Sustainability Report Applicability

Currently, Sustainability Reporting are applicable to Top 1000 Listed Companies (by market capitalisation).

The Govt. of India has constituted a Committee on Business Responsibility Reporting under the chairmanship of Mr. Gyaneshwar Kumar Singh, Joint Secretary, MCA.

The Committee has issued their report to the Govt. on 8th May, 2020 after a detailed research.

Here, you can look some excerpts:

1. With regard to listed entities, reporting may be done by top 1000 listed companies (by market capitalisation) as applicable presently, or as prescribed by SEBI. The reporting requirement may be extended by MCA to unlisted companies above specified thresholds of turnover and/or paid-up capital. Further, the Committee recommends that smaller unlisted companies below this threshold may, to begin with, adopt a lite version of the format, on a voluntary basis.

2. The Committee recommends that the BRSR be integrated with the MCA21 portal. This would ensure that all information already filed on the MCA21 portal by companies would be automatically filled while filing the BRSR.

3. Notwithstanding the fact that it is desirable to extend the scope of applicability of responsibility and sustainability disclosures to all businesses, it is important to ensure preparedness of businesses for such disclosures. The larger, listed entities have already been making such disclosures driven by their investors and by law. The export-based companies have also been making these disclosures to their buyers in other countries where this is already mandated. They have also had to share this information with standard setting bodies and other multi-stakeholder platforms of which they are members. However, the level of preparedness of small-sized companies, informal, and home-based businesses is likely to be low or nonexistent. The Committee therefore recognises the importance of staggered applicability to smaller companies, perhaps beginning with disclosure on a voluntary basis. The scope and applicability to Limited Liability Partnerships (LLPs) may also be considered in terms of size for staggering. As for businesses in the informal sector, it is hoped that as formal businesses become more mindful of their value chain partners, considerations of business responsibility and sustainability shall also become operational there.

4. To standardise and deduplicate reporting requirements, the formats have been developed in a manner that makes it easy to be integrated with filings made on the MCA21 Portal. The information already filed on the MCA21 Portal by companies would get prefilled where applicable in the proposed formats. Further, where there are multiple options, dropdown menus for appropriate selection have been proposed.

5. The reporting requirement may be extended by MCA to unlisted companies above a specified threshold of turnover or paid-up capital. Further, the Committee recommends that smaller unlisted companies below this threshold may, to begin with, adopt a Lite version of the format, on a voluntary basis.

6. BRS Reporting be integrated with reporting under the Companies Act, 2013 on the MCA21portal, preferably in XBRL formats.


This blog is authored by Company Secretary Ronak Gupta. He is author of many blogs and runs many websites and youtube channels. His work is dedicated to corporate laws, legal, secretarial, professional services and also in strategy formulations for corporates. Mail him at: csronakgupta23@gmail.com or call at :9910226715

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