THE POLICY EDGE
Expert Commentary

6 October 2026

Communication Beyond CSR Spending: Should BRSR Reach More Companies?

India tracks corporate spending on social initiatives at scale, while mandatory sustainability reporting covers only the top 1,000 listed companies

Sadhna Swayamsidha is an Assistant Professor at the Global Institute of Business Studies, Bengaluru. Sanchar Sarkar is an Assistant Professor at IIM Kozhikode. 

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In FY 2024–25, 29,546 companies reported CSR spending of ₹40,794 crore across 72,233 projects. These figures show the scale of India’s statutory corporate social responsibility regime. They communicate far less about how the companies themselves use resources, treat workers or manage environmental risks.

India’s corporate reporting framework asks two related questions. Under the CSR mandate, eligible companies report what they spend on social initiatives and the activities they support. Under SEBI’s Business Responsibility and Sustainability Report (BRSR) framework, the largest listed companies also disclose their environmental, social and governance performance. A company may report under both frameworks, but CSR expenditure is only one part of its wider sustainability picture. Funding a water project, for example, does not show how the company manages water in its own operations.

How the Two Reporting Tracks Developed

Before statutory CSR, the Ministry of Corporate Affairs issued voluntary CSR guidelines in 2009. Its 2011 National Voluntary Guidelines broadened the discussion to the social, environmental and economic responsibilities of business. Neither imposed the CSR expenditure obligation that subsequently came through the Companies Act.

The reporting tracks then developed through different regulators. Section 135 of the Companies Act established the CSR framework for eligible companies. Separately, SEBI required the top 100 listed companies to publish Business Responsibility Reports from 2012. It later introduced BRSR, which became mandatory for the top 1,000 listed companies by market capitalization from FY 2022–23.

BRSR seeks comparable information on how businesses operate. SEBI has also phased in third-party assurance or assessment for selected BRSR Core indicators, beginning with the top 150 listed companies in FY 2023–24 and extending to the top 1,000 by FY 2026–27. This requirement concerns those selected indicators, rather than third-party verification of every disclosure in the report.

What the Spending Figures Cannot Tell Us

CSR disclosures provide visibility into expenditure and the projects companies support. Spending totals alone cannot establish whether those projects achieved measurable social outcomes. Nor can they establish whether the companies funding them have reduced emissions, improved resource efficiency or strengthened practices within their own operations.

The difference in reach therefore matters. The 29,546 companies in the CSR figures include companies that may also be subject to BRSR. But mandatory BRSR covers only the top 1,000 listed companies. CSR data consequently provides a view of social spending across a much wider corporate population than the population covered by mandatory BRSR disclosures.

The Next Layer of Corporate Accountability

Section 135 need not be judged against a function it was not designed to perform. The question is what level of operational sustainability information should be available for companies beyond the current BRSR requirement.

A proportionate disclosure framework could begin with a limited set of indicators, such as energy and water use, waste, workforce conditions and governance practices. Its scope and thresholds would need to reflect company size, reporting capacity and disclosures already required under other laws. The aim would be to make basic operational performance visible without imposing the full BRSR framework on every company that has a CSR obligation.

India has built substantial visibility into what companies spend on social initiatives. The next step is to decide how to extend visibility into how a wider set of companies operates.


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