Strengthening BRSR for climate transition plan disclosures in India

This briefing note builds on two previous reports by the Institute for Energy Economics and Financial Analysis (IEEFA). The first report, titled Bridging the net-zero gap, is an empirical assessment of transition plan disclosures by 33 Indian companies across six high-emitting sectors. The second, titled Corporate climate transition planning and disclosures in India, is a comparative mapping of Business Responsibility and Sustainability Reporting (BRSR) and the International Sustainability Standards Board’s (ISSB) International Financial Reporting Standards (IFRS) S2 Climate-related Disclosures standard against IEEFA’s transition plan assessment framework. Both reports concluded that the BRSR provides a strong base for sustainability disclosures but does not, in its current form, support the forward-looking, financially integrated transition plan information that capital providers such as lenders and investors increasingly require.

This note translates those findings into a concrete, two-phase pathway that the Securities and Exchange Board of India (SEBI) and Indian companies can use to embed transition planning within BRSR. The objective is not to create a parallel disclosure regime, but to make BRSR fit for the purpose by reorganising existing disclosures, supplementing them with a small set of priority metrics, and sequencing the introduction of new requirements in a manner sensitive to corporate sector readiness.