1. Which listed Companies are mandatorily required to file BRSR?

Top one thousand listed Companies based on market capitalization shall mandatorily submit BRSR in the format as specified by the SEBI Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated May 10, 2021.

Link of market capitalization as on March 31, 2024, is given below: https://www.nseindia.com/regulations/listing-compliance/nse-market-capitalisation-all-companies

For e.g. If the listed Companies are falling under top one thousand listed Companies based on market capitalization as on March 31, 2024, filing of BRSR shall be applicable to them for the Financial Year 2023-24.

2. If the Company is not falling under top one thousand listed Companies based on market capitalization as on March 31, 2024, but the Company was falling under top one thousand listed Companies based on market capitalization as on March 31, 2023, and March 31, 2022, will BRSR be applicable to the Company for March 31, 2024, pursuant to Regulation 3 (2) of SEBI LODR, 2015?

• Pursuant to Regulation 3(2) of the SEBI LODR, 2015 - The provisions of these regulations which become applicable to listed companies on the basis of market capitalisation criteria shall continue to apply to such companies even if they fall below such thresholds.The listed companies are requested to comply with the existing Regulation.

3.Can the listed Companies which do not form part of top one thousand listed Companies file BRSR on a voluntary basis?

• Yes, listed Companies which do not form part of top one thousand listed Companies including the Companies which have listed their specified securities on the SME Exchange, may voluntarily submit BRSR.

4.If the listed Company is in top one thousand market capitalization list of NSE & not in top one thousand market capitalization list of BSE or vice versa. Whether the applicability for filing BRSR is with NSE / BSE only or with NSE & BSE together?

• If the listed Company is in the top one thousand market capitalization list on any Exchange, then the listed Company is required to file BRSR with both the Exchanges.

5.Which listed Companies are mandatorily required to obtain Reasonable Assurance on BRSR Core?

• Top 150 listed Companies based on market capitalization as on March 31, 2024, shall mandatorily obtain Reasonable Assurance of BRSR Core as specified by the SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated July 12, 2023.
• If the listed Companies have obtained assurance and selects “Yes” under “Whether the company has undertaken reasonable assurance of BRSR Core?” in BRSR utility, then it shall be mandatory to provide details of Point 15 i.e. Name of assurance provider & Point 16 i.e.Type of assurance obtained, in the BRSR utility. If listed Companies select “All / Partial”option under Point 16 in the BRSR utility, then the listed Companies need to specify whether the assurance obtained is “Reasonable Assurance” or “Limited Assurance”. Also, a copy of Reasonable Assurance Certificate is mandatorily to be attached along with theBRSR while submitting PDF & Annual Report with the Exchanges.

6.Whether the BRSR XBRL utility at the BSE portal can be used for uploading at NSE NEAPS portal and vice-versa?

• Yes, listed Companies can use either of NSE or BSE BRSR XBRL utility to upload at either of the Exchanges. The utility is compatible at both BSE and NSE.

7.What is the mode of submission of BRSR with the Exchange?

• The BRSR is to be submitted with the Exchange in PDF and XBRL mandatorily. The path for submitting the same is enumerated as under: XBRL & PDF: Path: NEAPS > Common XBRL Upload > Business Responsibility & Sustainability Report.

8.What is the timeline for submitting the BRSR in PDF and XBRL format?

• BRSR PDF and XBRL shall be submitted on the same day of submission of Annual Report with the Exchanges.

9.Whether the BRSR can be provided as a LINK in the Annual Report of the Company instead of publishing the whole report?

• Yes, BRSR Link can be provided in the Annual Report instead of publishing the whole report.

10.Is there any option for Revision for BRSR XBRL and PDF filed with the Exchange?

• Yes, BRSR filed with the Exchange can be revised by listed Company on the following path. XBRL & PDF: Path: NEAPS > Common XBRL Upload > Business Responsibility & Sustainability Report.
• Please note that although the option of filing revised BRSR with the Exchange is available, the same needs to be exercised only as a last resort and sparingly. The Exchange request(s) the listed Companies to verify the correctness of data and other fields prior to filing the original BRSR submission with the Exchange.
• Further, listed Companies need to submit Covering letter, wherein they should update what are the changes in the revised filing made.

11.What should listed Companies do in case data is not available for certain Industries fields?

• Some of the disclosures sought under the BRSR XBRL may not be applicable to certain industries, in such cases, the Company can state that such disclosure is not applicable along- with reasons for the same. The reason shall be provided in BRSR pdf and in BRSR XBRL under add Notes.

12.Has Exchange published any material / guidance note on BRSR?

• Yes, to help the listed Companies in understanding the updated disclosure requirements and concepts associated with the new format of the BRSR, NSE has released guidance on 38 sector- specific integrated guides to BRSR format. This comprehensive guidance provides detailed explanation of each parameter in the format and the objective for such disclosures, along with an elaborate guidance on how to measure and report such parameters. Link for the 38-sector specific guidance notes. https://www.nseindia.com/companies-listing/corporate-filings-bussiness-sustainabilitiy-reports (Kindly refer - NSE-SES Integrated Guide to BRSR)

13. What about listed Companies who are already preparing BRSR as per internationally accepted standards?

• Those listed Companies which prepare and disclose sustainability reports (as part of annual report) based on internationally accepted reporting frameworks such as GRI, SASB, TCFD, Integrated Reporting, can provide the cross-reference of the disclosures made under such framework to the disclosures sought under the BRSR. Further, if the data sought in the reporting format is already disclosed in the annual report, the listed Company can provide a cross- reference to the same.
• Thus, a Company need not disclose the same information twice in the annual report. However, the Company should specifically mention the page number of the annual report or sustainability report where the information sought under the BRSR format is disclosed as part of the report prepared based on internationally accepted reporting framework.

14. Where will be the BRSR filings displayed on NSE website?

• BRSR filings shall be viewed on NSE website through below mentioned link: https://www.nseindia.com/companies-listing/corporate-filings-bussiness-sustainabilitiy-reports

In case of query, the contact details of the NSE Officials are available over path NEAPS >HELP > CONTACT US > Listing Compliance.