# Which definition of wages does the BRSR use for gross wages paid to women?

Canonical: https://senseible.earth/answers/brsr-wages-remuneration-salary-definitions

The Business Responsibility and Sustainability Report (BRSR) guidance does not pick one. It prints three definitions: remuneration under the Companies Act, 2013, salary under the Income-tax Act, 1961, and wages under the Code on Wages, 2019. The guidance does not say which to use. Pick one, say which in a remark, and keep it the same each year.

## What the table asks for

- Median remuneration, salary or wages, male and female, for the Board of Directors, key managerial personnel, employees other than those two groups, and workers.
- Gross wages paid to females as a percentage of total wages paid by the entity, for the current and previous financial year.

## The three definitions the Securities and Exchange Board of India (SEBI) guidance prints

- Remuneration: section 2(78) of the Companies Act, 2013, any money or its equivalent given or passed to any person for services rendered, including perquisites as defined under the Income-tax Act, 1961.
- Salary: under the Income-tax Act, 1961, it includes wages, any annuity or pension, any gratuity, fees, commissions, perquisites or profits in lieu of or in addition to salary or wages, any advance of salary, and two items tied to a recognised provident fund.
- Wages: section 2(y) of the Code on Wages, 2019, all remuneration which would be payable under the terms of employment, and includes basic pay, dearness allowance and retaining allowance.

## What the narrower wages definition leaves out, and the proviso that brings some back

- It does not include a bonus payable under any law that is not part of the remuneration under the terms of employment, house rent allowance, overtime allowances, any commission payable to the employee, or gratuity payable on termination.
- It also leaves out employer contributions to a pension or provident fund and conveyance allowance.
- A proviso says that if the left-out payments in clauses (a) to (i) of the Code exceed one-half of all remuneration, or another per cent notified by the Central Government, the excess is deemed remuneration and added to wages.
- A second proviso says that for equal wages to all genders and for payment of wages, conveyance allowance, house rent allowance, pay under an award or settlement and overtime allowances (clauses d, f, g and h) are counted in computing wages.

## Why it matters for the percentage

Gross wages to women as a share of total wages moves with the definition. Using the narrow wages definition for women and a broad one for the total, or the reverse, gives a number that cannot be compared. Several of the left-out items, such as overtime and house rent allowance, are counted under the second proviso for equal wages and payment of wages, so check which items your definition includes before you split men and women. The guidance does not say which definition to use. Pick one, apply it to both numbers, say which in a remark, and keep it the same each year (our advice, not a SEBI rule).

## Example: the share of wages paid to women

- Total wages paid in the year: rupees (Rs) 6.0 crore. Paid to women: Rs 1.2 crore
- Gross wages paid to females as % of total wages = 1.2 / 6.0 x 100 = 20.0%
- Mismatch: if women's wages are counted with overtime (Rs 1.3 crore) but total wages are counted without it (Rs 6.0 crore), the share reads 1.3 / 6.0 x 100 = 21.7%, against 20.0% when one rule is used for both (1.3 / 6.5 x 100 = 20.0%, with total wages Rs 6.5 crore once overtime is counted for everyone)

The amounts are an example.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not hold payroll, so wage figures stay with your accounts team.

- [BRSR minimum wage table for workers](https://senseible.earth/answers/brsr-minimum-wage-table-equal-or-more-than)
- [BRSR wages by town type](https://senseible.earth/answers/brsr-wages-paid-in-rural-semi-urban-urban-metropolitan)
- [BRSR Core: the nine attributes and KPIs](https://senseible.earth/answers/brsr-core-nine-attributes-explained)
- [BRSR and BRSR Core in plain words](https://senseible.earth/brsr-reporting)

Sources: [SEBI, master circular for LODR compliance, 11 July 2023, BRSR guidance note and formats](https://www.sebi.gov.in/sebi_data/attachdocs/jul-2023/1689087475880.pdf), [SEBI, Updated BRSR format, Annexure II to circular of 12 July 2023](https://www.sebi.gov.in/sebi_data/commondocs/jul-2023/Annexure_II-Updated-BRSR_p.PDF)

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.
