Corporate climate transition planning and disclosures in India

With climate transition planning becoming central to global sustainability reporting, a new assessment by the Institute for Energy Economics and Financial Analysis (IEEFA) compares India’s Business Responsibility and Sustainability Reporting (BRSR) framework with the International Sustainability Standards Board’s (ISSB) standards, highlighting key strengths and gaps. 

The analysis is based on IEEFA’s climate transition plan framework that is informed by a review of 18 international frameworks, as well as consultations with regulators, companies, investors and research bodies. IEEFA’s framework is grounded in the Transition Plan Taskforce (TPT) framework, which IEEFA identifies as a robust reference for transition plan disclosures. 

The framework aims to evaluate the quality of climate-related disclosures, the essential elements of transition plans, and how that translates to progress by corporates on climate transition outcomes. 

The assessment focuses on whether disclosures are decision-useful for investors seeking to assess transition risk, capital allocation plans and long-term resilience.  

IEEFA’s framework comprises five major categories: Foundation, Governance, Implementation Strategy, Engagement Strategy and Transparency, but the analysis covers only the first four, as the Transparency category reflects the results of companies’ actions, while the analysis is limited to understanding disclosure regulations pertaining to the transition planning process.

The Foundation category sets a company’s strategic ambitions and identifies the transition levers it will deploy to achieve its goals, as well as the scenario analysis it will undertake to test the resilience of its responses to climate-related risks and opportunities. ISSB sets out detailed requirements covering key metrics needed to report on an entity’s overall greenhouse gas and climate resilience targets, and disclosure of its transition plan. Disclosure of scenario analysis is also required. However, under BRSR, overall targets and identified responses are covered more broadly. Scenario analysis is not required under BRSR. 

The Governance category focuses on oversight and accountability mechanisms that ensure a transition plan is managed smoothly. ISSB provides detailed guidance on these governance-related targets, requiring companies to disclose how governance mechanisms support climate ambitions. By contrast, BRSR focuses on broader ESG principles rather than climate-specific governance measures. 

Implementation strategy examines how a company operationalises its transition plan and ensures that ambitions are translated into credible action. ISSB requires detailed disclosure of expected impacts on the financial position, R&D priorities, investments and operational cash flows. On the other hand, BRSR only asks companies to report R&D and capital expenditure that generate environmental or social benefits. 

Engagement strategy assesses how companies work with stakeholders to deliver their transition plans. It covers engagement with the value chain, industry and policymakers, and workforce and communities. While ISSB focuses on narrative disclosure of engagement, BRSR provides specific, measurable indicators for stakeholder interaction, particularly for social and community impact. 

From a transition planning perspective, ISSB provides a clearer linkage between overall GHG targets, alignment with global or national sectoral pathways, identified risks and opportunities, selected transition levers, and the resilience of these risks and potential responses. BRSR, while covering several foundational ESG indicators and offering deeper insights into social impact and community engagement, does not provide the same level of granularity required to evaluate a company’s climate-transition readiness.

A key differentiating factor between the two standards is a guidance document on climate transition planning that ISSB released in 2025, which enables companies to report transition plan–specific information under current ISSB standards. The guidance is based on the TPT framework. There is no similar guidance on climate-related disclosures as part of BRSR. 

As companies set net-zero targets, the credibility and clarity of their transition strategies have become essential. Clear and well-structured transition plans can help translate climate ambition from aspiration to implementation.

Overall, however, IEEFA’s mapping exercise highlights that neither BRSR nor ISSB alone offers a comprehensive view of a company’s transition plan. IEEFA’s framework positions transition planning as a unified exercise for corporates and highlights ways to make existing sustainability standards more consistent.