Around a quarter of listed companies failed to file the mandatory emissions data for calendar year 2024 under the Securities and Exchange Board of India (Sebi)’s Business Responsibility and Sustainability Reporting (BRSR) guidelines, bringing focus on strengthening quality and integrity of disclosures, according to a report.
The report by the Indian Institute of Corporate Affairs (IICA) and Council on Energy, Environment and Water (CEEW) says that of the 1,000 companies mandated to file BRSR, 998 did so in 2024.
“However, filing the report does not guarantee completeness or accuracy of data. For instance, only 781 companies reported scope 1 and 2 emissions, which are essential indicators for reporting for FY25. The leadership indicator, scope 3, was reported by only 268 companies. This suggests that while accuracy of data needs verification, the quality and consistency of reporting also needs attention,” according to the authors’ analysis based on BRSR reports.
Scope 1 emissions are greenhouse gases that an organisation emits from sources it owns or controls directly. Scope 2 emissions are indirect, deriving from an organisation’s purchase of electricity, steam, heat, or cooling. Scope 3 emissions, also known as life-cycle emissions, are those that arise across the value chain, both upstream and downstream.
Corporations are a significant source of emissions across sectors, which makes them a useful cross-cutting lever to drive emission reductions.
“India’s total emissions stand at about 3 billion tonnes of carbon dioxide equivalent (tCO2e). Of this, the top 1,000 listed companies account for about 43% (1.3 billion tCO2e), whereas the emissions from companies between top 500 and top 1,000 are 0.3 billion tCO2e (which is 24%). This suggests that going beyond the top 1,000 alone may not yield substantial gains on emissions coverage, and may actually inappropriately widen the corporate net without widening the emissions net,” noted report.
The authors say that there is scope to extend emissions reporting coverage beyond 43% (share of the top 1,000) either by expanding the coverage of non-BRSR frameworks, such as those of the RBI, the IRDAI, and the PFRDA that are expected to enter into force, and introducing ministry-wise mandates for sectors uncovered through the above disclosures; or a revenue-based threshold, as in other jurisdictions, that will widen the net to include large non-listed firms, leaving smaller listed entities unaffected.
Emissions disclosures in India are mandated either as a part of broad Environment, Social and Governance (ESG) disclosures, or through emissions reporting requirements under the compliance carbon market (required FY26 onwards). Currently, Sebi’s BRSR is the only disclosure mandate in India—covering emissions within the broad ESG disclosure framework. It is mandatory to file for the top 1000 listed companies by market capitalisation.
Other regulators, such as the Reserve Bank of India (RBI), the Insurance Regulatory and Development Authority of India (IRDAI), and the Pension Fund Regulatory and Development Authority (PFRDA) have also integrated ESG risk monitoring within their regulatory purview, but are yet to introduce disclosure templates.
Other levers that the reports recommend are to strengthen quality and integrity of disclosures, harmonising real-time emissions monitoring through an interoperable system and building ecosystem capacity for emissions measurement and reporting among MSMEs.
