BRSR Core value chain data is voluntary but supplier evidence still matters

SEBI moved value-chain ESG disclosures to a voluntary approach. Suppliers should respond with defined boundaries and evidence, not treat every questionnaire as a legal mandate.

SEBI’s 28 March 2025 circular changed value-chain ESG disclosures to a voluntary approach and addressed assessment or assurance. That means a supplier questionnaire from a listed customer should not automatically be described as a direct legal obligation on the supplier. The customer may be preparing a voluntary value-chain disclosure, meeting another obligation or applying its own procurement requirements.

The practical response is neither refusal nor blind completion. Ask what the customer is reporting, which period and boundary apply, how the supplier was selected, which indicators are requested and what level of evidence or assessment is expected. Then provide data that is proportionate, traceable and clearly qualified.

Source evidence: SEBI circular 28 March 2025 on assessment or assurance and value chain disclosures.

• BRSR applies directly to listed entities within the SEBI framework; value-chain requests can reach private and overseas suppliers through commercial relationships.

• Current value-chain disclosure is voluntary. Keep that status separate from mandatory BRSR Core requirements that may apply to the listed entity itself.

• SEBI’s accepted approach focuses on top upstream and downstream partners individually representing 2 percent or more of purchases or sales, with the listed entity able to limit coverage to 75 percent by value. Check the current circular and reporting instructions before applying thresholds.

• A supplier figure needs boundary, period, method, source records, estimation note, approval and correction route.

Record the requesting listed entity, reporting year, value-chain position, product or service relationship, requested indicator, requested organisational or facility boundary, due date, unit, methodology, assessment expectation and intended publication. If the customer cannot explain these fields, do not manufacture precision.

For cross-border suppliers, map local units, fiscal periods and legal entity structures to the customer’s request. A calendar-year energy figure should not be silently inserted into an Indian financial-year field. State conversions and allocation methods.

For energy and emissions, retain invoices or meter records, fuel records, calculation workbook, emission-factor source and version, ownership boundary and any allocation. For water and waste, distinguish withdrawal, discharge, consumption, generation, treatment and destination; do not infer diversion from collection alone. For workforce and safety metrics, define worker populations, hours, case definitions and privacy protections.

Use a cover sheet that states which values are measured, calculated, estimated or unavailable. Identify material exclusions and whether the evidence has been internally checked or independently assessed. An honest limitation is more useful than an unsupported number.

A value-chain request can impose cost on smaller suppliers. Use the customer’s stated scope to avoid collecting irrelevant data. Where records contain personal, payroll, commercial or security-sensitive information, provide aggregated evidence or controlled inspection rather than an unrestricted data dump.

Record the lawful and contractual basis for sharing, the recipient, retention expectation and any onward disclosure. The listed entity’s reporting objective does not remove the supplier’s privacy, confidentiality or records-management duties.

BRSR Core covers a wider set of ESG indicators than greenhouse gases. Where emissions are requested, the customer still needs to explain attribution and method. The QSE Advisory supplier-data-quality article provides a deeper workflow for moving from spend-based estimates to supplier-specific Scope 3 data.

Likewise, a sustainability questionnaire is not proof that a product is low carbon, a facility is compliant or a supplier has been assured. Keep disclosure, inventory, claim and certification evidence separate.

A concise supplier statement should identify the reporting entity and site, period, indicator, unit, boundary, source record, calculation or estimation method, reviewer, limitations and version date. It should also say whether the value was prepared specifically for the customer and whether it has been independently assessed.

If a correction is discovered, issue a controlled replacement with the reason and affected fields. Do not overwrite the earlier submission without a record, particularly when the customer may already have incorporated it into a public report.

Suppose a fictional customer requests site electricity for 1 April 2026 to 31 March 2027. The supplier currently has only a calendar-year 2025 company total. Neither the requested period nor the requested site boundary is covered by that total.

All facts are invented. At the time of a request made before 31 March 2027, the full requested year would also be unfinished. Any year-to-date amount or forecast should be separately labelled and agreed with the customer, not presented as a measured full-year total.

A concise response could state: “The available company total does not match your requested site and reporting period. We have kept the requested value open and will agree the appropriate evidence and delivery date with you.”

Do not allocate the company total by customer sales simply to fill the blank unless an appropriate method and boundary have been established. This example demonstrates a qualified handoff; it creates no new BRSR duty or assurance conclusion.

Under SEBI’s March 2025 measure, the value-chain disclosure approach is voluntary. Confirm the latest circular and the listed entity’s own obligations.

No universal supplier rule follows from the BRSR circular. Contractual requirements and customer reporting choices may still matter.

The framework concerns coverage; public identification and commercial confidentiality require careful reading of the applicable reporting instructions.

Use the applicable methodology and disclose estimation, allocation, source and limitations. Do not present an estimate as directly measured.

This article is general information. Verify current requirements and seek qualified advice for your specific circumstances.

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