BRSR Core Assurance: The Waste and Circularity Metrics Your Auditor Will Test

Updated: August 28, 2026 · 16 min read

SEBI’s BRSR Core framework landed quietly inside a 48-page circular in July 2023. Eighteen months on, with FY 2024-25 annual reports now being compiled and the top 250 listed companies under mandatory assurance, ESG audit teams are discovering that BRSR Core waste metrics are the single hardest attribute cluster to evidence. The problem is not intent — most large Indian manufacturers genuinely care about their circularity story. The problem is data infrastructure: weighbridge tickets that live in a plant manager’s drawer, hazardous waste manifests that were never reconciled against the CPCB portal, and recycling ratios computed on memory rather than measurement. Auditors are noticing, and SEBI is paying attention.

The Nine BRSR Core Attributes — And Where Waste Sits

SEBI’s BRSR Core framework, introduced via the circular dated 12 July 2023, identifies nine Key Performance Indicators (KPIs) that must be subjected to reasonable-assurance by an independent third party. The nine attributes span greenhouse gas intensity, water intensity, diversity ratios, pay equity, and — critically for any manufacturing, logistics, or consumer goods company — waste intensity and the percentage of waste recycled or reused.

The precise language in the BRSR Core schedule describes this as: total waste generated per unit of relevant output, reported in metric tonnes per crore of revenue (or per unit of production where more material), alongside the recycling and reuse ratio expressed as a percentage of total waste generated. These are not soft narrative disclosures. They are quantitative KPIs with a defined numerator, denominator, and boundary — and an assurance provider who signs off on them is professionally liable for that sign-off.

For companies in heavy industry, automotive, pharmaceuticals, or FMCG — sectors where National Recycling Corporation works closely with compliance teams across Maharashtra, Gujarat, and Tamil Nadu — waste data is rarely held in one system. Statutory waste (hazardous, biomedical, e-waste, plastic) sits in CPCB portals and statutory registers. General trade and process waste sits in ERP systems. Construction and demolition waste from capital projects may not sit anywhere at all. The BRSR Core audit begins by mapping these silos.

What SEBI’s 12 July 2023 Circular Actually Requires of Your Waste Data

SEBI’s circular (ref. SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122) set out a phased mandatory assurance schedule: the top 150 listed entities by market capitalisation were required to obtain BRSR Core assurance from FY 2023-24, with the scope expanding to the top 250 from FY 2024-25. By the time this article is read, almost every Nifty 500 ESG team should be assuming they are within striking distance of the mandate. The circular also specified that assurance must be at the “reasonable assurance” level — not the softer “limited assurance” — for the Core KPIs, which puts the evidentiary bar materially higher than what most Indian companies were used to under their previous sustainability reports.

Reasonable assurance, for practical purposes, means your assurance provider must independently verify the underlying data, not merely assess the plausibility of management’s assertions. For waste metrics, that translates to: they will ask for the source documents. A CFO who has only seen the summary figure in the ESG dashboard will struggle to answer the auditor’s first question: “Where is the weighbridge register for your Pune plant for Q2 FY 2024-25?”

Waste Intensity and Recycling Ratios: How Auditors Build the Test

The assurance test for waste intensity is built in three stages. First, the auditor establishes the completeness of waste streams — have all categories been captured, including non-process waste such as packaging, e-waste from office infrastructure, and construction debris from ongoing capital expenditure? Second, they test the accuracy of individual stream volumes against primary source documents. Third, they verify the denominator — the revenue or production figure used to compute intensity — against the audited financial statements, checking for deliberate or inadvertent denominator manipulation.

Recycling Ratios: The Numerator Problem

The recycling ratio — expressed as a percentage of total waste channelled to recycling, reuse, or recovery versus total waste generated — is where most misstatements originate. A common error is counting waste handed over to a recycler as equivalent to waste actually recycled. These are not the same. Under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, a consignment is only legally recycled when a registered recycler has processed it and issued a utilisation certificate. The moment between dispatch and utilisation certificate can span 60 to 90 days for some hazardous streams — a timing mismatch that inflates the FY ratio if not carefully managed.

For non-hazardous scrap — mild steel, copper, aluminium — the recycling ratio numerator should be supported by: (a) weighbridge tickets from the recycler’s yard, (b) a GST-compliant purchase invoice from the scrap dealer (which is the buyer’s invoice, since scrap sales are typically under reverse charge in specific categories), and (c) a certificate of recycling or destruction where the material is being destroyed rather than resold. Companies that channel scrap through a formal, registered waste dealer have a cleaner paper trail than those using informal kabadiwalas — and the difference shows up acutely under assurance.

Data Lineage: From Weighbridge to Disclosure

Data lineage is the auditor’s phrase for the chain of custody of a number — who measured it, when, with what instrument, how it was transferred from source to system, and who approved it at each stage. For BRSR Core waste metrics, that chain must run from the physical weighbridge or measurement point all the way to the number on page 87 of the annual report.

In practice, the chain breaks most often at three points. The first is the plant-to-HO transfer: plant teams record waste in tonnes in an Excel sheet, which is then re-keyed into a corporate ESG tool — a manual step with no version control and no reconciliation protocol. The second break is the third-party contribution: waste generated at contract manufacturing units, warehouse operations, or construction sites managed by EPC contractors is often excluded from the boundary entirely, without explicit disclosure of that exclusion. The third break is the unit conversion: plant data may be in kilograms; the BRSR disclosure must be in metric tonnes; and the conversion, trivial as it sounds, is often done ad hoc and without audit trail.

The fix is straightforward to describe and harder to execute: a documented data management protocol, approved by the CFO or sustainability committee, that specifies the measurement method, the responsible person at each plant, the cut-off date, the consolidation tool, and the review sign-off. This protocol becomes primary evidence for the assurance provider.

BRSR Core Waste KPI — Evidence Requirements by Stream Type

Waste Stream	Applicable Regulation	Primary Evidence Required	Retention Period
Hazardous waste	Hazardous & Other Wastes Rules, 2016	CPCB Form 3 manifest, TSDF utilisation certificate	5 years
E-waste (IT assets)	E-Waste (Management) Rules, 2022	EPR credit certificate, recycler’s authorisation, certificate of destruction	5 years
Plastic waste	Plastic Waste Management Rules, 2016 (amended 2024)	EPR account statement, recycler’s quarterly return on CPCB portal	3 years
Metal scrap (ferrous/non-ferrous)	GST Act, 2017 (HSN 7204 / 7404 etc.)	Weighbridge ticket, GST invoice, purchase order from recycler	6 years (GST)
Construction & demolition waste	C&D Waste Management Rules, 2016	Contractor disposal receipts, ULB C&D facility transfer records	3 years

Regulatory Overlap: BRSR Core Waste Metrics Meet CPCB Rules

One of the under-appreciated complexities of BRSR Core waste metrics is that the disclosure does not exist in a regulatory vacuum — it sits on top of, and must be consistent with, several pre-existing statutory registers and returns. An auditor with any rigour will cross-reference your BRSR waste figure against what your company filed with the Central Pollution Control Board and relevant State Pollution Control Boards during the same financial year.

Under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, every occupier generating hazardous waste above the threshold must submit an annual return (Form 4) to the SPCB by 30 June of the following financial year. The hazardous waste tonnage in that Form 4 should reconcile — within a reasonable tolerance — to the hazardous waste figure in the BRSR. If the BRSR shows 120 metric tonnes of hazardous waste generated and the Form 4 shows 85 metric tonnes, an auditor will stop the review and ask for an explanation. In practice, the gap is almost always caused by definitional differences (e.g., waste oil included in one filing but not the other) or boundary differences (captive power plant waste excluded from BRSR but included in Form 4). Either way, those differences must be documented and disclosed.

Similarly, under the E-Waste (Management) Rules, 2022, producers must file annual EPR returns through the CPCB portal, capturing both the volume of electrical and electronic equipment placed on the market and the quantum of e-waste collected and channelled to authorised recyclers. These returns carry e-waste recycling volumes that must tie back to the BRSR circularity disclosure. Our CPCB-authorised e-waste recycling service provides the precise documentation — recycler’s authorisation number, category-wise processing certificates — that makes this reconciliation clean.

For companies with plastic packaging obligations, the CPCB’s EPR plastic portal holds quarterly data on EPR targets and fulfilment. The Plastic Waste Management Rules, 2016 (as amended in 2024) set EPR collection targets — reaching 70% for certain rigid plastic categories for FY 2025-26 — and the portal balance must be reconciled against the BRSR recycling ratio for the same period.

BRSR Core Waste Metrics — Common Misstatements and How They Are Found

After reviewing disclosures across multiple manufacturing clients in Maharashtra and Gujarat, a clear pattern of misstatements has emerged. None of these are typically fraudulent — they are the product of poor data governance and a misunderstanding of what the BRSR framework actually demands.

Misstatement 1 — Double-counting recycling: Waste sold as scrap to a dealer and subsequently counted as recycled because the dealer is a recycler. If the GST invoice treats the transaction as a sale of scrap (which it should, under HSN 7204 for ferrous scrap), the recycling event is the dealer’s processing — not the company’s handover. The company can only claim the recycling once it holds a certificate of recycling from the authorised processor.

Misstatement 2 — Omitting non-process waste: IT asset disposals, cafeteria waste, packaging waste from raw material procurement — these are waste generated within the company’s operational boundary but are routinely excluded because they are not captured in the production waste management system. With e-waste volumes from IT refresh cycles now material (a mid-sized Indian manufacturer might retire 400-600 laptop units per year, amounting to 4-6 metric tonnes of e-waste), exclusion is increasingly auditable.

Misstatement 3 — Misclassifying waste category: Spent catalyst classified as general waste to avoid hazardous waste reporting obligations — and then appearing in the BRSR as non-hazardous, inconsistent with MoEFCC’s Schedule I categories under the Hazardous and Other Wastes Rules. This is the misstatement most likely to trigger regulatory scrutiny beyond SEBI, as it potentially involves a violation of the Rules themselves.

Misstatement 4 — Intensity denominator mismatch: Using consolidated group revenue (including subsidiaries) as the denominator for waste intensity while using only parent-company waste in the numerator. Or vice versa. The boundary must be consistent, and the assurance provider will check this against the financial statement consolidation boundary.

The 7-Step Compliance Checklist for Your ESG Reporting Team

The following checklist is designed for ESG controllers and company secretaries preparing for BRSR Core assurance engagement. Each action should be completed before the assurance provider commences fieldwork — typically six to eight weeks before the annual report sign-off deadline.

1. Map all waste streams against the BRSR boundary: List every waste category — hazardous, e-waste, plastic, metal scrap, C&D, biomedical where applicable — and confirm which falls inside the reporting boundary (own operations, direct subsidiaries) and which is explicitly excluded with a stated reason.
2. Reconcile BRSR waste figures to statutory filings: Pull your SPCB annual return (Form 4 under the Hazardous & Other Wastes Rules, 2016), your EPR portal balance (plastic and e-waste), and any CPCB consent-to-operate returns. Reconcile line-by-line to the draft BRSR disclosure. Document every variance exceeding 5% with a signed explanation.
3. Collect and file primary evidence by stream: For each waste stream, assemble: (a) weighbridge tickets or measurement logs, (b) vendor invoices and certificates, (c) CPCB/SPCB manifests where mandatory, and (d) EPR credit or utilisation certificates. Store in a single, indexed evidence pack accessible to the assurance team.
4. Verify recycler credentials before claiming recycling credit: Confirm that every recycler handling your waste holds a current CPCB or SPCB authorisation. An authorisation that expired on 31 March 2025 does not cover Q4 FY 2024-25 processing. Maintain copies of authorisation certificates with validity dates.
5. Document the intensity calculation methodology: Prepare a one-page data management note that specifies the numerator (total waste in metric tonnes, by stream), the denominator (revenue in ₹ crore from the audited P&L), the consolidation boundary, any restatements from prior year, and the name of the person who prepared and approved the calculation.
6. Conduct a dry-run interview with one plant team: Ask the plant environment manager to walk you through how the monthly waste figure reaches the corporate ESG system. If they cannot trace the number from the weighbridge register to the corporate dashboard in under 10 minutes, the data lineage is broken — and the assurance provider will find it.
7. Engage your waste service providers for audit-period certificates: Write formally to all authorised recyclers and waste management partners requesting (a) quantity-wise certificates of recycling or destruction for FY 2024-25, (b) confirmation of their authorisation status, and (c) HSN-wise GST invoice copies. Allow four weeks for response. For ferrous and non-ferrous metal scrap and for EPR-linked waste streams, The National Recycling Corporation issues these certificates as a standard part of every transaction.

Related Articles

• Hazardous and Other Wastes Rules 2016: A Practical Compliance Map for Indian Factories
• Hazardous Waste Rules 2016: The Manifest System Audit Trail Most Indian Factories Are Failing
• Why Procurement Now Asks for Certificate of Recycling: The New Vendor Onboarding Filter

Frequently Asked Questions

Which companies must obtain BRSR Core assurance for FY 2024-25?

Under SEBI’s circular dated 12 July 2023 (ref. SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122), the top 250 listed entities by market capitalisation (as on 31 March of the preceding year) are required to obtain third-party reasonable assurance on BRSR Core KPIs from FY 2024-25. The top 150 were already covered from FY 2023-24. Companies just outside the top 250 should begin voluntary preparation, as the threshold is expected to widen in subsequent SEBI amendments.

What is the penalty for a false BRSR Core disclosure?

SEBI can take enforcement action under Section 15HB of the Securities and Exchange Board of India Act, 1992, which provides for penalties up to ₹1 crore per violation for contravention of any SEBI regulation or circular. Beyond financial penalty, a false circularity disclosure could constitute misleading ESG communication, which carries reputational and, in extreme cases, criminal liability under the Companies Act, 2013.

How long must waste records be retained to support BRSR assurance?

Retention periods vary by stream. Hazardous waste manifests and annual returns under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 must be kept for five years. GST records, including scrap sale invoices, must be retained for six years under the GST Act, 2017. For BRSR purposes, retain all primary evidence for at least five years from the date of the annual report — since SEBI enforcement windows can extend beyond the immediate filing year.

Can waste handed to an unregistered kabadiwala be counted in the recycling ratio?

No. For BRSR Core assurance purposes, recycling can only be claimed where the receiving entity holds a valid CPCB or SPCB authorisation as a recycler, reprocessor, or pre-processor. Informal dealers — regardless of the volume handled — do not qualify, and the assurance provider will reject any recycling claim not supported by an authorisation certificate. This is also a legal requirement under the Hazardous & Other Wastes Rules, 2016 for scheduled wastes, and increasingly enforced under CPCB’s recent drive to formalise the scrap sector.

What is the CPCB’s position on e-waste in BRSR intensity calculations?

E-waste generated within the company’s operations — including obsolete IT hardware, batteries, and electrical equipment — must be disclosed separately under the BRSR’s “other waste” category and managed under the E-Waste (Management) Rules, 2022. The Rules require producers and bulk consumers to channel e-waste only to CPCB-authorised dismantlers and recyclers, and to file annual returns through the CPCB portal. Both the volume and the authorised recycler’s identity must be recorded and available for assurance review.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered B2B recycling and scrap trading company with pan-India collection and processing capabilities. We work with manufacturing companies, IT firms, pharmaceutical majors, and FMCG brands across Maharashtra, Gujarat, Karnataka, Tamil Nadu, Telangana, and Delhi-NCR — providing the kind of documented, traceable waste management that BRSR Core assurance now demands.

Every transaction we handle comes with GST-compliant invoicing, weighbridge-backed quantity records, and certificates of recycling or destruction issued on company letterhead — the exact primary evidence that assurance providers request. For EPR-linked waste streams — plastic, e-waste, batteries — we work through CPCB-authorised disposal partners and can provide stream-wise EPR credit documentation tied to each consignment. For metal scrap — ferrous and non-ferrous — our pricing is indexed to LME spot rates and Mumbai yard benchmarks, so your finance team is always selling at a fair-market rate that can be independently verified.

If your ESG team is heading into a BRSR Core assurance cycle and your waste documentation is not audit-ready, the time to act is before the assurance provider commences fieldwork — not after. Contact us this quarter to arrange a documentation review and agree a service structure that closes every evidence gap before it becomes an audit finding.

• Pan-India pickup and processing — Mumbai, Pune, Thane, Ahmedabad, Bengaluru, Chennai, Hyderabad, Delhi-NCR
• CPCB-authorised disposal partners for hazardous, e-waste, and EPR-regulated streams
• GST-compliant purchase invoices with correct HSN classification for all scrap categories
• Certificates of recycling and destruction, issued per consignment, audit-ready
• BRSR-grade data packs: weighbridge records, authorisation copies, stream-wise processing certificates
• Fair-market pricing for metal scrap, indexed to LME and transparent to your finance team
• Dedicated compliance account manager for companies under BRSR Core assurance obligation

Sources and References

• SEBI Circular dated 12 July 2023 — BRSR Core framework and assurance mandate (sebi.gov.in)
• CPCB — Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 (cpcb.nic.in)
• CPCB — E-Waste (Management) Rules, 2022 — EPR registration and authorised recyclers portal (cpcb.nic.in)
• CPCB — EPR Plastic Portal — targets, registrations and quarterly returns (eprplastic.cpcb.gov.in)
• Ministry of Environment, Forest and Climate Change — Construction & Demolition Waste Management Rules, 2016 and Plastic Waste Management Rules (moef.gov.in)
• NITI Aayog — Circular Economy policy framework and resource efficiency reports (niti.gov.in)
• GST Council — HSN classification for scrap categories and reverse charge provisions (gst.gov.in)
• Press reports — Business Standard and Economic Times ESG desk coverage of BRSR Core assurance enforcement trends, FY 2024-25 (referenced generally; specific headlines not reproduced)