Can we point the BRSR to our GRI report or annual report instead of repeating the data?

Yes. Guidance from the Securities and Exchange Board of India (SEBI) for the Business Responsibility and Sustainability Report (BRSR) lets an entity cross-reference disclosures made under frameworks such as the Global Reporting Initiative (GRI), or its annual report, but it should name the page number where the information sits.

What the general guidance says

• Entities that prepare sustainability reports based on GRI, the Sustainability Accounting Standards Board (SASB), the Task Force on Climate-related Financial Disclosures (TCFD) or Integrated Reporting can cross-reference those disclosures to the BRSR.
• If the data is already in the annual report, a cross-reference to it is allowed, so the same information need not be disclosed twice.
• The entity should specifically mention the page number of the annual report or sustainability report where the information is disclosed.

Rules that stay in force

• Reporting boundary: the BRSR asks whether reporting is stand-alone or consolidated, and listed entities shall ensure consistency in the reporting boundary across the report.
• Reporting period means the financial year for which the BRSR is prepared.
• Where a disclosure does not apply to an industry, such as the service industry, the entity can state that it is not applicable and give the reasons.
• The entity should endeavour to give clear, complete and concise responses, with web-links to the relevant document if available.

Small details in the guidance

• Gender rows show male and female; a separate column of Other may be added.
• Complaint tables carry a Remarks column to explain pending complaints or the nature of the complaints.
• The entity may disclose any other relevant sustainability information at appropriate places.

A caution

Our reading, not SEBI's: a cross-reference only works if the figure in the GRI report uses the same boundary and period as the BRSR. If it does not, give the BRSR figure again and explain the difference.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records, so energy and fuel figures can be traced to the bill behind them. It does not write the report or hold the other disclosures.

• BRSR, GRI or ISSB: which one
• Documents behind each BRSR environment figure
• BRSR and BRSR Core in plain words

Sources: SEBI, master circular for LODR compliance, 11 July 2023, BRSR guidance note and formats

Last reviewed 2026-11-05. The guidance and formats are from SEBI's 11 July 2023 master circular and the Annexure II format. SEBI's April 2025 FAQ names a later master circular dated 11 November 2024, so check the current guidance note and format before you file.