BRSR value-chain disclosures in 2026: what suppliers face

Many mid-sized Indian manufacturers and service providers have started receiving a new kind of request from their largest customers: their energy use, emissions, water, waste and workforce figures, often with evidence. The reason is the value-chain section of SEBI's BRSR framework.

What SEBI asks of listed companies

SEBI's July 2023 circular introduced ESG disclosures for the value chain of the top 250 listed companies.² Its circular of 28 March 2025 then changed the timetable and the scope:¹

• Value-chain disclosures are made on a voluntary basis from FY 2025-26, instead of comply-or-explain.
• Assessment or assurance of the value-chain disclosures is voluntary from FY 2026-27.
• The value chain means the company's top upstream and downstream partners, each making up 2% or more of its purchases or sales by value.
• A company that makes these disclosures states the percentage of its purchases and sales covered by those partners.

Voluntary does not mean ignored. Listed companies that intend to report on their value chain — and those preparing for the requirement to tighten — need their partners' figures, and they need them in a form that can be traced.

What suppliers can expect to be asked

The value-chain disclosures follow the BRSR Core indicators, so requests typically cover:

• greenhouse gas emissions (Scope 1 and Scope 2) and energy use;
• water withdrawal and consumption, and waste generated and recovered;
• workforce indicators such as safety and wellbeing;
• the evidence behind each figure, and how it was calculated.

How to respond well

1. Measure by site and month. Annual totals assembled at the last minute are hard to defend.
2. Keep the evidence — electricity bills, fuel registers, water meter readings.
3. Use recognised factors and say which ones: for Indian grid electricity, the CEA's grid emission factor.
4. Answer once, reuse often. The same figures are usually asked for by several customers.

Our guide Collecting ESG data from sites and suppliers covers the process from both sides.

How ESGTrack helps

For listed companies, ESGTrack identifies value-chain partners by SEBI's 2% rule, sends each one a request, follows the responses and keeps every figure with its evidence. For suppliers, a guided form can be finished in one sitting, and answers can be shared with other customers. More on the supplier data page.