BRSR reporting has arrived, but the harder task — embedding ESG accountability into board oversight — is still work in progress for most Indian companies.
Two cycles in, form still outpaces substance
The Business Responsibility and Sustainability Reporting framework has now produced two full cycles of disclosures from India's top 1,000 listed companies. CXO India Insights has reviewed a cross-section of these reports, and the pattern will be familiar to anyone who has watched corporate governance evolve: the form arrives before the substance. Companies are disclosing; fewer are governing.
Disclosure is not governance
The distinction matters enormously. Disclosure is a compliance exercise. It can be delegated to the sustainability team, packaged by a consulting firm, and signed off at a board meeting that spends eighteen minutes on the topic.
Governance is something different. It requires the board to understand material ESG risks the same way it understands financial risks: with clear metrics, honest assessments of where the company stands against its targets, and a willingness to make difficult trade-offs when ESG commitments conflict with short-term financial performance.
What the leading boards do differently
The boards genuinely ahead of this curve share several characteristics:
- Real expertise on the board. At least one director with substantive ESG credentials — not a former regulator who attended a two-day seminar, but someone who has managed environmental or social risks as a practitioner.
- ESG built into pay. ESG KPIs integrated into executive compensation in a meaningful way — not a token 5% weighting on a vague metric, but measurable targets tied to specific outcomes.
- An honest materiality process. A materiality assessment that is genuinely candid about which risks matter to their specific business model, rather than a copy-paste of their sector peers.
