Does BRSR require a board sustainability committee?
No. BRSR does not make a board sustainability committee mandatory. It asks you to name the highest authority responsible for your business responsibility policies and to answer Yes or No on whether a board committee or director is responsible for sustainability decisions, with details if Yes. A No is allowed, but investors will see it.
The governance questions in BRSR Section B
- Question 8: details of the highest authority responsible for implementing and overseeing the business responsibility policies.
- Question 9: whether the company has a specified committee of the board, or a director, responsible for decision making on sustainability issues. Yes or No, with details if Yes.
- Question 10: how the company reviews its performance against the nine NGRBC principles, whether that review is done by a director, a board committee or another committee, and how often.
Who has to file BRSR
Regulation 34(2)(f) of the SEBI LODR Regulations requires the top 1,000 listed entities by market capitalisation to include a BRSR in their annual report. Other listed companies may file one voluntarily. Unlisted companies are not covered, though they may receive value chain questions from listed customers.
Board rules that do touch sustainability
- Risk management committee: LODR Regulation 21 requires one for the top 1,000 listed entities, and its role in Schedule II includes identifying sustainability risks, in particular ESG related risks.
- CSR committee under Section 135 of the Companies Act, 2013: it oversees CSR policy and spending. It is not a sustainability committee unless its charter says so.
Ways companies answer Question 9
Whichever applies, answer from what the board charter and minutes support, because investors and assurance providers may ask to see them.
- A dedicated ESG or sustainability committee of the board, with its own charter.
- An existing committee, often risk management or CSR, whose charter has been widened to cover sustainability decisions.
- A named director given responsibility for sustainability.
- No committee, with the highest authority and review frequency disclosed under Questions 8 and 10.
What Senseible does here
Senseible's BRSR output is a self-declared draft built from your uploaded bills and invoices, with energy and emissions figures traced to their source documents. Governance answers such as Section B come from your board records and are completed by your company secretary.
Sources: SEBI circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122, 12 July 2023, with the updated BRSR format, SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, Regulations 21 and 34(2)(f)
Last reviewed 2026-10-17. SEBI amends the BRSR format and the LODR Regulations from time to time; check the current text before filing.