From FY2024–25, India's top 250 listed companies must obtain independent third-party assurance on their ESG disclosures under BRSR Core. Self-reported plantation numbers are no longer sufficient. Here is what changed, what it means, and what you need.
On 12 July 2023, SEBI introduced BRSR Core — a subset of 49 Key Performance Indicators within the Business Responsibility and Sustainability Report framework that listed companies must now subject to mandatory independent assurance. These KPIs cover greenhouse gas emissions, water consumption, waste generation, workforce safety, gender diversity and governance structures.
For the first time, companies can no longer rely on self-reported sustainability claims. An independent assessor — either their statutory auditor or a SEBI-accredited assurance provider — must validate the data.
Rollout timeline
FY 2023–24: Top 150 listed companies must report and assure BRSR Core KPIs
FY 2024–25: Extends to top 250 companies by market capitalisation
FY 2025–26: Extends to top 500 companies
FY 2026–27: All top 1,000 listed companies
Many Indian corporations report tree plantation under their CSR or ESG disclosures. Until now, this typically meant reporting a number: "We planted 50,000 trees." BRSR Core changes the question. The independent assurer will ask for the data behind the claim — location coordinates, survival verification, care records, and if carbon credits are being claimed, survival-verified sequestration figures.
A plantation report that says "50,000 trees planted at Site X on Date Y" without survival data, GPS coordinates, or post-plantation monitoring records is no longer sufficient for companies within scope.
In March 2025, SEBI went further: it issued a circular requiring listed entities to also report green credits generated or procured — both directly and through their top 10 value chain partners. This directly connects plantation activity to the Green Credit Programme framework.
Companies that have been reporting tree plantation numbers without underlying survival data now face a material compliance risk. If an independent assurer cannot verify that trees are alive — with GPS locations, health records and care logs — the disclosure cannot be independently assured. For companies in the top 250 from FY2024–25, that assurance is no longer optional.
The shift is straightforward: plantation CSR now requires the same rigour as financial reporting. The data must exist. It must be verifiable. And someone independent must confirm it.
SEBI Circular: BRSR Core introduction — 12 July 2023
SEBI Master Circular on LODR Regulations — 11 November 2024, amended 28 March 2025
KPMG First Notes: SEBI proposes amendments to BRSR Core assurance — June 2024
Datatracks: 'SEBI Mandates ESG Reporting for Top 1000 Listed Companies' — October 2025
Bilancia Consulting: 'ESG Compliance in 2025: Key Regulatory Changes' — November 2025