BRSR and ESG Disclosures Assurance Services

Expanding Mandate for ESG Disclosures

May 10, 2021

SEBI/HO/CFD/CMD2/P/CIR/2021/562

SEBI mandates Business Responsibility and Sustainability Reporting (BRSR) framework (Regulation 34(2)(f) of SEBI LODR) for Top 1000 listed entities.

July 12, 2023

SEBI/HO/CFD/CFDSEC-2/P/CIR/2023/122

Introduced “BRSR Core” subset of 9 ESG attributes and mandated reasonable assurance for top listed entities in a phased manner. Recognizing that a company’s impact extends beyond its own operations, this circular also introduced Value Chain Reporting.

December 20, 2024

SEBI/HO/CFD/CFDPoD-1/P/CIR/2024/177

Issued the Industry Standards developed by the Industry Standards Forum (ISF) comprising ASSOCHAM, FICCI, and CII, and aim to facilitate the standardisation and ease of implementation of BRSR Core disclosures.

March 28, 2025

SEBI/HO/CFD/CFDPoD-1/P/CIR/2025/42

Deferred Value Chain disclosures and assurance by one year (now applicable from FY
2025-26). Introduced a leadership indicator for Green Credits under Principle 6.

Enhancing Disclosure Integrity Through Strategic Rotation

Mitigating Bias with Professional Skepticism: Periodic rotation of your assurance provider after 1–2 cycles introduces a fresh perspective of objective oversight as per ISAE 3000 (Revised) and other leading standards for assurance.
Systematic Gap Identification: This rotation allows for the systematic identification of hidden disclosure gaps and mitigates confirmatory bias, ensuring your reports withstand deep regulatory scrutiny.
De-risking and Governance: Implementing a rotation strategy every 1–2 cycles eliminates familiarity bias and ensures the highest level of data integrity.
Strengthening Investor Confidence: Demonstrating a commitment to rigorous governance through rotation strengthens investor confidence in your BRSR disclosures by ensuring independent, third-party verification remains truly objective.

BRSR Core Attributes

Greenhouse Gas (GHG) Emission Footprint
Energy Footprint
Water Footprint
Embracing Circularity (Waste Management)

Enhancing Employee Well-being & Safety
Enabling Gender Diversity in Business
Enabling Inclusive Development

Fairness in Engaging with Customers & Suppliers
Openness of Business

Compliance Timelines: For Top 1000 And Voluntary By All

While SEBI mandates specific reporting for the top listed entities by market capitalization, SEBI’s LODR (Regulation 34(2)(f)) recommends that all companies disclose their ESG practices through the BRSR framework to meet growing customer and investor requirements.

Key Timelines in India	FY 23-24	FY 24-25	FY 25-26	FY 26-27	FY 27-28	FY 28-29
BRSR MANDATE	Top 1000	Top 1000	Top 1000	Top 1000	Top 1000	Top 1000
BRSR CORE MANDATE	Top 150	Top 250	Top 500	Top 1000	Top 1000	Top 1000
BRSR CORE REASONABLE ASSURANCE/ASSESSMENT	Top 150	Top 250	Top 500	Top 1000	Top 1000	Top 1000
BRSR VALUE CHAIN DISCLOSURE	–	–	Top 250	Top 500	Top 1000	Top 1000
BRSR VALUE CHAIN DISCLOSURES’ LIMITED ASSURANCE/ASSESSMEN	–	–	Voluntary	Mandatory	Mandatory	Mandatory
SEBI RECOMMENDATION FOR BRSR	–	–	More Companies	More Companies	More Companies	More Companies

NGRBC, BRSR And JointValues’ Assurance Approach

We meet the criteria of SEBI Circular/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023 and subsequent guidelines.

Clause 5.1 – “The Board of the listed entity shall ensure that the assurance provider of the BRSR Core has the necessary expertise, for undertaking reasonable assurance.”

JointValues mitigate Board’s responsibility by engaging a team of ESG domain specialists, including BEE-certified Energy Auditors and ISO 14064 certified GHG Verifiers, for Reasonable Assurance against nine core attributes of BRSR and Sustainability Report as per GRI and IFRS-ISSB standards.

Clause 5.2 – “The listed entity shall ensure that there is no conflict of interest with the assurance provider appointed for assuring the BRSR Core. For instance, it shall be ensured that the assurance provider or any of its associates do not sell its products or provide any non-audit / non-assurance related service including consulting services, to the listed entity or its group entities.“

We satisfy clause 5.2 by maintaining an “Assurance-Only” focus for audit clients in a given financial year. Our practitioners ensure no conflict of interest while verifying historical data and validating forward looking statements like climate disclosures. We conduct assurance in accordance with ISAE 3000 (Revised) and the latest ISSA.

Proven Expertise

Assurance by JointValues meet Global Expectations and Regulatory Scrutiny

Investor Trust: Provides a “stamp of confidence” for global investors and ESG rating agencies such as S&P Global, MSCI, EcoVadis, ISS, and FTSE Russell.
Regulatory De-risking: Ensures alignment with SEBI’s BRSR Core mandates and NGRBC principles, shielding the company from “greenwashing” risks.
Operational Excellence: Identifies gaps in data collection, improving internal reporting systems and overall data integrity.

We have successfully conducted Reasonable Assurance engagements for the BRSR Core for major public and private sector companies, including Bank of India (BOI), Mazagon Dock Shipbuilders Limited (MDL), Coal India Limited (CIL), NLC India Limited (NLCIL), Indian Railway Finance Corporation (IRFC), and NIIT Learning Systems Limited.

Recommended 9+3 Model For Assurance

JointValues proposes a semi-annual data collection and assurance approach rather than waiting for the year-end deadline. This approach is strategic, aiding in de-risking annual compliance by enabling the early identification of data gaps and control weaknesses before the final report is due.

MID-YEAR SUBMISSION (Q1-Q2-Q3 DATA)

Company submits the data and draft report for 3 Quarters as per the criteria for reporting (subject matter). In case of the BRSR, as per Annexure 17A of the SEBI Master Circular dated 11 Nov 2024.

ROUND 1 ASSURANCE (Q3-Q4 PROCEDURE)

JointValues conducts the 1st round of assurance procedures, focusing on testing the design and operational effectiveness of controls and the accuracy of the submitted mid-year data.

FULL YEAR SUBMISSION (DATA AND DISCLOSURES – Q1, Q2, Q3, Q4)

Company submits its print ready disclosure/report for the full reporting period to JointValues.

ROUND 2 ASSURANCE (Q1 OF SUBSEQUENT FY)

JointValues executes the final round of assurance procedures, leading to the issuance of the formal opinion on the full-year data and report.

Alternatively, as a conventional approach, comprehensive review and assurance process is conducted entirely after the closure of the financial year.

Assurance Team Structure

To ensure no conflict of interest, maintain quality control, and adhere to ISAE 3000 standard, our engagement team is structured across three distinct layers:

Execution & Verification: Assurance Team Members perform the actual fieldwork, data verification, and documentation. They are the primary point of contact for data collection from the Company.
Oversight & Control: The Internal Quality Control (IQC) Team applies an internal maker-checker system (as required by ISAE 3000). They review the work of Layer 1 to ensure independence and quality across the engagement before it reaches the signatory.
Final Authority & Sign-Off: The Lead Assurer & Signatory provides final oversight on ethics, quality, and issues the official assurance opinion. They bear the ultimate responsibility for the assurance statement.

Our Alignment With Ethics And International Quality Standards

Ethical Requirements

JointValues’s Code of Conduct aligns with the best practices and the International Code of Ethics (ICE) for Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants (IESBA). This ensures our team remains objective and unbiased.

Quality Management

JointValues adhere to quality controls in line with the International Standards on Quality Management (ISQM). This ensures a high-quality, systematic engagement where every output is vetted before release.

Assurance Methodology: ISAE 3000 (Revised)

Phase 1: Planning and Risk Assessment

Materiality Assessment

We assess the appropriateness of various assumptions, estimations, and materialitythresholds used by the Company for data analysis. We identify which quantitative or qualitative misstatements could actually influence the decisions of the Report’s intended users (investors, regulators).

Risk Identification

We assess the risk of material misstatement due to errors (unintentional mistakes) or fraud(intentional manipulation) in the Company’s information system and control environment.

Control Design Review

We assess the internal control mechanisms for collecting, collating, and reporting thesubject matter data, as per the SEBI Circular for BRSR Core. This helps us determine if your systems are capable of producing reliable data.

Phase 2: Evidence Gathering and Testing (Execution)

Interactions

Detailed interactions with relevant personnel responsible for Sustainability, ESG, HR, EHS, and theirteams through virtual and physical meetings to understand the process flow and data lineage.

Analytical Procedures

Performing analytical procedures to analyze trends in the historical data (e.g., comparing Year-on-Year energy consumption) and ascertain the reasonableness of the data reported in the current year.

Substantive Testing (Vouching)

Vouching underlying source documents (e.g., electricity bills, fuel invoices, wastemanifests, accident registers, statutory returns) against the reported data. This includes assessing records and performing testing, including the recalculation of sample data to verify formula accuracy.

Physical Verification

On-site visits to a sample of [Number] locations to validate physical assets (e.g., verifying theexistence of a treatment plant), operational controls, and raw data generation processes.

Phase 3: Finalising Assurance Opinion and Reporting

Draft Assurance

We issue a Draft Assurance Statement and a Management Report. The Management Report is avalue-add document detailing findings, gap analysis, and recommendations for improvement.

Final Opinion

The formal, signed Independent Assurance Opinion is issued after management acceptance isreviewed on the draft.

Report to Management (Recommendatory Memorandum)

This is contingent upon whether any finding is withinthe material threshold for the assurance period but may pose a risk in the future, or if a modified or qualified opinion is required. It serves as a tool for continuous improvement.

Assurance Specialists

JointValues integrates diverse technical specializations to address core ESG attributes of BRSR and Sustainability Reports.

ESG Domain Specialists: Experts who partner with clients to translate the nine NGRBC Principles into measurable, reportable performance.
Experienced Assurance Professionals: Practitioners specialized in ISAE 3000 (Revised) and AA1000 AS standards to deliver a high-integrity “stamp of confidence”.
Financial Audit & Governance Specialists: Senior advisors with deep expertise in financial indicators and corporate governance, ensuring fiduciary alignment for the Board.
Environmental Verifiers: ISO 14064 certified Lead Verifiers for GHG footprints and BEE certified Energy Auditors for technical energy footprint verification.
IT & Digital Governance Experts: Specialists in data security and privacy to verify indicators related to data protection and potential data breach risks.