BRSR Core: Why SEBI’s New ESG Mandate Will Force a Rethink of Your Scrap Disposal

Updated: June 26, 2026 · 17 min read

When SEBI issued its circular on 12 July 2023 making BRSR Core reporting mandatory with third-party assurance for the top 1,000 listed companies, most sustainability teams assumed the heavy lifting would be on greenhouse gas emissions and energy intensity. Fewer than a third of those teams, based on early assurance engagements in FY 2023-24, had mapped their scrap disposal processes to the waste intensity KPI before the assurance provider walked in. That gap is now closing — sharply, and not always comfortably. For listed companies still treating BRSR Core scrap disposal as a procurement afterthought, FY 2025-26 is the year that complacency becomes an assurance qualification risk.

The 12 July 2023 Circular That Changed What “Waste Reporting” Means

SEBI’s circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122, dated 12 July 2023, did two things simultaneously: it introduced BRSR Core as a subset of the existing Business Responsibility and Sustainability Report, and it mandated reasonable assurance on those Core KPIs for the top 150 listed entities by market capitalisation starting FY 2023-24. This was not voluntary. SEBI made clear that the assurance requirement would phase upward — covering the top 250 entities by FY 2024-25, and the full top 1,000 by FY 2026-27.

The significance for waste and scrap teams is structural. Before July 2023, a company could report waste generated and disposed of under the existing BRSR framework as a narrative disclosure with limited external verification. BRSR Core changed the standard: specific KPIs must now be backed by evidence that meets a reasonable assurance threshold under SEBI’s regulatory framework, which in practice means assurance standards equivalent to ISAE 3000 (Revised) or the ICAI’s equivalent guidance. The shift from self-reported narrative to assured quantitative KPI is, in compliance terms, the difference between a declaration and a sworn statement.

What triggered additional scrutiny in early assurance engagements was the discovery that most listed companies had robust energy metering systems but rudimentary scrap-off-take documentation. A company with ₹800 crore in capital equipment can often tell you its Scope 1 and Scope 2 emissions to two decimal places. Ask the same company to produce a reconciled record of ferrous and non-ferrous scrap disposed of in the same financial year, with recycler authorisation numbers and GST invoices, and the answer is frequently a spreadsheet compiled the week before the assurance visit.

The 9 BRSR Core Attributes: Where Scrap Disposal Sits

BRSR Core comprises 9 ESG attributes drawn from the broader BRSR framework. SEBI has specified these in the Annexure to the 12 July 2023 circular. The nine are: GHG emissions intensity, energy intensity, water use intensity, waste intensity, human rights complaints, employee well-being expenditure, pay equity ratio, transparent business practices, and circularity. Of these, two directly govern how a company handles its scrap stream: waste intensity (total waste generated per unit of production or revenue) and circularity (proportion of waste recovered, reused, or recycled versus landfilled or incinerated).

For a manufacturing company with significant metal, plastic, or electronic scrap generation, both KPIs feed directly from the scrap disposal record. Waste intensity is typically expressed in metric tonnes of waste per crore of revenue. Circularity is expressed as a percentage: if 80% of your scrap by weight goes to an authorised recycler and 20% goes to landfill, your circularity rate is 80%. The assurance provider will not accept that number without underlying evidence — weigh-bridge slips, recycler certificates, and the recycler’s own CPCB or State Pollution Control Board authorisation. If the recycler is not authorised, the tonnage routed through them may be reclassified as “disposed” rather than “recycled” for assurance purposes, materially worsening your circularity score.

Why “Recycled” Requires a Paper Trail

The word “recycled” carries specific weight in the BRSR Core framework. SEBI has aligned its definitions with the Ministry of Environment, Forest and Climate Change (MoEFCC) framework, which means recycling is only recognised as such when conducted by an entity holding valid authorisation under applicable waste rules. A sale to an unregistered scrap dealer — however common in Indian industrial practice — does not qualify. This single definitional issue is the most common cause of circularity rate restatements in early BRSR Core assurance cycles.

Reasonable Assurance vs. Limited Assurance: A Practical Difference Worth Knowing

Limited assurance is the lower standard: the assurance provider performs analytical procedures and enquiries, and their conclusion is framed as “nothing has come to our attention” — a negative assurance. Reasonable assurance is the higher standard: the provider performs substantive testing, evidence inspection, and site verification, and their conclusion is a positive opinion. The difference in effort, and in the documentation burden placed on the reporting entity, is substantial.

For the top 150 listed entities who have been under reasonable assurance since FY 2023-24, this distinction already has real consequences. Assurance teams have been requesting recycler authorisation certificates, CPCB registration details, and weigh-bridge slips as part of substantive testing. A missing document chain for even one waste stream can result in a scope limitation note in the assurance report — which is publicly disclosed. For the top 250, now under reasonable assurance from FY 2024-25, the same standard applies. Companies ranked 251–1,000 that are still under limited assurance should treat FY 2025-26 as the last year to build their documentation infrastructure before the higher standard arrives.

What Assurance Providers Actually Ask For During a Scrap Disposal Walk

Based on engagements across listed manufacturing and infrastructure companies in Maharashtra, Gujarat, and Tamil Nadu, BRSR Core assurance walkthroughs for waste typically follow a consistent sequence. The assurance team begins by requesting the waste register — a facility-level log of all waste streams generated, categorised by type (hazardous, non-hazardous, e-waste, metal scrap, plastic scrap, and so on) and by disposal route. They then cross-reference the register against financial records: GST invoices issued by the recycler, outward delivery challans, and bank receipts or payment records for scrap sold.

The third check — and the one that most commonly produces gaps — is recycler authorisation status. The assurance provider will ask for the recycler’s CPCB or SPCB authorisation certificate and verify it is current, covers the relevant waste categories, and was valid during the period of disposal. For hazardous waste streams, this means cross-checking against the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 (and its subsequent amendments), under which both the waste generator and the recycler must hold valid authorisation. For e-waste streams, the check is against the E-Waste (Management) Rules, 2022.

Three Documents Most Frequently Flagged as Missing

Across BRSR Core assurance engagements reviewed in FY 2023-24 and FY 2024-25, three documents were flagged as absent or incomplete with the highest frequency: (1) the recycler’s current CPCB/SPCB authorisation certificate, (2) a certificate of recycling or certificate of destruction issued by the recycler for each disposal event, and (3) the GST-compliant tax invoice from the recycler confirming the transaction. Without all three, the disposal event cannot be classified as “recycled” in the assured BRSR Core data, and the tonnage is reclassified under “disposed” — directly worsening the waste intensity and circularity KPIs reported to SEBI.

BRSR Core Waste KPI — Document Requirements for Assurance

Waste Stream	Governing Rule	Required Authorisation	Key Document for Assurance	Record Retention
Hazardous Waste (oils, solvents, spent catalysts)	Hazardous & Other Wastes Rules, 2016	CPCB/SPCB Form 1 Authorisation	Manifest (Form 9/10), Certificate of Disposal	5 years
E-Waste (IT assets, circuit boards)	E-Waste (Management) Rules, 2022	CPCB e-waste recycler registration	Certificate of Recycling / Destruction	3 years (CPCB portal)
Plastic Scrap / Packaging Waste	Plastic Waste Management Rules, 2016 (as amended in 2024)	CPCB EPR portal registration	EPR certificate, GST invoice from recycler	3 years
Battery Waste (Li-ion, lead-acid)	Battery Waste Management Rules, 2022	CPCB battery waste portal registration	EPR fulfilment certificate, recycler invoice	3 years
Ferrous / Non-Ferrous Metal Scrap	Solid Waste Management Rules, 2016 (for industrial scrap); GST HSN 7204/7404	GST registration; SPCB consent where applicable	Weigh-bridge slip, GST invoice, Certificate of Recycling	5 years (GST)

BRSR Core Phasing for FY 2025-26: Deadlines by Entity Band

SEBI’s phasing schedule under the 12 July 2023 circular is explicit. The top 150 listed entities by market capitalisation were required to provide reasonable assurance on BRSR Core from FY 2023-24 (disclosures filed with the Annual Report for the year ended 31 March 2024). The top 250 moved to reasonable assurance from FY 2024-25. The band from 251 to 1,000 was required to provide limited assurance from FY 2023-24, stepping up to reasonable assurance by FY 2026-27.

For practical purposes, companies ranked 251–500 by market cap should treat FY 2025-26 as the year to build reasonable-assurance-grade documentation for waste KPIs, not the year to scramble once SEBI’s timeline arrives. Assurance providers — typically the Big 4 or their sustainability arms, plus specialist ESG assurance firms — have already flagged that waste stream documentation is the single most common gap in BRSR Core readiness assessments conducted across Indian manufacturing, infrastructure, and consumer goods companies in FY 2024-25.

One development that sharpened this urgency: in early 2025, SEBI’s enforcement division issued a guidance note reiterating that BRSR Core disclosures are subject to the same materiality and accuracy standards as financial disclosures. A material misstatement in a BRSR Core KPI — including waste intensity — could attract scrutiny under SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR). That regulatory proximity to financial reporting standards is new, and it changes the risk calculus for CFOs who have historically treated sustainability reporting as a communications exercise.

The Compliance Checklist: 7 Actions to Take This Quarter

Companies under BRSR Core scope — whether already at reasonable assurance or approaching it — should use Q1 FY 2025-26 to close the most common documentation gaps before the annual assurance engagement. The following checklist is drawn from common deficiencies noted in BRSR Core assurance walkthroughs across listed manufacturing and logistics entities.

1. Audit your recycler panel. For every vendor receiving scrap from your facilities, obtain a current copy of their CPCB or SPCB authorisation certificate. Verify that the authorisation covers the specific waste categories you are routing to them. An authorisation limited to ferrous metal scrap does not cover e-waste or hazardous sludge — both streams may exist on the same site.
2. Implement a certificate-of-recycling protocol. Require every authorised recycler to issue a certificate of recycling or certificate of destruction for each consignment, referencing the consignment date, net weight, waste category, and their CPCB registration number. File these alongside weigh-bridge slips and GST invoices in a disposal event register.
3. Reconcile your waste register monthly, not annually. Assurance providers sample across the reporting period. A waste register updated in March for an April–March year is a red flag. Monthly reconciliation against financial records (GST invoices, payment receipts) demonstrates process rigour.
4. Classify waste correctly by disposal route. Separate “recycled” (authorised recycler, certificate issued), “reused” (internal), “recovered for energy” (incineration with energy recovery under valid consent), and “disposed” (landfill or non-authorised routes). Your BRSR Core circularity rate is the ratio of the first three to total waste generated. Reclassifying non-documented disposal as “recycled” is the most common cause of BRSR Core assurance qualifications.
5. Verify GST compliance for all scrap transactions. Under GST, scrap sales attract specific HSN codes — for example, HSN 7204 for ferrous waste and scrap, HSN 7404 for copper waste and scrap. Ensure your recycler is issuing tax invoices under the correct HSN and that reverse-charge mechanism (RCM) obligations, where applicable, are being met. The GST portal provides the current HSN rate schedule.
6. Map hazardous waste streams against the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. If your manufacturing process generates Category 1 or Category 2 hazardous waste as listed in Schedule I or Schedule II of those Rules, you must hold a CPCB/SPCB authorisation as a generator — not just rely on your recycler’s authorisation. Check this via the CPCB hazardous waste portal.
7. Brief your CFO and Audit Committee on BRSR Core waste KPI risk. Given SEBI’s 2025 guidance note aligning BRSR Core accuracy standards with financial disclosure standards, waste intensity and circularity rate should be included in the Audit Committee’s review of BRSR Core prior to sign-off. A material misstatement in these KPIs carries regulatory risk under the SEBI (LODR) Regulations, 2015, not just reputational risk.

Regulations That Underpin Your Scrap Chain-of-Custody

BRSR Core’s waste KPIs do not exist in isolation. They sit atop a pre-existing regulatory framework governing waste generation, storage, transport, and recycling — and the assurance provider’s job is partly to verify that your reported disposal routes are consistent with those frameworks. The three regulations most relevant to industrial scrap are the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, the E-Waste (Management) Rules, 2022, and the Plastic Waste Management Rules, 2016 (as amended in 2024).

Under the Hazardous and Other Wastes Rules, 2016, Schedule I lists 89 categories of hazardous waste. Any industrial company generating these wastes must obtain authorisation under Rule 5 from the relevant SPCB or CPCB. Failure to hold or renew this authorisation can result in penalties under the Environment Protection Act, 1986, and — critically for BRSR Core purposes — means your disposal of those streams cannot be counted as authorised recycling. Under the E-Waste (Management) Rules, 2022, producers, bulk consumers, and recyclers all hold specific obligations under Schedule I and II; bulk consumers with more than 5 tonnes of e-waste per year must channel it exclusively to CPCB-registered recyclers. The CPCB e-waste portal maintains the list of registered dismantlers and recyclers by state.

The Plastic Waste Management Rules, 2016 (as amended in 2024) introduced stricter EPR targets and tightened the definition of “recycled content” under the CPCB EPR plastic portal. For companies with significant plastic packaging waste — FMCG, pharma, consumer goods — the EPR fulfilment certificate from a registered recycler or PRO is the evidence that plastic scrap has been legitimately recycled. Without it, the tonnage cannot be counted toward circularity in a BRSR Core-assured disclosure. Similarly, the Battery Waste Management Rules, 2022 — which set EPR collection targets of 70% for FY 2025-26 for Li-ion batteries — require battery waste to flow through CPCB-registered recyclers. If your company operates a fleet or a data centre with UPS battery banks, these obligations apply to you as a bulk consumer.

A note on NITI Aayog’s circular economy framework: NITI Aayog’s 2021 report on circular economy established a policy architecture that SEBI’s BRSR Core circularity metric explicitly builds upon. NITI Aayog has been pushing for extended producer responsibility norms across seven priority sectors. The alignment between NITI Aayog’s sectoral targets and SEBI’s BRSR Core KPIs means that companies already engaged in EPR compliance for plastic, e-waste, or battery waste have a head start — their existing EPR documentation is directly usable as BRSR Core assurance evidence.

Related Articles

• Plastic Waste Management Rules 2024 Amendment: What Changed and Who Needs to Worry
• Battery Waste Management Rules 2022: EPR Targets, Deadlines and Fines for FY 2026
• EPR Compliance Deadline 2026: What Indian Manufacturers Must Do This Quarter

Frequently Asked Questions

Which listed companies are required to provide reasonable assurance on BRSR Core in FY 2025-26?

Under SEBI’s circular dated 12 July 2023, the top 250 listed entities by market capitalisation are required to provide reasonable assurance on BRSR Core from FY 2024-25 onwards, which means the FY 2025-26 Annual Report will again require reasonable assurance for this band. Entities ranked 251–1,000 are currently under limited assurance, with the step-up to reasonable assurance phased in by SEBI by FY 2026-27. Assurance must be provided by a SEBI-registered third-party assurance provider.

What is the difference between waste intensity and circularity rate in BRSR Core?

Waste intensity is expressed as total waste generated (in metric tonnes) per unit of revenue (typically per ₹ crore) or per unit of production. Circularity rate is the percentage of total waste generated that is recovered through recycling, reuse, or energy recovery — as opposed to being landfilled or disposed of through non-authorised routes. Both are BRSR Core KPIs subject to assurance. A higher circularity rate requires documented evidence that waste was routed through authorised recyclers under applicable rules including the Hazardous and Other Wastes Rules, 2016 and the E-Waste (Management) Rules, 2022.

Does selling scrap to a local kabadiwala count as “recycled” under BRSR Core?

No. For a disposal event to be classified as recycling in a BRSR Core-assured disclosure, the recipient must hold valid CPCB or SPCB authorisation to recycle the specific waste category involved, and must be able to issue a certificate of recycling or certificate of destruction. An unregistered kabadiwala cannot provide either. Tonnage routed through unregistered buyers will be reclassified as “disposed” by the assurance provider, worsening your reported circularity rate. This is the single most frequent reclassification noted during BRSR Core waste walkthroughs in FY 2023-24 and FY 2024-25.

What record retention period applies to waste disposal documents under BRSR Core?

BRSR Core does not specify its own retention period, but the underlying regulatory frameworks govern this. The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 require waste manifests and disposal records to be retained for 5 years. GST records — including tax invoices from scrap recyclers — must be retained for 5 years under the GST Act, 2017. For CPCB portal-based e-waste and plastic EPR records, a minimum of 3 years’ records must be maintained on the portal. Given that BRSR Core assurance providers may request records for the prior year as a comparator, maintaining 5 years of records across all streams is recommended.

Can BRSR Core waste KPI misstatements attract SEBI enforcement?

SEBI’s 2025 guidance note explicitly aligns BRSR Core disclosure accuracy standards with those applicable to financial disclosures under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR). A material misstatement — including in waste intensity or circularity — could attract scrutiny under LODR Regulation 4(2)(f), which requires fair and accurate disclosure. While SEBI has not yet published a case specifically targeting BRSR waste KPI misstatements, the alignment of standards means the risk is structural, not theoretical. Companies should treat BRSR Core sign-off with the same rigour applied to financial statement sign-off.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered, pan-India scrap trading and recycling company with established operations across Maharashtra, Gujarat, Delhi-NCR, Tamil Nadu, Karnataka, and Telangana. Our industrial waste management service is built specifically for the documentation demands of listed companies operating under BRSR Core, EPR, and statutory waste management obligations.

For BRSR Core compliance teams, we provide the full documentation stack required by assurance providers: CPCB-authorised disposal partner credentials, certificates of recycling or destruction issued per consignment, weigh-bridge slips, and GST-compliant tax invoices under the correct HSN codes for each scrap category. Our pricing for ferrous and non-ferrous metal scrap is indexed to LME benchmarks and Mumbai yard rates, ensuring you receive fair market value alongside audit-grade documentation. Our metal scrap recycling service covers iron, steel, copper, aluminium, brass, stainless steel, and lead — and our EPR compliance services cover plastic, e-waste, and battery waste streams requiring CPCB portal registration and fulfilment.

Whether you are preparing for your first reasonable-assurance BRSR Core engagement, closing documentation gaps identified in a prior-year assurance walk, or building a systematic waste chain-of-custody programme ahead of SEBI’s FY 2026-27 full-scope deadline, we can help. Contact us to speak with our compliance team or to schedule a facility assessment.

• Pan-India pickup and scrap collection with scheduled frequency
• CPCB-authorised recycling partners for hazardous, e-waste, plastic, battery, and metal streams
• GST-compliant invoicing under correct HSN codes for all scrap categories
• Certificates of recycling and certificates of destruction issued per consignment
• BRSR Core-grade documentation: monthly disposal registers, recycler authorisation copies, weigh-bridge reconciliation
• Fair-market pricing for ferrous and non-ferrous scrap indexed to LME and prevailing Mumbai yard rates
• Dedicated compliance account manager for listed company clients

Sources and References

• SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023 — BRSR Core and Assurance Framework
• CPCB — Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016
• CPCB — E-Waste (Management) Rules, 2022: Registered Recyclers and EPR Portal
• CPCB — Extended Producer Responsibility Portal for Plastic Waste (Plastic Waste Management Rules, 2016 as amended in 2024)
• Ministry of Environment, Forest and Climate Change (MoEFCC) — Waste Management Regulatory Framework
• NITI Aayog — Circular Economy Report and Policy Framework (2021)
• GST Portal — HSN Code Schedule for Scrap and Waste (Chapter 72, 74)
• London Metal Exchange (LME) — Reference Pricing for Ferrous and Non-Ferrous Metals