Environmental reporting and ESG

Define the report’s audience and evidence boundary

We first identify whether the requested output responds to a statutory condition, customer questionnaire, lender request or voluntary ESG initiative. Each needs an explicit reporting period, entity or site boundary and evidence standard.

The assignment can include a data-owner matrix, energy and water records, waste evidence, calculation notes and a draft narrative. Unsupported claims are flagged rather than filled with assumed savings or certification language.

Create an indicator register showing the requested measure, covered sites, period, unit and data owner. Identify whether the value comes from a measurement, a calculation or an estimate. Keep the recipient’s question beside the proposed response so a convenient available figure is not substituted for a different measure without explanation.

For a concrete reporting example, Section A of SEBI’s May 2021 BRSR format asks whether the disclosures cover the standalone entity or its consolidated group. That illustrates why the reporting boundary should be agreed before data collection. It does not mean that every customer questionnaire or voluntary ESG project is a BRSR filing.

What to prepare

• Reporting request and required framework, if any
• Site and entity boundary with reporting period
• Utility bills, production data and waste records
• Previous disclosures and calculation methodologies

Retain calculation workings with the source bills or operating records and explain exclusions, missing months and adjustments. Where a comparison uses production or floor area as a denominator, document that source as well as the environmental numerator. A change in calculation method or reporting boundary should remain visible when comparing the result with an earlier disclosure.

A practical example

A customer may request group-wide environmental data while only one factory has metered records. The response should identify that coverage limit and avoid presenting the factory’s results as the whole group’s performance.

For the single-factory example, the response can state which sites supplied data and which remain outside the calculation. If the company later adds another site, distinguish the effect of wider coverage from a change in operating performance. A larger reported total should not automatically be described as deterioration, nor a smaller boundary presented as an efficiency improvement.

Scope, fees and responsibilities

Preparation is not independent assurance or certification. Emissions inventories, assurance opinions and legally mandated disclosures require a separately defined methodology and qualified review where applicable.

The proposal identifies the deliverables, client data responsibilities and follow-up included. Government charges and external technical work are quoted separately where applicable.

The handover includes the indicator definitions, source index, calculations, missing-data explanations and agreed narrative. Management confirms the business facts and intended use before the response is issued. Keep the final version and subsequent corrections identifiable; independent assurance, where commissioned, needs its own scope and cannot be implied by completion of the preparation work.

SEBI’s April 2025 LODR FAQs discuss the expertise and independence of BRSR Core assurance or assessment providers, including conflicts involving consulting and preparation-related services. Where BRSR Core work is involved, establish the preparation role and the independent provider’s role separately at the outset. The appointment and applicable requirements need assessment for the actual engagement.