Can a SEBI-registered ESG rating provider act as the reviewer for an ESG bond?
Yes. SEBI lets a registered ESG rating provider act as independent reviewer for social, sustainability and sustainability-linked bonds if it meets the independence, conflict-free fee and expertise conditions. But for any client group an ESG rater may offer either ESG ratings or green debt certification, or audit and assurance, not both.
Who may be appointed
SEBI's June 2025 ESG debt framework says that, apart from other eligible reviewers, an ESG rating provider registered with SEBI may be appointed as the independent third-party reviewer, provided it is independent of the issuer and its management, paid without conflicts of interest and has expertise in assessing ESG debt securities. The February 2026 green debt circular was addressed to registered ESG rating providers too.
The client-group split
SEBI's master circular for ESG rating providers treats a client and all its group companies as one client group. For any client group, an ESG rating provider may offer only one of two product categories: ESG ratings or certification of green debt securities, or audit of financial statements or assurance of sustainability disclosures. Switching between the two needs a one-year cooling period.
Other conflict rules for ESG raters
- Analysts may not take part in marketing, business development or fee negotiations with the issuer being rated.
- Employees in the rating process and their dependants may not own shares of the rated issuer.
- Ratings are reviewed promptly if a rating employee joins the rated issuer.
- A provider must use either an issuer-pays or a subscriber-pays model, never a mix.
Practical point
If your BRSR Core assurance provider is also an ESG rating provider, check which side of the split it sits on for your group before asking it to review a bond.
What Senseible does here
Senseible is not a SEBI-registered ESG rating provider or bond reviewer. It produces bill-based energy and emissions records that companies and their reviewers can examine.
- Green bond reviewer rules from 2026
- ESG rating products SEBI requires
- Issuer-pays vs subscriber-pays ESG ratings
Sources: SEBI circular, Framework for ESG Debt Securities (other than green debt securities), 5 June 2025, SEBI Master Circular for ESG Rating Providers, 11 July 2025, SEBI circular, Revised norms for appointment of an independent third-party reviewer/certifier for green debt security, 27 February 2026
Last reviewed 2026-10-23.