Which fines and penalties go in the BRSR Principle 1 table?

Principle 1, essential indicator 2 of the Business Responsibility and Sustainability Report (BRSR) asks for fines, penalties, settlements and compounding fees paid in proceedings with regulators, law enforcement or courts. The guidance says disclosures are made on the basis of materiality in Regulation 30 of the listing regulations and as disclosed on the entity's website.

Two tables, monetary and non-monetary

• Monetary: penalty or fine, settlement, compounding fee. Each row gives the principle, the regulator or court, the amount in rupees, a brief of the case, and whether an appeal has been preferred.
• Non-monetary: imprisonment, punishment. Each row gives the principle, the regulator or court, a brief of the case, and whether an appeal has been preferred.
• The question covers amounts paid by the entity or by its directors or key managerial personnel.

The materiality rule

The note in the format, and the guidance of the Securities and Exchange Board of India (SEBI) on it, say the entity shall make disclosures on the basis of materiality as specified in Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, and as disclosed on the entity's website. The note ties the table to Regulation 30 materiality and to what the entity discloses on its website. Whether a small fine is in or out is a question for your company secretary; the guidance does not say (our reading).

The questions that follow

• Question 3: details of any appeal or revision preferred where monetary or non-monetary action has been appealed, with the case and the body.
• Question 5: number of directors, key managerial personnel, employees and workers against whom a law enforcement agency took disciplinary action for bribery or corruption.
• Question 7: details of corrective action taken or underway on fines, penalties and action by regulators, and on corruption and conflict of interest cases.

If you are a supplier

A listed buyer fills this table for itself, not for you. Expect a supplier questionnaire to ask about your own regulatory actions only if the buyer's policy says so; the BRSR text we checked does not ask for it.

Example: one row

• A fine of rupees (Rs) 2,00,000 paid to a regulator in a proceeding that Regulation 30 treats as material, with an appeal filed
• It goes in the monetary table as penalty or fine, appeal Yes, and again in the appeal details in question 3
• The corrective action goes in question 7

The amount is an example.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not hold legal or regulatory case records, so this table stays with your legal team.

• The environmental compliance question in the BRSR
• Essential and leadership indicators
• BRSR Core: the nine attributes and KPIs
• BRSR and BRSR Core in plain words

Sources: SEBI, Updated BRSR format, Annexure II to circular of 12 July 2023, 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.