For any Indian company listed at home and exposed to Europe — through EU customers, an EU listing, or a large enough EU subsidiary footprint — the question isn't whether to disclose Scope 3, it's how to satisfy two different rulebooks without running two separate reporting processes.
BRSR and BRSR Core, in brief
SEBI's Business Responsibility and Sustainability Reporting (BRSR) framework applies to India's largest listed companies by market capitalisation, requiring disclosure across environmental, social, and governance principles. BRSR Core is a tighter subset of that framework — a defined set of key performance indicators, including GHG emissions intensity, that carries a phased assurance requirement (independent verification, not just self-disclosure), starting with the largest companies and extending down the market-cap list over successive years.
BRSR's emissions disclosure is principle-based and India-specific in its KPI set, but it draws on the same underlying GHG Protocol categorisation that CSRD and the GHG Protocol Corporate Standard use — so the measurement work underneath is largely shared, even where the disclosure format differs.
CSRD and ESRS, in brief
The EU's Corporate Sustainability Reporting Directive (CSRD), implemented through the European Sustainability Reporting Standards (ESRS), applies to companies meeting EU size and activity thresholds — including, critically, large non-EU companies with a sufficiently large EU subsidiary or branch presence. ESRS E1 (Climate Change) requires Scope 1, 2, and 3 emissions disclosure, but layers on a concept BRSR doesn't formally require in the same way: double materiality — reporting not just how climate affects the company's own risk, but how the company's activities affect the climate and environment, assessed and disclosed together.
CSRD's Scope 3 requirement also comes with an explicit value chain estimation obligation: where primary data isn't available, companies must still produce and disclose an estimate, using industry averages or other proxies, and disclose the methodology — self-estimation is not an acceptable reason to omit a material category.
Where the two genuinely diverge
- Materiality logic. CSRD's double materiality assessment is more demanding than BRSR's principle-based structure — it requires justifying, category by category, both financial and impact materiality, with documented reasoning for what's excluded.
- Assurance timeline and threshold. BRSR Core's assurance requirement is phased by market capitalisation over a period of years; CSRD's assurance requirement (starting at limited assurance, moving toward reasonable assurance over time) applies on a different in-scope-company timeline tied to company size bands, not market cap rank.
- Category-level granularity. ESRS E1's disclosure tables are more prescriptive about categorising and quantifying each of the fifteen GHG Protocol Scope 3 categories individually; BRSR Core's current KPI set is comparatively higher-level.
- Who's actually in scope. BRSR applies by Indian listing status and market cap; CSRD can pull in an Indian company with no EU listing at all, purely through the size of its EU-based operations — a scope trigger many Indian groups don't realise applies to them until an EU subsidiary crosses the threshold.
The practical approach for dual-exposed companies
Building one underlying GHG inventory — measured at GHG Protocol category level, with documented methodology and data quality per category — and then mapping that single source of truth into both BRSR Core's KPI format and ESRS E1's disclosure tables is significantly more efficient than running two parallel measurement exercises. The double materiality assessment and the assurance workflow still need to be built separately for each framework, but the underlying emissions data does not.