CSRD vs BRSR: Which Sustainability Framework Does Your Indian Company Actually Need?

The Compliance Landscape Just Changed (And Nobody's Talking About It)

If your Indian company has:

• European subsidiaries

• EU-listed debt or equity

• Consolidated EU revenues >€150M

You're potentially in CSRD territory. And yes, that's in addition to your BRSR requirements.

But here's the thing most consultants won't tell you upfront:

These frameworks aren't enemies. They're cousins.

CSRD vs BRSR: The Side-by-Side Breakdown

📋 APPLICABILITY

BRSR (Business Responsibility and Sustainability Reporting)

• Top 1,000 listed companies by market cap (NSE/BSE)

• Mandatory since FY 2022-23

• SEBI-mandated for Indian companies

• ~1,000 companies currently affected

CSRD (Corporate Sustainability Reporting Directive)

• EU-based companies + non-EU with significant EU operations

• Phased rollout: 2024-2028

• Replaces NFRD (Non-Financial Reporting Directive)

• Potentially affects 50,000+ companies globally

💡 Indian Impact: If you're Tata Motors, Infosys, or any Indian MNC with EU presence—you're looking at dual compliance.

⏰ TIMELINE REQUIREMENTS

BRSR

• Annual reporting (aligns with financial year)

• Disclosed in Annual Report

• FY 2023-24 onwards: Core + extended metrics

• No independent assurance required (yet)

CSRD

Company Type	First Report Due
Large EU public companies (>500 employees)	FY 2024 (Report in 2025)
Other large EU companies	FY 2025 (Report in 2026)
Listed SMEs	FY 2026 (Report in 2027)
Non-EU companies with EU operations	FY 2028 (Report in 2029)

💡 Reality Check: CSRD requires limited assurance from day one, progressing to reasonable assurance by 2028.

🔍 DISCLOSURE DEPTH: Where They Diverge

BRSR: The "What" Framework

• 9 Principles, 30+ Key Performance Indicators

• Quantitative + some qualitative

• Focus: Governance, stakeholders, environment, social impact

• Depth: Moderate (200-300 data points typically)

• Approach: Checklist-driven

CSRD: The "Why, How, and What Next" Framework

• Double materiality assessment (financial + impact)

• 12 ESRS (European Sustainability Reporting Standards)

• 1,000+ potential data points

• Forward-looking metrics required

• Approach: Narrative + data storytelling
  

The Real Differences Nobody Mentions

1. Materiality Philosophy

BRSR asks: "What ESG topics are we involved in?"

CSRD demands: "What impacts us financially AND what do we impact environmentally/socially?"

This isn't semantic. It changes everything about how you collect data.

2. Value Chain Inclusion

BRSR: Your direct operations (mostly)

CSRD: Your entire value chain—including:

• Scope 3 emissions from suppliers

• Downstream product use

• Employee commuting

• Customer behavior post-sale

One Indian textile exporter told me: "BRSR was our annual report. CSRD feels like mapping our entire supply chain DNA."

3. Assurance Requirements

BRSR: Currently voluntary assurance

• Most companies self-report

• Growing trend toward external verification

CSRD: Mandatory third-party assurance

• Limited assurance initially (like financial statement review)

• Reasonable assurance by 2028 (like full audit)

• Specific EU-approved assurers only

Translation: Budget for audit fees in your CSRD planning.

The Strategic Question: Do You Need Both?

Here's my decision framework:

✅ You MUST do BRSR if:

• You're in top 1,000 NSE/BSE listed companies

• (Non-negotiable—SEBI mandate)

✅ You MUST do CSRD if:

• You're an EU-incorporated entity above thresholds

• You're a non-EU company with >€150M EU revenue + EU subsidiary/branch
  

🤔 You SHOULD CONSIDER CSRD if:

• Major EU clients are demanding it (supplier due diligence)

• You're planning EU expansion

• Your competitors are already CSRD-compliant

The Smart Play: Strategic Alignment

Here's what leading Indian MNCs are doing:

Step 1: Build BRSR compliance as your foundation

• It's mandatory anyway

• Creates data collection infrastructure

• Establishes baseline ESG metrics

Step 2: Map BRSR to ESRS standards

• ~60% overlap in environmental metrics

• Similar governance disclosures

• Social metrics have divergence (CSRD goes deeper)

Step 3: Layer CSRD-specific requirements

• Double materiality assessment

• Value chain expansion

• Forward-looking metrics

• Taxonomy alignment (if applicable)
  

The Data Infrastructure Reality

Most companies fail at sustainability reporting because of data, not intent.

BRSR Data Needs:

• HR systems (workforce metrics)

• EHS systems (environmental data)

• Procurement records (supplier diversity)

• Energy bills and utility data

Typical setup time: 4-6 months

CSRD Data Needs:

• Everything in BRSR, plus:

• Value chain emissions (Scope 3)

• Biodiversity impact assessments

• Forward-looking scenario analysis

• Financial-ESG integration metrics

Typical setup time: 12-18 months

Pro tip: If you're facing both, start building the CSRD-level infrastructure now. BRSR compliance becomes a byproduct.

Cost Reality Check

Based on conversations with 50+ Indian companies:

BRSR Implementation:

• Small-cap listed company: ₹15-30 lakhs

• Mid-cap: ₹40-80 lakhs

• Large-cap: ₹1-2 crores

CSRD Implementation:

• Initial assessment: €50,000-150,000

• Full implementation: €200,000-500,000

• Annual compliance: €100,000-250,000

Why the difference? Assurance requirements, value chain data, and EU regulatory complexity.

The 2025 Action Plan

If You're BRSR-Only (For Now):

Q1 2025:

• Complete BRSR Core reporting

• Begin extended metrics if not already doing

Q2-Q3 2025:

• Assess EU exposure (revenue, subsidiaries, clients)

• Gap analysis: BRSR vs CSRD requirements

Q4 2025:

• If CSRD-applicable: Start double materiality assessment

• Build business case for data infrastructure upgrade

If You're CSRD-Bound:

Immediate:

• Engage EU sustainability consultant + Indian implementation partner

• Start value chain mapping

• Budget for 18-month implementation

Q2 2025:

• Complete double materiality assessment

• Identify data gaps

• Select reporting software/platform

Q3-Q4 2025:

• Pilot data collection across value chain

• Train finance team on ESG-financial integration

• Engage assurance provider early
  

The Unpopular Truth

Many Indian companies are treating this as a compliance checkbox.

The winners are treating it as competitive intelligence.

Why?

1. Supplier preference: EU companies must report Scope 3. They're prioritizing CSRD-ready suppliers.

2. Access to capital: EU banks and investors are using CSRD data for credit/investment decisions.

3. Operational insight: The data you collect reveals inefficiencies you didn't know existed.

One automotive component manufacturer discovered through their CSRD prep that switching to renewable energy would reduce costs by ₹4.2 crores annually—info that was buried in their utility data all along.

Final Take: What We Tell Every CFO

"Think of BRSR as your sustainability driver's license you need it to operate in India.

Think of CSRD as your international sustainability passport you need it to compete globally.

The question isn't which one to choose. The question is: What's your growth trajectory, and what will you need 3 years from now?"

Your Move

We are curious where is your company in this journey?

Comment below:

• 🟢 BRSR only (and staying there)

• 🟡 BRSR now, CSRD watching brief

• 🔴 Dual compliance already

And if you're already implementing both what's been your biggest surprise?

Let's build a knowledge base together. The companies that figure this out first will have a serious competitive advantage.

P.S. If you found this useful, here's how Csquare helps companies navigate this:

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