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Value Chain Sustainability & SEBI Compliance

ESG Specialists

Ms Vedanshi Singh

Mr Vishal Kaushik

Mr Kaustav Dutta

Mr JS
Kamyotra

Ms Santosh Bhattacharya

Mr Satya Mishra

Mr Ayush Vadagama

From FY 2025–26, the top 250 listed companies are expected to begin ESG data collection across their upstream and downstream partners under the BRSR Core framework. Even companies outside the immediate SEBI mandate should act now—early preparation ensures competitive advantage, operational resilience, and future compliance readiness. 

At the same time, thousands of SMEs who supply or distribute to large companies must build their ESG capabilities. In fact, your ESG performance on BRSR Core indicators can open up opportunities to improve your business operations—leading to cost savings and higher profitability.

Here are some of the most common questions we receive from clients at JointValues:

1. What is SEBI’s mandate on supply chain sustainability reporting?

Starting FY 2025–26, the top 250 listed companies in India are expected to begin voluntary ESG data collection from their value chain (both upstream and downstream). By FY 2026–27, this will require assessment or assurance for BRSR Core disclosures relating to value chain partners, especially those contributing to 75% of the entity’s business value.

2. Is this requirement applicable to the full BRSR or just the BRSR Core?

This requirement applies only to the BRSR Core disclosures, which include 9 ESG attributes such as GHG emissions, water usage, employee welfare, safety, and governance metrics. Full BRSR disclosure by supply chain entities is not mandated.

3. What qualifies as the “value chain” under SEBI’s guidance?

SEBI defines the value chain for BRSR Core purposes based on materiality: partners (upstream and downstream) that contribute 2% or more of the total procurement or sales value and together cover at least 75% of the respective value.

4. Why is this important now if it’s not mandatory until FY 2026–27?

SEBI’s current phase is a grace period—meant to help companies:

  • Prepare their partners,
  • Establish reporting systems,
  • Avoid future non-compliance risks.

Delaying action could result in costly assurance failures and reputational risks once the mandate becomes binding.

5. What are the biggest challenges companies face with supply chain ESG reporting?

  • Low ESG readiness among MSME suppliers
  • Data availability gaps (e.g., no GHG, water, or waste records)
  • Lack of standard tools for intensity calculations
  • Difficulty in engaging partners for data collection or audits
  • Assurance complications if suppliers lack internal controls

6. How can JointValues support us in addressing these challenges?

JointValues offers an end-to-end solution that includes:

  • Supply chain mapping and segmentation
  • ESG data collection templates aligned with BRSR Core
  • Partner engagement & training (for suppliers and distributors)
  • Support for third-party assessment or assurance
  • Assistance in green credit disclosure (new leadership KPI)

7. Do suppliers need to report under full BRSR?

No. Suppliers are not required to submit full BRSR disclosures. They must only provide data related to the 9 BRSR Core attributes, in formats tailored for value chain data collection (e.g., “BRSR Lite”).

8. Is assurance mandatory for the value chain data?

From FY 2026–27, SEBI allows companies to choose between:

  • Third-party assurance, or Assessment

JointValues supports both pathways to ensure compliance, credibility, and cost-efficiency.

9. What is the role of green credits in the BRSR Core?

Green credits, introduced as a leadership indicator in FY 2024–25, can boost a company’s sustainability score. JointValues helps:

  • Integrate disclosures for both entity and value chain
  • Track green credit generation or purchase
  • Map them to BRSR KPIs

10. Does the downstream value chain include customers, especially for B2C companies?

Yes, downstream value chain reporting under BRSR Core may include distributors, dealers, franchisees, or institutional customers, particularly for B2C companies. However, the inclusion is based on materiality thresholds — specifically, downstream partners that contribute 2% or more to the company’s total sales value and collectively represent at least 75% of the downstream value chain.

It is important to note that SEBI does not mandate the inclusion of individual end-consumers. Instead, the focus is on business entities that are commercially significant and fall within the material scope of the company’s value chain.

11. Is it true that companies must report on their top 10 upstream and downstream partners?

No, the reference to “top 10 upstream and top 10 downstream entities” applies only to the Green Credit disclosures under Leadership Indicator 6.8 of Principle 6. It does not apply to general ESG value chain disclosures required under the BRSR Core.

12. How does BRSR Core value chain action create business value beyond compliance?

For large enterprises—especially export-oriented ones—engaging suppliers in ESG objectives leads to de-risking, improved brand resilience, and regulatory preparedness across jurisdictions. It strengthens governance and transparency in your extended operations.

13. Can supplier-level data improve Scope 3 emission accuracy? 

Yes. Actual GHG and resource use data from suppliers can be up to 30% lower than estimated emissions derived from spend-based methods. Collecting real data not only improves climate disclosures but supports carbon mitigation planning.

14. How can SMEs benefit from participating in this ecosystem?

SMEs who align with their buyers’ ESG expectations not only gain long-term supply relationships but also enhance their credibility in global markets. Early movers among SMEs can qualify as direct exporters or vendors to ESG-compliant multinational buyers.

How do we get started with JointValues?

We offer a discovery call, followed by a BRSR Value Chain Readiness Diagnostic. This includes:

  • Compliance roadmap
  • Supplier risk segmentation
  • Templates for data collection and audit planning

To initiate a consultation or receive a copy of our readiness checklist, reach out at Contact Us.