers tested that were never built to be tested.

Who is in scope, and when

SEBI's circular of 12 July 2023 introduced BRSR Core as a subset of BRSR, being a set of KPIs under nine ESG attributes, and set a glide path by market capitalisation. The circular of 28 March 2025 then eased the verification requirement, replacing reasonable assurance with assessment or assurance, where an assessment is a third-party review under standards developed by the Industry Standards Forum in consultation with SEBI. Value chain ESG disclosure moved to voluntary in the same circular, and a leadership indicator on green credits was added under Principle 6 from FY 2024-25.

That doubling matters more than it looks. The companies entering now are the ones ranked 501 to 1,000, which means smaller sustainability functions, fewer dedicated data owners and, in most cases, a first encounter with an external party testing a non-financial number.

The nine attributes, and where health hides

One attribute out of nine can carry the whole of climate-health, and it was written to carry occupational safety. That is the structural finding, and everything below follows from it.

The five disclosures that fail most often

These are the ones worth rehearsing before an assessor arrives, because four of the five fail for the same reason: the boundary of the number moves between the source register and the report.

Note what is common to the first four. None is a measurement problem. Each is a definition problem that was never written down, and an assessor tests the evidence chain behind a number rather than the number itself. A figure that is roughly right with nothing underneath it fails; a figure that is modest, defined and traceable passes.

An assessor does not ask whether the number is impressive. They ask who counted it, from what, and whether the same rule was applied in March as in September.

Four questions to put to every wellbeing number

• BoundaryWho is inside this number? Permanent employees, contract workers, value chain, or a mix that changes by site. Write it once and apply it everywhere.
• BasisWhat rule turns an event into a data point? When does an incident become recordable, and when does a heat illness become a safety incident rather than sick leave?
• EvidenceWhat document would you hand over if someone asked for the source? If the answer is a spreadsheet maintained by one person, that is the finding.
• ComparabilityDoes this year's number use last year's rule? A definition change without a restatement reads, from outside, as a performance change.

The disclosure nobody is required to make, and should

Nothing in BRSR asks what climate disruption cost the workforce or the community programmes. The Lancet Countdown's 2025 India data sheet puts the national figure at 247 billion potential labour hours lost to heat in 2024, 419 hours per person, with agriculture at 66 per cent of the loss and construction at 20 per cent. No company-level equivalent exists in any Indian disclosure. We read those national numbers in operating terms in five India numbers, and what each one costs you.

A company that reports one voluntary line is in a stronger position than one that waits for an indicator. The line does not need to be elaborate. Hours lost to heat at the three most exposed sites, measured the same way each year, tells an investor more about operating resilience than a page of intensity ratios. The disclosure also does something quieter and more useful internally: it forces someone to own the number, which is the step that precedes managing it.

The legal backdrop makes it sharper. Workplace heat is already covered by the general duty in India's occupational safety law, with no threshold attached, which is set out in heat is now a workplace duty of care. A company disclosing a wellbeing spend figure while holding no record of heat exposure is describing an input for an obligation it has not measured.

What to do in this reporting cycle

Three moves, in order, and none of them needs a new system.

Write the boundary document first. One page per BRSR Core KPI you own: who is inside the number, what rule converts an event into a data point, which register holds the evidence, and who signs it. Most assessment findings die in this document before they are raised.

Then reconcile Principle 3 against Principle 6 once, by hand. Put the sites with the highest energy and water intensity next to the sites with the highest incident rates and the highest attrition. Where the same sites appear on each list, you have found your exposure, and you have found it without buying anything.

Then add one voluntary line on climate and health. Keep it small enough to repeat next year. A measure that survives three cycles is worth more than an ambitious one that gets restated.

The CSR side of the same question, where the budget is statutory rather than the disclosure, runs through Section 135 and climate-health, and the rule-by-rule reference for every disclosure regime we track is in the regulations and standards library.

Common questions

What health metrics go into BRSR?

Health sits mainly under Principle 3, covering employee and worker wellbeing. Companies report measures including health and accident insurance coverage, maternity and paternity benefits and day care, spending on wellbeing as a share of revenue, whether a health and safety management system is in place, safety incidents including lost time injury frequency rate and fatalities for employees and contract workers, and the share of sites assessed for health and safety practices and working conditions.

Who has to obtain BRSR Core assessment or assurance in FY 2026-27?

The full top 1,000 listed entities by market capitalisation. The 12 July 2023 circular set the glide path: top 150 from FY 2023-24, top 250 from FY 2024-25, top 500 from FY 2025-26 and top 1,000 from FY 2026-27, the year that began on 1 April 2026. Rank is fixed by market capitalisation as of 31 March.

Is BRSR Core still reasonable assurance, or can a company choose assessment?

Either. SEBI's circular of 28 March 2025 replaced reasonable assurance with assessment or assurance, where assessment is a third-party review under standards developed by the Industry Standards Forum in consultation with SEBI. Value chain ESG disclosure moved from comply-or-explain to voluntary at the same time.

What are the nine BRSR Core ESG attributes?

Greenhouse gas footprint, water footprint, energy footprint, embracing circularity through waste management, enhancing employee wellbeing and safety, enabling gender diversity in business, enabling inclusive development, fairness in engaging with customers and suppliers, and openness of business. More than forty KPIs sit beneath them.

Why do employee wellbeing numbers fail assessment?

Most often because the boundary moves. Wellbeing spend is reported for permanent employees while the safety incident count includes contract workers, or a site counts as assessed on the strength of a self-declaration. An assessor tests the evidence chain behind the number, so a figure with no underlying register fails even when it is close to correct.

Does BRSR require companies to report climate impacts on worker health?

Not directly. Principle 3 asks about wellbeing and safety. Principle 6 asks about energy, emissions, water, waste and, through a leadership indicator, climate-related matters. Neither one asks what heat, flooding and air quality did to the workforce and to the reach of community health programmes, which is why that exposure sits undisclosed in reports that are otherwise complete.

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.

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

Last updated: 20 September 2026