Lakshmikumaran & Sridharan Attorneys
Corporate Governance

ESG Compliance Guide

Environmental, Social, and Governance framework for Indian businesses - BRSR requirements, labour-related disclosures, and sustainable business practices.

The Three Pillars of ESG

Environmental
Climate action, resource management, and environmental stewardship
  • Carbon emissions and climate risk
  • Energy efficiency and renewables
  • Water management and conservation
  • Waste management and circular economy
  • Biodiversity and ecosystem impact
Social
Human capital, community relations, and social responsibility
  • Labour practices and working conditions
  • Employee health and safety
  • Diversity, equity, and inclusion
  • Human rights in supply chain
  • Community engagement and CSR
Governance
Corporate governance, ethics, and accountability
  • Board composition and independence
  • Executive compensation
  • Anti-corruption and business ethics
  • Risk management framework
  • Stakeholder engagement

Business Responsibility & Sustainability Report (BRSR)

Mandatory for top 1000 listed companies by market capitalization from FY 2022-23
Section A

General Disclosures

Company overview, products, operations, employees, CSR details

Section B

Management & Process Disclosures

Policy disclosures across 9 NGRBC principles, governance structure

Section C

Principle-wise Performance

Detailed metrics on each of the 9 NGRBC principles

BRSR Core

SEBI has introduced "BRSR Core" - a subset of key performance indicators with mandatory reasonable assurance for top 150 companies from FY 2023-24, expanding to top 1000 by FY 2026-27.

Labour-Related ESG Disclosures

Social pillar requirements under BRSR (Principle 3 & 5)

Workforce Composition

Total employees and workers (permanent, temporary, contractual)
Gender diversity at all levels
Differently-abled employees
Employee turnover rates

Training & Development

Training hours per employee
Skill development programs
Career advancement initiatives
Performance evaluation coverage

Health & Safety

Workplace injury rates (LTIFR)
Safety training coverage
Health assessment coverage
Fatalities and near misses

Labour Rights

Minimum wage compliance
Collective bargaining coverage
Grievance redressal mechanisms
Child labour prevention measures

Benefits & Welfare

Social security coverage (PF, ESI)
Health insurance coverage
Parental leave availability
Retirement benefits
9 NGRBC Principles
National Guidelines on Responsible Business Conduct
1

Businesses should conduct and govern themselves with integrity

Ethics & Transparency
2

Businesses should provide goods and services in a sustainable manner

Sustainable Products
3

Businesses should respect and promote well-being of all employees

Employee Well-being
4

Businesses should respect interests of all stakeholders

Stakeholder Engagement
5

Businesses should respect and promote human rights

Human Rights
6

Businesses should respect and protect the environment

Environment
7

Businesses engaged in influencing public policy should do so responsibly

Policy Advocacy
8

Businesses should promote inclusive growth and equitable development

Inclusive Growth
9

Businesses should engage with and provide value to consumers responsibly

Consumer Interest

ESG & New Labour Codes

The new labour codes significantly impact ESG disclosures, particularly in the Social pillar:

Code on Wages

  • • Minimum wage compliance disclosures
  • • Equal remuneration data
  • • Wage structure transparency

Social Security Code

  • • PF/ESI coverage metrics
  • • Gig worker protection data
  • • Maternity benefit compliance

OSH Code

  • • Workplace safety metrics
  • • Health check-up coverage
  • • Working hours compliance

IR Code

  • • Fixed-term employment data
  • • Standing orders compliance
  • • Grievance mechanism effectiveness
ESG Implementation Roadmap
  • 1
    Conduct materiality assessment for ESG factors
  • 2
    Establish ESG governance structure and accountability
  • 3
    Set measurable targets across E, S, and G pillars
  • 4
    Implement data collection and monitoring systems
  • 5
    Engage with stakeholders on ESG priorities
  • 6
    Integrate ESG into business strategy and operations
  • 7
    Prepare and publish ESG/BRSR report
  • 8
    Seek third-party assurance for key metrics

Frequently Asked Questions

BRSR is mandatory for the top 1000 listed companies by market capitalization from FY 2022-23. Other listed companies may file voluntarily. The top 150 companies must also get BRSR Core assured from FY 2023-24.

BRSR (Business Responsibility & Sustainability Report) replaced BRR (Business Responsibility Report) from FY 2022-23. BRSR is more comprehensive, with quantitative disclosures, sustainability focus, and alignment with global frameworks like GRI and TCFD.

Yes, for BRSR Core metrics. Top 150 companies need reasonable assurance from FY 2023-24, top 250 from FY 2024-25, top 500 from FY 2025-26, and top 1000 from FY 2026-27.

Labour law compliance directly feeds into ESG's Social pillar. Proper compliance with wage codes, safety standards, social security contributions, and fair employment practices all contribute to ESG scores and BRSR disclosures.

Discuss this topic with our Employment Law team