As india strengthens its climate commitments and global expectations for sustainability transparency increase, robust climate reporting has become an imperative rather than a choice. The Securities and Exchange Board of India’s (Sebi’s) Business Responsibility and Sustainability Reporting (BRSR) framework is currently mandatory for the top 1,000 listed entities, but there is a growing urgency for large unlisted private firms, unicorns, IPO-bound companies, and infrastructure giants to adopt similar disclosure standards.
The BRSR framework, influenced by global standards like the Global Reporting Initiative (GRI), provides a structured yet flexible mechanism for climate reporting. Although greenhouse gases remain a major focus, effective climate reporting should encompass more than just carbon emissions. Metrics such as resource efficiency, water and energy usage, biodiversity impacts, and waste management are becoming increasingly important, especially for sectors like agriculture, textiles, fast-moving consumer goods (FMCG), and heavy industry. Sebi’s recent updates aim to simplify value chain reporting, introduce Green Credits, and shift from third-party assurance to internal assessments to reduce compliance burdens, but meaningful reporting still requires clarity and rigor, particularly regarding environmental impact.
Climate reporting under BRSR requires disclosure of Scope 1 emissions (direct emissions from owned operations), Scope 2 emissions (indirect emissions from purchased electricity), and Scope 3 emissions (all other indirect emissions in the value chain, which are often the largest share for sectors such as manufacturing, mining, metals, retail, IT, and logistics). The BRSR also integrates governance and board oversight of sustainability, climate risk identification and resilience planning, and targets for emissions reduction and broader environmental impacts.
Private companies, though not yet legally obligated, have a strong business case for climate reporting. Climate risk now translates into financial risk, and stakeholders—including investors, lenders, clients, employees, and regulators—are increasingly factoring ESG (environmental, social and governance) performance into their decisions. The benefits for private companies include better access to capital, as ESG-compliant firms attract more investment from climate-conscious funds and global investors; improved creditworthiness, since banks and NBFCs are integrating ESG factors into lending models; enhanced IPO readiness, as transparency builds trust and reduces information asymmetry; greater client acquisition, especially since many global corporations require ESG disclosures across their supply chains; and higher employee engagement, as sustainability is a key value for younger, mission-driven talent.
Several large Indian conglomerates and unlisted IT firms already publish voluntary climate reports aligned with frameworks such as GRI, CDP, or TCFD, with disclosures often extending to water consumption and conservation strategies, renewable energy adoption, circular economy practices, waste reduction, and biodiversity preservation measures. Smaller firms, particularly in export-driven sectors, are following suit to remain globally competitive. Infrastructure companies, including many state-owned entities, are especially important due to their significant carbon footprints, with leaders like NTPC, SAIL, and Indian Railways having adopted climate targets and begun disclosing Scope 1, 2, and sometimes Scope 3 emissions.
Globally, climate disclosure mandates are expanding. For example, IFRS S1 & S2 (ISSB standards) focus on financial materiality and climate-specific data; the EU’s CSRD & ESRS require detailed ESG reporting by large listed and unlisted firms starting in 2026; the SEC in the US is introducing phased climate risk disclosure, including potential Scope 3 requirements; and Singapore will require large unlisted firms with more than S$1 billion in revenue to file assured climate reports aligned with ISSB from FY27. These frameworks are converging to form a global baseline that Indian regulators and companies will need to align with.
The Reserve Bank of India (RBI) has introduced a Draft Disclosure Framework on Climate-related Financial Risks for financial institutions, starting from FY26. This framework requires disclosures on climate governance, strategy, risk management, and metrics/targets, including both absolute and financed emissions, as well as scenario analysis to assess resilience under various climate pathways. The RBI’s move reflects its recognition that climate vulnerabilities could reduce GDP by up to 4.5% by 2030, and financial institutions are expected to reallocate capital away from carbon-intensive assets, pushing their corporate borrowers to become more climate-transparent.
While carbon emissions dominate climate discussions, other environmental factors such as water usage and stress, waste generation and circularity, biodiversity and land use, and energy mix and intensity also carry significant business risks and opportunities. As global ESG standards evolve, these non-GHG metrics will become an increasingly important part of sustainability disclosures.
For private companies, the key takeaways are to start early with voluntary reporting to prepare for future mandates, leverage existing frameworks like BRSR, GRI, and ISSB for credible disclosures, build internal capacity by training sustainability teams and integrating ESG into core strategy, and engage stakeholders through transparent communication to build trust and enhance brand value.
In conclusion, the case for climate reporting by unlisted private companies in India is both compelling and urgent. As global standards converge and stakeholder expectations rise, transparent climate disclosures are becoming a hallmark of responsible business. By adopting robust reporting practices, India’s private sector can mitigate risks, attract investment, and play a pivotal role in advancing the nation’s sustainable future.
The authors are from InGovern Research Services. Views are personal.
