India's BRSR Framework Should Add Climate Transition Plan Disclosures, IEEFA Argues

India's Business Responsibility and Sustainability Reporting framework currently lacks dedicated requirements for climate transition plans, leaving a significant gap in corporate sustainability disclosure that IEEFA says should be addressed through a phased implementation approach. With BRSR becoming mandatory for the top 1,000 listed companies from FY2024, the moment is opportune to introduce transition plan requirements aligned with global developments.

The UK Transition Plan Taskforce unveiled its transition plan disclosure framework on 9 October, described as a global gold standard, shortly before this analysis was published. Globally, several jurisdictions — including the UK, EU and in proposals from the US SEC — are mandating the disclosure of climate transition plans as part of sustainability reporting. Despite more than 18,000 companies reporting to the Carbon Disclosure Project globally, fewer than 0.5% have disclosed transition plans. In India, 25 of the largest corporates have stated net-zero or emission reduction targets, a figure expected to grow as BRSR obligations expand.

Transition plans carry particular significance for India, according to IEEFA, for three reasons. First, Indian power utilities and industrial companies are actively financing transition activities, requiring detailed disclosures to attract credible investor capital. Second, several Indian communities are economically dependent on fossil fuel supply chains, making just transition disclosures critical from a social risk management perspective. Third, detailed transition plans can help Indian companies allay greenwashing concerns among investors in developed markets who are increasingly demanding rigorous climate accountability.

IEEFA recommends a phased implementation approach for SEBI, beginning with linking existing BRSR disclosures to create a more integrated picture before introducing formal transition plan requirements. A regulatory sandbox for stakeholder feedback is proposed as an intermediate step. The current BRSR already includes some relevant elements — environmental and social risk reporting, governance disclosures and commitment timelines — but lacks the explicit linkages between financial performance, business strategy and transition goals that a credible transition plan requires.

Key figure — Less than 0.5% — share of 18,000-plus CDP-reporting companies globally that have disclosed climate transition plans