Senseible

How does a listed company report BRSR value chain emissions when an MSME supplier gives no data?

Report what partners actually sent, state the coverage you reached, and either leave silent suppliers out with that gap named or add a clearly labelled estimate with its method. Never fold estimates into partner-reported totals without saying so. The disclosure is voluntary from FY 2025-26, so partial, clearly stated coverage is a legitimate answer.

Who is on the partner list

The list is set by value. Since SEBI's March 2025 circular, a supplier or customer is a value chain partner if it alone is 2% or more of your purchases or sales, and you may stop adding partners once those covered reach 75%. For the top 250 listed companies the whole disclosure is voluntary from FY 2025-26, and its assessment or assurance is voluntary from FY 2026-27.

Three ways to handle a silent supplier

  1. Make it easy to answer: send a one-page template with only the indicators you need, the April to March period and the units, and offer a call. Many MSMEs can work out Scope 1 and 2 from a year of fuel invoices and electricity bills once they know what is wanted.
  2. Disclose with coverage: report the partners that responded and state their share of purchases. Name the gap rather than hide it.
  3. Estimate, clearly labelled: from the supplier's own proxies, such as known output or sanctioned load, from the intensity of responding peers making similar goods, or from a spend-based factor. Show the method and the data used.

How estimates fit the GHG Protocol

SEBI asks for the BRSR Core indicators of each partner to the extent they are attributable to your business with that partner. Chapter 7 of the GHG Protocol Scope 3 Standard allows secondary data and estimates where primary data is not available, provided the method and data quality are disclosed. A reader of the BRSR value chain section expects figures supplied by partners, so keep estimates on a separate line or in a footnote and never present them as partner data.

Agree with your assessment or assurance provider, before the season, how estimates should be shown.

What to keep for the assessor

Worked example: coverage and one estimate

SEBI asks for the share attributable to your business with the partner, so scale a partner's whole footprint by your share of its sales, and do it the same way for every partner.

What Senseible does here

A supplier using Senseible can build its Scope 1 and 2 from its own fuel invoices and electricity bills and share the totals with factor sources; where only spend exists, Senseible provides a spend-based estimate labelled with wider uncertainty. How estimates appear in the BRSR is the listed company's decision.

Sources: SEBI circular on assurance or assessment and value chain disclosures, 28 March 2025, SEBI circular on BRSR Core and value chain disclosures, 12 July 2023, GHG Protocol Scope 3 Standard (2011), Chapter 7, collecting data

Last reviewed 2026-10-18. SEBI revises value chain rules often and the format gives no explicit guidance on marking estimates; recheck the latest circular before each BRSR season.