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

Canonical: https://senseible.earth/answers/brsr-value-chain-estimate-when-supplier-silent

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

- The partner list with each partner's share of purchases or sales.
- Requests sent and follow-up dates.
- Responses as received, with the factor sources the partner gave.
- For each estimate: method, inputs, source and date.

## Worked example: coverage and one estimate

- Annual purchases: Rs 3,000 crore; suppliers at 2% or more: 10, together Rs 2,160 crore (72%)
- 7 responded, covering Rs 1,500 crore: 50% of purchases, and 1,500 / 2,160 = 69% of the partner group
- Silent supplier: Rs 90 crore of your purchases (3%)
- Two responding suppliers of similar castings report 1.8 and 2.2 t CO2 per crore of revenue; average 2.0 (illustrative)
- Estimate attributable to your purchases: 90 x 2.0 = 180 t CO2, shown separately as a peer-intensity 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.

- [The supplier side of a value chain request](https://senseible.earth/answers/brsr-value-chain-data-request-msme-supplier)
- [Value chain assurance timeline](https://senseible.earth/answers/brsr-core-value-chain-assurance-timeline)
- [How to fill gaps in Scope 3 data](https://senseible.earth/answers/how-to-fill-gaps-in-scope-3-data)
- [Supplier data collection playbook](https://senseible.earth/climate-intelligence/supplier-emissions-data-collection-playbook-msme)

Sources: [SEBI circular on assurance or assessment and value chain disclosures, 28 March 2025](https://www.sebi.gov.in/legal/circulars/mar-2025/measures-to-facilitate-ease-of-doing-business-with-respect-to-framework-for-assurance-or-assessment-esg-disclosures-for-value-chain-and-introduction-of-voluntary-disclosure-on-green-credits_93102.html), [SEBI circular on BRSR Core and value chain disclosures, 12 July 2023](https://www.sebi.gov.in/sebi_data/attachdocs/jul-2023/1689087475880.pdf), [GHG Protocol Scope 3 Standard (2011), Chapter 7, collecting data](https://ghgprotocol.org/corporate-value-chain-scope-3-standard)

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.