The Rules Got Easier. Your Obligation Didn't.

SEBI's ESG assurance regime expanded to the top 500 listed companies this year. In the same season, SEBI eased two adjacent parts of the same framework. Reading those as one signal is the mistake worth naming before it costs anyone an audit finding.

SEBI's BRSR Core reasonable-assurance requirement follows a fixed cohort schedule by market capitalisation, measured as at 31 March each year: the top 150 listed entities from FY2023-24, the top 250 from FY2024-25, the top 500 from FY2025-26, and the top 1,000 scheduled for FY2026-27. A company crossing into the top 500 this year has a live, present obligation - not a future one - to obtain reasonable assurance or an equivalent third-party assessment on nine ESG attributes.

That same company, doing its first pass of research on what's expected of it, will very quickly run into a different story: SEBI significantly eased the BRSR Core framework in March 2025.

Both things are true. They are not the same thing.

What actually changed in March 2025

SEBI's circular of 28 March 2025 (SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42) made two substantive changes, and it is worth being precise about which parts of the framework each one touches.

First, it replaced the framework's "Data & Assurance Approach" terminology with "Data & Assessment or Assurance Approach." Companies may now satisfy their obligation through third-party assessment - conducted to standards set by the Industry Standards Forum, a body of ASSOCHAM, CII and FICCI representatives working with SEBI - as an alternative to the more demanding reasonable assurance route.

Second, it eased the value-chain disclosure layer specifically. Reporting on upstream and downstream partners - those individually accounting for 2% or more of a company's purchases or sales by value, with the option to cap coverage at 75% of total value - moved from a comply-or-explain mandate to a voluntary basis, and the timeline for it shifted out to FY2025-26. Voluntary assessment or assurance for that value-chain layer was pushed further, to FY2026-27.

Both are real relaxations. Neither touches the base requirement.

What didn't change

The nine-attribute BRSR Core obligation - the entity's own reasonable assurance or assessment, on its own operations, on the cohort schedule set out above - remains mandatory. For a company newly inside the top-500 band this financial year, that obligation is due now, on the same terms it was due for the top-150 cohort two years earlier, minus only the option to substitute assessment for assurance.

The two things that got easier - the assurance/assessment choice, and the value-chain layer - are additions to the framework, not the framework's core. A company reading "SEBI eased BRSR Core" and concluding its own reporting burden has lightened is reading the relaxation of the newer, more contested layer as if it applied to the older, settled one.

Why this particular misreading is easy to make

What follows is inference, not something stated in the circular or in any source consulted: the companies most likely to make this error are exactly the ones for whom it matters most - those encountering BRSR Core obligations for the first time this year, precisely because they are new to the cohort. A company that has already been through two prior assurance cycles under the top-150 or top-250 schedules has direct experience of what the base nine-KPI requirement actually demands. A company crossing the threshold for the first time in FY2025-26 has no such experience, is doing its research under time pressure, and is reading news coverage that leads with "SEBI eases ESG rules" rather than with the cohort schedule that determines whether that easing applies to them at all.

The practical consequence isn't a paperwork error. It's a company that budgets three weeks for what its assurance provider needs three months to actually deliver, discovered only once the provider is on site and the nine attributes' underlying data - water figures, waste figures, wage figures - turn out not to have an owner.

What to check, specifically

Confirm cohort status against 31 March market capitalisation, not against a general sense of company size. Confirm which of the nine attributes actually require assurance versus assessment for your specific cohort year - the choice exists, but choosing requires knowing the base obligation is unmoved. And treat the value-chain and green-credit provisions as separate, optional items on their own timeline, not as evidence about the timeline for the core nine.

Source: SEBI Circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, dated 28 March 2025, read via a direct excerpt hosted by BSE and corroborated by two independent legal-update services quoting the same operative clauses. A claim that SEBI plans further relaxation before FY2026-27 was considered and could not be sourced to any SEBI announcement; it is not asserted.