India's New Supply Chain Accountability.

India’s top 250 companies are now being asked to report not just on their own impact, but also on the environmental and social performance of the companies they buy from (suppliers) and sell to (distributors).

𝟏. 𝐓𝐡𝐞 "𝐖𝐡𝐨" 𝐚𝐧𝐝 "𝐖𝐡𝐞𝐧"

SEBI introduced some "ease of doing business" relaxations to give companies more time to set up data systems.

• 𝐖𝐡𝐨: The top 250 listed companies (by market capitalization) in India.

• 𝐕𝐨𝐥𝐮𝐧𝐭𝐚𝐫𝐲 𝐃𝐢𝐬𝐜𝐥𝐨𝐬𝐮𝐫𝐞: For FY 2025-26, value chain reporting is voluntary.

• 𝐀𝐬𝐬𝐞𝐬𝐬𝐦𝐞𝐧𝐭/𝐀𝐬𝐬𝐮𝐫𝐚𝐧𝐜𝐞: Third-party verification of this value chain data becomes voluntary starting FY 2026-27.

• 𝐓𝐡𝐞 "𝐓𝐫𝐢𝐜𝐤𝐥𝐞 𝐃𝐨𝐰𝐧": Even though it's "voluntary" for the giants, they are already starting to demand this data from their MSME suppliers to ensure they are "compliance-ready" when the mandatory phase kicks in.

𝟐. 𝐃𝐞𝐟𝐢𝐧𝐢𝐧𝐠 𝐭𝐡𝐞 "𝐕𝐚𝐥𝐮𝐞 𝐂𝐡𝐚𝐢𝐧" (𝐓𝐡𝐞 𝟐% & 𝟕𝟓% 𝐑𝐮𝐥𝐞𝐬)

In the past, the definition of a "value chain partner" was vague. Now, SEBI has made it mathematically precise:

• 𝐓𝐡𝐞 𝟐% 𝐑𝐮𝐥𝐞: You must report on any upstream (supplier) or downstream (distributor/customer) partner that accounts for 2% or more of your total purchases or sales by value.

• 𝐓𝐡𝐞 𝟕𝟓% 𝐑𝐮𝐥𝐞: Companies have the option to limit their reporting to enough partners to cover at least 75% of their total value of purchases and sales.

𝟑. 𝐓𝐡𝐞 𝟗 "𝐁𝐑𝐒𝐑 𝐂𝐨𝐫𝐞" 𝐀𝐭𝐭𝐫𝐢𝐛𝐮𝐭𝐞𝐬

Companies need to report on 9 specific attributes (which are a high-integrity subset of the full 800+ BRSR KPIs):

𝟏. 𝐆𝐇𝐆 𝐅𝐨𝐨𝐭𝐩𝐫𝐢𝐧𝐭: Scope 1 and Scope 2 emissions (and eventually Scope 3).

𝟐. 𝐖𝐚𝐭𝐞𝐫 𝐅𝐨𝐨𝐭𝐩𝐫𝐢𝐧𝐭: Total consumption and discharge patterns.

𝟑. 𝐄𝐧𝐞𝐫𝐠𝐲 𝐅𝐨𝐨𝐭𝐩𝐫𝐢𝐧𝐭: Total energy used and percentage from renewables.

𝟒. 𝐖𝐚𝐬𝐭𝐞 𝐌𝐚𝐧𝐚𝐠𝐞𝐦𝐞𝐧𝐭: Data on plastic, e-waste, and hazardous waste.

𝟓. 𝐄𝐦𝐩𝐥𝐨𝐲𝐞𝐞 𝐖𝐞𝐥𝐥𝐛𝐞𝐢𝐧𝐠: Safety incidents and spending on worker welfare.

𝟔. 𝐆𝐞𝐧𝐝𝐞𝐫 𝐃𝐢𝐯𝐞𝐫𝐬𝐢𝐭𝐲: Percentage of women in the workforce and median pay parity.

𝟕. 𝐈𝐧𝐜𝐥𝐮𝐬𝐢𝐯𝐞 𝐃𝐞𝐯𝐞𝐥𝐨𝐩𝐦𝐞𝐧𝐭: Purchases specifically from MSMEs or small producers.

𝟖. 𝐅𝐚𝐢𝐫𝐧𝐞𝐬𝐬 𝐢𝐧 𝐄𝐧𝐠𝐚𝐠𝐞𝐦𝐞𝐧𝐭: Speed of payment to suppliers (days of accounts payable).

𝟗. 𝐁𝐮𝐬𝐢𝐧𝐞𝐬𝐬 𝐎𝐩𝐞𝐧𝐧𝐞𝐬𝐬: Transparency in related-party transactions.

𝟒. "𝐀𝐬𝐬𝐮𝐫𝐚𝐧𝐜𝐞" 𝐯𝐬. "𝐀𝐬𝐬𝐞𝐬𝐬𝐦𝐞𝐧𝐭"

This is a major change in 2025. Previously, SEBI only used the word "Assurance" (which usually means hiring a Big 4 accounting firm).

• 𝐓𝐡𝐞 𝐔𝐩𝐝𝐚𝐭𝐞: SEBI now allows "𝐀𝐬𝐬𝐞𝐬𝐬𝐦𝐞𝐧𝐭."

• 𝐓𝐡𝐞 𝐃𝐢𝐟𝐟𝐞𝐫𝐞𝐧𝐜𝐞: This opens the door for technical experts, environmental engineers, and specialized ESG startups to verify the data.

👉 𝐂𝐨𝐧𝐧𝐞𝐜𝐭 𝐰𝐢𝐭𝐡 C² (Csquare) 𝐭𝐨 𝐠𝐞𝐭 𝐬𝐭𝐚𝐫𝐭𝐞𝐝!

🌐 𝐜𝐬𝐪𝐮𝐚𝐫𝐞𝐜𝐚𝐫𝐛𝐨𝐧.𝐜𝐨𝐦

✉️ 𝐢𝐧𝐟𝐨@𝐜𝐬𝐪𝐮𝐚𝐫𝐞.𝐜𝐨.𝐢𝐧