Who counts as an employee, a worker, permanent or other than permanent in the BRSR?

Guidance from the Securities and Exchange Board of India (SEBI) for the Business Responsibility and Sustainability Report (BRSR) borrows the Industrial Relations Code, 2020 for employee and worker. Permanent means full-time or part-time for an indeterminate period. Other than permanent means a fixed term or task, and may be through third party contractors.

Employee and worker

• Employee: the guidance cites section 2(l) of the Industrial Relations Code, 2020: any person, other than an apprentice under the Apprentices Act, 1961, employed on wages to do skilled, semi-skilled or unskilled, manual, operational, supervisory, managerial, administrative, technical or clerical work.
• Worker: the guidance cites section 2(zr) of the same Code: any person, except such an apprentice, employed in any industry to do manual, unskilled, skilled, technical, operational, clerical or supervisory work.
• Among others, a worker does not include a person employed mainly in a managerial or administrative capacity, or in a supervisory capacity drawing wages exceeding eighteen thousand rupees per month or an amount as may be notified by the Central Government. The Code also excludes people subject to the Air Force Act, 1950, the Army Act, 1950 or the Navy Act, 1957, and people employed in the police service or as an officer or other employee of a prison.

Permanent and other than permanent

• Permanent: employed for full-time or part-time work, for an indeterminate period.
• Other than permanent: employed for a fixed term that ends when a specific time period expires, or on completion of a specific task or event such as the end of a project or the return of a replaced employee.
• The guidance says other than permanent staff could be employed directly or through third party contractors. It does not say how to class contractor labour on an indeterminate contract, so decide and record it (our reading).

Layout and timing

• The table shows permanent, other than permanent and the total, for employees and for workers, each with a male and female split.
• The guidance says to give details as at the end of the reporting period, and to explain any significant change in numbers from the beginning to the end.
• Differently abled staff are identified by the definition of persons with disabilities in the Rights of Persons with Disabilities Act, 2016.

What is left to the company

The guidance gives definitions but no rule for placing a particular person, such as a supervisor on a fixed-term contract. Decide, record the reason and apply it to every site. That is our reading.

Example: counting one plant

• Employees: 15 permanent + 5 other than permanent = 20
• Workers: 60 permanent + 20 supplied by a labour contractor on fixed-term or task terms (other than permanent) = 80
• Both tables are then split male and female, and the totals must match the headcount you report elsewhere

The headcounts are an example.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not hold payroll or contractor records, so headcounts stay with your HR files.

• BRSR employee turnover rate formula
• Health and safety assessments of value chain partners
• BRSR and BRSR Core in plain words

Sources: SEBI, master circular for LODR compliance, 11 July 2023, BRSR guidance note and formats, SEBI, Updated BRSR format, Annexure II to circular of 12 July 2023

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.