In short
An invented example of how a listed cement manufacturer entering the top 500 might get ready for its first BRSR Core reasonable assurance — from scoping in October to a signed statement in July — and the problems a dry run would typically find. The company, people and figures are invented to show the steps.
The starting point
The company in this scenario makes cement at four integrated plants and two grinding units. Its market capitalisation puts it in the top 500 listed companies for FY 2025-26, so for the first time its BRSR Core figures need independent assessment or assurance1. It has filed a BRSR for three years, but the figures came from spreadsheets sent by each plant in April and assembled by a two-person sustainability team.
The CFO decides on reasonable assurance, as most large companies have chosen, and appoints a firm that does no other work for the group — SEBI bars the provider from consulting for the company1.
October: scope before data
The first meeting with the assurer is about scope, not figures. Together they agree:
- The boundary: the standalone company — six sites and the head office. A captive power plant at one site is inside the boundary; a joint-venture packaging unit is outside it, and the BRSR will say so.
- The KPIs: all nine BRSR Core attributes, with process emissions from calcination shown separately within Scope 1.
- The methodology document: for each KPI, the source records, the calculation, the emission factors (with publisher and version), and who enters and approves at each site.
Writing the methodology takes the sustainability head two weeks. It turns out to be the document the assurer refers to most.
November–December: back-filling the year
Each plant enters April to November month by month, attaching evidence as it goes: fuel stock registers and delivery challans for coal, petcoke and diesel; meter readings and electricity bills; kiln feed and clinker production for calcination; the waste register and recyclers' certificates; the safety register; payroll extracts for wages and headcount.
Two problems surface early. One plant has no photos of its water meter readings for June and July; the team uses the borewell pump's log hours and its rated flow, records it as an estimate with the method, and starts photographing readings. And the plants have been converting coal tonnes to energy with three different calorific values; the methodology now says each plant uses the monthly lab value, with the supplier's value only when the lab result is missing.
January: the dry run
In January the assurer tests a sample of 25 figures from April to December. It finds what dry runs usually find:
| Finding | What it was | Fix |
|---|---|---|
| Out-of-date factor | One site still used FY 2023-24's grid factor (0.727) after CEA had published FY 2024-25's (0.710, version 21.0, December 2025) | Factors from one maintained library, by date; the methodology says which year applies when the current year's is not yet published |
| Missing approvals | Three monthly diesel figures entered and approved by the same person | Approver changed; the three figures re-approved by the plant head |
| Waste in the wrong category | Discarded electronics from the plants' IT and control rooms reported as "other non-hazardous waste" | Moved to BRSR's e-waste category, with the recycler's certificate attached |
| Unexplained drop | Water consumption 38% lower in August at one plant | A reason added — the kiln was down for 19 days of planned maintenance — with the shutdown record attached |
None of these is hard to fix in January. Each would have been an argument in June.
April–July: close, test, sign
The year closes in April with every site and month either entered or marked "not used at this site" with a reason. Fieldwork runs through May and June: the assurer samples figures at two plants on site and the rest remotely, and raises queries against the figures they are about. The team answers most within two working days.
The assurer signs its reasonable assurance statement in July. The approved figures are locked; any later change needs a recorded reason. The BRSR goes to both exchanges in PDF and XBRL with the annual report. The same approved fuel, electricity and production data also feed the plants' reports under the Carbon Credit Trading Scheme, whose emission intensity targets cover cement2 — those follow the Bureau of Energy Efficiency's procedure, plant by plant and per tonne of product, so their totals need not match the BRSR's.
What the team would keep, and what it would change
- Keep starting in October with the methodology, not in March with the data.
- Attach evidence when a figure is entered. The two missing months of photos cost more time than everything else together.
- One factor library, chosen by date. Most calculation findings were factor findings.
- Explain big movements when they happen, by the person who knows why.
How this would run in ESGTrack
In ESGTrack, the plants would enter figures with evidence attached and fingerprinted, approvals would be named and separated, factors would come from one library by date, and the assurer would query and sign inside ESGTrack, with figures locked once signed. See assurance readiness and our guide to getting ready for BRSR Core assessment or assurance.
References
- Master Circular for compliance with the SEBI (LODR) Regulations, 2015 — Chapter IV-B — SEBI (copy published by NSDL). 30 January 2026; checked October 2026
- Greenhouse Gases Emission Intensity Target Rules, 2025 (G.S.R. 739(E), 8 October 2025), as amended by G.S.R. 25(E) — Ministry of Environment, Forest and Climate Change (the amendment, which recites the 2025 Rules; copy published by TEXPROCIL). 13 January 2026; checked October 2026
Next review due 1 April 2027. Regulations change: check the primary sources above before relying on a date or threshold.