Who counts as an associate or group entity under the BRSR Core conflict of interest rule?

The Securities and Exchange Board of India (SEBI) Frequently Asked Questions (FAQ) for Business Responsibility and Sustainability Report (BRSR) Core define group as the holding company, subsidiaries, associates and joint ventures of the listed entity. A provider's associates include its partners, parent, subsidiaries and entities it controls, and for a Chartered Accountant firm the whole network.

Why the two words matter

The SEBI conflict test says the provider or any of its associates must not sell products or provide non-audit, non-assessment or non-assurance services to the listed entity or its group entities. So both the provider's side and the listed entity's side are drawn wide.

Group, on the listed entity's side

For this circular, the FAQ says, group means the holding company, subsidiaries, associates and joint ventures of the listed entity.

Associate, on the provider's side

• If the provider is a firm or corporate entity: any of its partners, its parent, subsidiaries, associates, and any entity in which the provider, its parent or a partner has significant influence or control.
• For a Chartered Accountant firm: also all entities in the network firm or network entity of which the provider is a part.
• If the provider is an individual: any immediate relative as defined in the Companies Act, 2013, and any entity in which that individual has significant influence or control.

A check you can run

1. List every group entity of the listed company.
2. Ask the provider for its partners, parent, subsidiaries, associates and, if a Chartered Accountant firm, its network.
3. Ask whether any of them sells a product or a non-audit service to anything on the first list.
4. Keep the answer in writing.

Our reading

A network firm's advisory arm selling consulting to a subsidiary of the listed company would, on these definitions, be an associate selling a non-audit service to a group entity. The FAQ does not give that exact case, so take legal advice or ask the stock exchange if you are unsure.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It is not a BRSR Core provider and does not check a provider's independence.

• BRSR Core assurer: services allowed, barred
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Sources: SEBI, FAQs for the LODR Regulations, updated 23 April 2025, SEBI circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, 28 March 2025

Last reviewed 2026-11-05. SEBI's FAQ is dated 23 April 2025 and may be revised. Check the current FAQ.