The architectural design of the world’s future sustainability reporting landscape is currently being drafted in two primary hubs: London and Brussels. In London, the United Kingdom government has moved forward with public consultations regarding the adoption of the International Sustainability Standards Board (ISSB) standards—specifically IFRS S1 and S2—through a proposed UK Sustainability Reporting Standards framework. Meanwhile, in Brussels, the European Commission is refining its European Sustainability Reporting Standards (ESRS). This refinement follows a significant "Omnibus simplification package" that saw the removal of 61 percent of data points to streamline requirements for European firms.
As these two Western powers work toward a narrative of convergence and harmonization, the ISSB is increasingly positioned as the "global baseline." This connective tissue of interoperability aims to create a seamless language for Environmental, Social, and Governance (ESG) data. However, as this multi-billion-dollar reporting infrastructure takes shape, a significant structural blind spot has emerged. India’s Business Responsibility and Sustainability Reporting (BRSR) framework, which is already mandatory for the nation’s top 1,000 listed companies, remains largely excluded from the bilateral dialogues between the UK and the EU. This omission is not merely a geographic oversight; it represents a fundamental gap in the "global" ambitions of current sustainability standards.
The Magnitude of India’s BRSR Framework
India’s BRSR framework is not a nascent proposal or a voluntary guideline; it is a functioning, mandatory regulatory requirement. Since the 2022-23 financial year, the top 1,000 listed entities by market capitalization in India—representing approximately 70 percent of the country’s total market value—have been required to file these disclosures.
The framework is technically sophisticated, requiring machine-readable XBRL (eXtensible Business Reporting Language) filings, which facilitates easier data aggregation and analysis for investors. Furthermore, the Securities and Exchange Board of India (SEBI) has introduced "BRSR Core," a subset of high-priority indicators that require third-party reasonable assurance. This assurance mandate is on a structured expansion path: beginning with the top 250 companies in FY 2024-25, it will scale to include the top 1,000 companies by FY 2026-27. Despite this rigorous, state-backed implementation, BRSR is rarely mentioned in the high-level interoperability discussions held by the ISSB or EFRAG (the European Financial Reporting Advisory Group).
Solving the Social Disclosure Dilemma
One of the most significant arguments for including India in the global conversation is that the BRSR has already operationalized disclosures that Western regulators are still debating in committees. The Indian framework is built upon the National Guidelines on Responsible Business Conduct (NGRBC), which treat social and community accountability as mandatory quantitative disclosures rather than optional "leadership" indicators.
This distinction is critical for global supply chains. India serves as a primary hub for industries such as textiles, pharmaceuticals, and IT services. The social risks inherent in these sectors—including contracted labor, factory safety, and informal employment—are precisely the categories that the EU’s ESRS S2 (Workers in the Value Chain) and the ISSB’s upcoming social disclosure frameworks are struggling to make practically workable.
While EFRAG’s simplified ESRS drafts, released in late 2025, acknowledge the ongoing difficulty of standardizing social metrics, India has already implemented a system that captures this data for one of the world’s most complex industrial economies. The BRSR provides a blueprint for measuring social impact in emerging markets that could offer vital lessons for the "global baseline" currently being sought by the ISSB.
A Chronology of Regulatory Evolution
The development of these frameworks reveals a stark contrast in regulatory philosophy. In the West, the path to standardization has often been reactive to political and industry pressure.
- May 2021: SEBI introduces the BRSR framework, replacing the older Business Responsibility Report (BRR).
- FY 2022-23: BRSR becomes mandatory for the top 1,000 listed Indian companies.
- March 2024: The US Securities and Exchange Commission (SEC) pauses its climate disclosure rule following intense litigation and political backlash.
- Late 2024: The EU implements the Omnibus simplification, significantly reducing the number of mandatory ESRS data points due to competitiveness concerns.
- March 2025: SEBI issues a revised BRSR circular. Unlike the Western "retreat" or "simplification" driven by lobbying, SEBI’s recalibration was based on data-driven pragmatism.
SEBI’s expert committee analyzed implementation data from the first two years of reporting. They identified that while value chain disclosures were necessary, the compliance burden for small and medium enterprises (SMEs) was too high. Consequently, they narrowed the definition of value chain partners to those accounting for 2 percent or more of transactions and deferred mandatory value chain reporting to FY 2025-26. This process represents "institutional learning"—a methodical adjustment of regulations based on field experience rather than political convenience.
The Risk of "Flying Blind" in Emerging Markets
For global institutional investors, the exclusion of BRSR from interoperability talks creates a practical data gap. Global portfolios have significant exposure to Indian equities, yet the reporting architecture being finalized in London and Brussels is designed almost exclusively for EU-listed or Western-centric companies.
In November 2024, the Financial Stability Board (FSB) released a progress report highlighting the difficulties emerging and developing economies face in implementing ISSB standards. Similarly, a 2025 report from the International Finance Corporation (IFC) titled Elevating ESG Reporting in Emerging Markets pointed to a growing tension between global standard ambitions and local disclosure realities.
If the BRSR—a framework that is already mandatory, machine-readable, and third-party assessed—is not integrated into the global interoperability map, investors will lack comparable ESG risk data for Indian allocations. This creates a fragmented market where "global" standards only apply to a specific subset of the world’s capital, leaving emerging market risks under-reported or misaligned.
Acknowledging the Limitations of BRSR
While the BRSR offers a robust model for emerging markets, it is not without its flaws. A joint study by the CFA Institute and the National Stock Exchange of India (NSE) identified persistent inconsistencies in data quality and a lack of standardization in reporting units among Indian firms.
Furthermore, the BRSR has yet to fully adopt the "financial materiality" architecture favored by the ISSB (which focuses on how sustainability impacts a company’s value) or the "double-materiality" depth of the ESRS (which looks at both financial impact and the company’s impact on the world). Because BRSR is anchored in Indian national guidelines, its direct comparability with international standards remains limited. However, proponents argue that these gaps are exactly why India should be at the negotiating table—to align these frameworks rather than letting them diverge further.
The Need for a Wider Table
The current trajectory of sustainability reporting suggests a "global" system that is, in reality, a reflection of Western priorities. The ESRS-ISSB interoperability work involved extensive bilateral engagement, but industry analysts have questioned the level of input received from emerging market regulators.
If the "global baseline" is built without the structural involvement of major emerging economies like India, Brazil, or Indonesia, the label "global" becomes a misnomer. A standard-setting process that excludes the perspectives of the regulators and issuers who manage the world’s most critical supply chains cannot claim to capture universal ESG risks.
The sustainability reporting landscape is at a crossroads. One path leads to a bifurcated system where Western standards and emerging market realities never quite meet. The other path requires London and Brussels to widen the table, acknowledging that the blueprints for transparency are being drawn not just in the Global North, but in the rapidly evolving markets of the South. As capital continues to flow into emerging markets, the conversation about who defines "responsible business" is long overdue for a more inclusive expansion.
