SEBI (LODR) Regulation 34(2)(f), SEBI Master Circular on BRSR Core, ICAI SAE 3410 & ICAI Social Audit Standards (SAS 100–1600)

ESG & BRSR Assurance

Independent reasonable and limited assurance on Business Responsibility and Sustainability Reporting (BRSR) Core parameters under SEBI (LODR) Regulation 34(2)(f), GHG emissions verifications under SAE 3410, and ICAI Social Audit Standards (SAS 100 to 1600) with universal UDIN certification.

CA Due Diligence

Official Portal Filing

State Stamp Advisory

Turnkey Statutory Filing

MCA & Tax Practice

Official Govt of India AuthoritySecurities and Exchange Board of India, Government of India

SEBI Official Portal & Stock Exchanges (NSE / BSE)

The official Government of India portal for SEBI regulations, circulars on BRSR Core ESG assurance mandates, and listing compliance portals on NSE (nseindia.com) and BSE (bseindia.com).

Visit Govt Portal

STATUTORY OVERVIEW

Independent Sustainability Assurance & SEBI BRSR Core Attestation

Environmental, Social, and Governance (ESG) reporting has evolved from voluntary corporate social responsibility narratives into rigorously audited statutory disclosures. Under Regulation 34(2)(f) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 [SEBI (LODR) Regulations], listed entities and their key value-chain partners must provide independent reasonable or limited assurance over Business Responsibility and Sustainability Reporting (BRSR) Core Key Performance Indicators (KPIs). Guided by the Standard on Assurance Engagements (SAE 3410) and the Institute of Chartered Accountants of India (ICAI) Social Audit Standards (SAS 100 to 1600), our multidisciplinary assurance practice validates sustainability data to safeguard corporate reputation, eliminate greenwashing risks, and meet institutional investor expectations.

Statutory & Practice Summary • At-A-Glance

ICAI UDIN Authentication Mandate

Governing Framework

SEBI (LODR) Regulation 34(2)(f), SEBI Master Circular on BRSR Core, ICAI SAE 3410 & ICAI Social Audit Standards (SAS 100–1600)

Regulatory Authority

Securities and Exchange Board of India (SEBI), Ministry of Corporate Affairs (MCA) & The Institute of Chartered Accountants of India (ICAI)

Professional Assurance

Chartered Accountants Attestation under ICAI Standards & Code of Ethics

DOCUMENTATION MATRIX

Mandatory Documents Checklist

Self-attested scanned copies required

1. Promoters / Partners / Directors KYC

✓Board of Directors / ESG Committee resolution approving the BRSR Core reporting framework
✓Nomination and Remuneration Committee governance records and POSH Committee reports
✓Written Management Representation on ESG assertions under ICAI SAE 3000 (Revised)

2. Registered Office & Premises Proof

✓Consent to Establish (CTE) and Consent to Operate (CTO) from State Pollution Control Boards (SPCB)
✓Factory, corporate headquarters, and warehouse operational location certifications

3. Specific Statutory Declarations & Enclosures

•Utility electricity bills, diesel consumption logs, and refrigerant replenishment records for Scope 1 & 2 GHG footprint
•Water withdrawal, consumption, and effluent discharge monitoring meter logs with third-party testing reports
•Hazardous and non-hazardous waste generation manifests, EPR plastic recycling certificates, and circularity data
•Human Resources payroll data: Total workforce count, gender diversity ratios, and median wage distributions
•Occupational Health & Safety (OHS) incident registers: Loss Time Injury Frequency Rate (LTIFR) and training records
•Tier-1 Value Chain Supplier ESG compliance assessments and Code of Conduct acceptance records

PROCEDURAL ROADMAP

Step-by-Step Filing & Approval Process

Structured execution roadmap managed by our Chartered Accountants from pre-filing due diligence to certificate allotment.

01Month 1

Materiality Assessment & Boundary Setting

Defining reporting boundaries (operational vs financial control), identifying value chain scope, and determining material ESG parameters under SEBI guidelines.

02Month 2

Data Validation & Carbon Footprint Sync

Validating activity data, testing electricity and fuel consumption logs, auditing emission factors under the GHG Protocol, and evaluating water/waste intensity.

03Month 3

Social & Governance Fieldwork (SAS 100-1600)

Reviewing employee diversity, median wage parity, occupational safety incident records, Section 135 CSR impact assessments, and whistle-blower mechanisms.

04Final Month

Independent Assurance Report & UDIN

Issuing the Independent Reasonable / Limited Assurance Report under SAE 3410 with mandatory ICAI UDIN, incorporated into the Annual Report filed on NSE/BSE.

SEBI (LODR) Regulation 34(2)(f) BRSR Core Assurance

Practice Scope & Statutory Guidance

We perform independent assurance over the nine mandatory attributes of SEBI's BRSR Core framework, including Greenhouse Gas (GHG) emissions footprint, water consumption and discharge intensity, waste management and circularity ratios, employee gender diversity, gross wages paid to female employees, health and safety incident rates, and supplier ESG compliance. Our procedures evaluate underlying source data, metering calibration logs, utility bills, and calculation methodologies in accordance with SEBI circulars and statutory guidelines.

Greenhouse Gas (GHG) Accounting & SAE 3410 Standards

Practice Scope & Statutory Guidance

In accordance with Standard on Assurance Engagements (SAE 3410 - Assurance Engagements on Greenhouse Gas Statements) and the GHG Protocol, we verify Scope 1 direct emissions, Scope 2 indirect emissions from electricity consumption, and relevant Scope 3 value-chain emissions. Our team validates emission factor selections, organizational boundaries (operational vs financial control), and energy transition assertions to ensure audit-ready carbon accounting.

Companies Act Section 135 CSR Audits & ICAI Social Audit Standards

Practice Scope & Statutory Guidance

Under the Social Audit Standards (SAS 100 to 1600) issued by the Social Audit Standards Board (SASB) of the ICAI, we provide independent verification of corporate social initiatives, Corporate Social Responsibility (CSR) impact assessments under Section 135 of the Companies Act, 2013 read with the CSR Policy Rules, fair remuneration practices, occupational health standards, and ethical vendor governance across tier-1 supplier networks.

STATUTORY MATRIX

Statutory Provisions & Regulatory Comparative Matrix

Comparative analysis of governing sections under the new framework alongside legacy statutory references.

SEBI BRSR Core ESG Parameter	Governing Standard / Statute	Statutory Assurance Scope & Key Metric
Greenhouse Gas (GHG) Footprint (Scope 1 & 2)	SEBI LODR Reg 34(2)(f) & ICAI SAE 3410	Verification of direct emissions (fuel combustion) and indirect emissions (electricity) per unit of turnover.
Water Consumption & Discharge Intensity	SEBI Circular on BRSR Core KPIs	Measurement of total water withdrawal, consumption, recycle percentage, and zero liquid discharge (ZLD) status.
Waste Management & Circularity Ratios	SEBI Circular on BRSR Core KPIs	Quantity of hazardous and non-hazardous waste generated, percentage recovered through recycling, and disposal modes.
Employee Diversity & Gender Wage Parity	ICAI Social Audit Standards (SAS 100–1600)	Percentage of female employees/directors, gross median wage ratio of female to male employees, and wage compliance.
Fair Remuneration & Value Chain ESG	SEBI Regulation 34(2)(f) Value Chain Mandate	Percentage of key value chain partners (top 75% purchases/sales) audited on ESG compliance and timely payments.

ONGOING GOVERNANCE

Mandatory Post-Registration Compliances

Failing to complete statutory post-incorporation actions carries steep daily penalties. Our CA firm manages continuous compliance:

BRSR Core in Annual ReportPart of Annual Report (within 21 days of AGM)

Submission of BRSR to Stock Exchanges

Mandatory filing of the Business Responsibility and Sustainability Report on NSE and BSE portals under Regulation 34(2)(f).

Corporate Sustainability PortalSimultaneous with Annual Report

Publication of Assurance Statement on Website

Hosting the independent assurance report and detailed ESG performance tables on the company's official corporate website.

Form CSR-2 & Impact Assessment ReportAnnexed to Board's Report (AOC-4)

Section 135 CSR Impact Assessment Filing

Mandatory independent impact assessment for projects having outlays of ₹1 Crore or more, undertaken by independent agencies.

ICAI SQC-1 ComplianceMinimum 8 Years

Assurance Working Paper Retention

Preserving emissions calculation sheets, metering calibration records, utility bills, and social audit interview evidence.

FREQUENTLY ASKED QUESTIONS

Statutory FAQs & Practical Guidance

Frequently asked questions and procedural guidance regarding ESG & BRSR Assurance.

Which companies are mandatorily required to obtain assurance on BRSR Core in India?

Under SEBI (LODR) Regulation 34(2)(f), the top 1,000 listed entities by market capitalization are required to publish the Business Responsibility and Sustainability Report (BRSR). Within this group, SEBI phased in mandatory reasonable assurance over the 'BRSR Core' framework, starting with the top 150 listed entities, expanding to the top 250, and progressively covering the top 1,000 entities and their key value chain partners.

What are the 9 key parameters under the SEBI BRSR Core framework?

The 9 BRSR Core parameters are: (1) Greenhouse Gas (GHG) footprint (Scope 1 & 2), (2) Water footprint, (3) Energy footprint, (4) Waste management, (5) Employee well-being and safety, (6) Gender diversity and wages paid to females, (7) Inclusive development (spending in aspirational districts), (8) Fairness in engaging with customers and suppliers, and (9) Openness of business (percentage of input purchases from MSEs/local suppliers).

Can the Statutory Financial Auditor also provide BRSR Core assurance?

Under SEBI guidelines, the assurance provider cannot be an entity that has a conflict of interest with the company. While the statutory auditor can provide BRSR assurance provided independence criteria are satisfied, many listed entities engage independent specialized assurance firms possessing domain certification in GHG carbon accounting (SAE 3410) and ICAI Social Audit Standards.

What is the difference between Limited Assurance and Reasonable Assurance under SAE 3410?

In a Limited Assurance engagement (negative assurance), the auditor states that 'nothing has come to our attention to cause us to believe that the statement is materially misstated' based on inquiries and analytical procedures. In a Reasonable Assurance engagement (positive assurance), the auditor performs extensive substantive testing, physical site visits, and metering recalibrations to provide a high level of assurance stating that 'in our opinion, the statement is fairly stated in all material respects'.

STATUTORY ADVISORY DESK • PRACTICE INQUIRIES

Statutory Inquiries & Practice Advisory

In strict conformity with ICAI Council Guidelines No. 1-CA(7)/06/2004, professional engagements for ESG & BRSR Assurance are accepted following formal conflict verification and statutory documentation. Contact our registered practice offices for procedural guidance.

Contact Practice Office +91 99140-14949