SEBI confirms BRSR Core value chain disclosure timeline for top 1000 entities
Assured value chain sustainability disclosure applies from FY 2027-28, covering upstream and downstream partners accounting for 75% of purchases and sales.
SEBI has confirmed the timeline for value chain disclosure under BRSR Core, requiring the top 1000 listed entities by market capitalisation to report on the sustainability performance of their value chain partners from FY 2027-28, with assurance following a year later.
What is required
Value chain partners are defined as those individually comprising at least two percent of purchases or sales by value, cumulatively covering seventy-five percent of the entity's purchases and sales.
For those partners, the entity must report the nine BRSR Core attributes: greenhouse gas intensity, water intensity, energy intensity, waste intensity, employee wellbeing spend, gender diversity in participation, wages, openness of business and job creation in smaller towns.
The obvious problem
Your value chain partners do not currently measure most of this, and you have no authority to require them to.
For a listed manufacturer, seventy-five percent of purchases typically means somewhere between forty and two hundred suppliers, many of them mid-size unlisted businesses with no sustainability function. Asking them for greenhouse gas intensity produces either a blank response or a number nobody can substantiate.
SEBI has permitted estimation and disclosure of methodology, which is the sensible accommodation, but it does not remove the collection exercise. Someone has to ask a hundred suppliers a structured set of questions annually and record what came back.
What actually works
The organisations further ahead on this have done three things:
Built the ask into procurement, not sustainability. The data request is part of the vendor onboarding and annual renewal process, owned by procurement, rather than a separate annual survey from a sustainability team with no leverage.
Started with the largest twenty. Getting good data from partners covering forty percent of spend is more useful than poor data covering seventy-five percent, and it establishes the method.
Documented the estimation methodology first. Where a partner cannot supply data, the estimation basis is defined, applied consistently and disclosed. Retro-fitting a methodology after collecting inconsistent data does not work.
Interaction with other obligations
There is meaningful overlap with the Carbon Credit Trading Scheme for obligated entities, and with customer-driven requests from European buyers subject to CSRD and CBAM. Organisations running these as three separate data collection exercises will ask the same supplier the same question three times in three formats.
One supplier sustainability data model serving all three is the sensible structure, with differences handled at the point of use.
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This analysis is provided for information only and does not constitute legal advice. Read it alongside the primary source it cites. Where a source reference is given (SEBI/HO/CFD/CFD-PoD-1/CIR/2026/94), that is the authoritative text.