Something significant is being built in the sustainability reporting landscape, and the blueprints are largely drawn in two cities.
Last year in London, the UK government opened three public consultations on adopting the ISSB standards, IFRS S1 and S2, through a new UK Sustainability Reporting Standards framework.
In Brussels, the European Commission is seeking feedback on revisions to the European Sustainability Reporting Standards (ESRS), following the removal of 61 percent of datapoints made under the EU’s Omnibus simplification package.
The ESRS-ISSB interoperability guidance has become the connective tissue binding these efforts together. The prevailing narrative is one of convergence and harmonisation, with ISSB as the global baseline.
It is an impressive project, but it has a conspicuous blind spot.
India’s Business Responsibility and Sustainability Reporting (BRSR) framework is mandatory for the top 1,000 listed companies by market capitalisation – entities representing 70 percent of India’s total market cap since FY 2022-23.
It requires machine-readable XBRL filings, carries regulatory enforcement, and includes a third-party assessed subset (BRSR core) on a structured expansion path from the top 250 companies in FY 2024-25 to 1,000 by FY 2026-27. Yet in the bilateral dialogue between London and Brussels, BRSR does not appear to exist.
What appears to be a peripheral oversight could be a structural problem. There are three reasons the conversation needs to widen.
1. BRSR captures what western frameworks are still debating
BRSR is built upon the National Guidelines on Responsible Business Conduct, embedding social and community accountability as mandatory quantitative disclosure topics rather than optional leadership indicators.
This matters in ways London and Brussels have not fully reckoned with. India sits at the centre of global value chains in industries such as textiles, pharmaceuticals and IT services.
The social risks embedded in those supply chains – such as contracted labour, factory safety and informal employment – are precisely the categories that ESRS S2 (workers in the value chain) and ISSB’s social disclosure framework are still working to operationalise in concrete, measurable form.
“The point is not that one framework is superior, it is that one has solved disclosure architecture problems that others are still discussing in committee.”
EFRAG’s own simplified ESRS drafts, delivered in December 2025, acknowledge the continued difficulty of making social disclosures practically workable.
BRSR already provides mandatory, structured disclosures on these issues for one of the world’s most complex industrial economies. The point is not that one framework is superior, it is that one has solved disclosure architecture problems that others are still discussing in committee.
2. Regulatory pragmatism, not political retreat
The EU’s Omnibus simplification was driven significantly by industry lobbying and competitiveness pressures. EFRAG received over 800 stakeholder inputs and held 41 industry interviews before delivering simplified drafts.
The US Securities and Exchange Commission effectively abandoned its climate disclosure rule in March 2025 under sustained litigation and political pressure. Reform-by-protest become the default mode.
BRSR’s 2024-45 recalibration followed an entirely different logic. When the Securities and Exchange Board of India (SEBI) – the apex regulatory body for securities and commodity markets in India – introduced the BRSR framework in May 2021, it approved target amendments.
Mandatory value chain disclosures were deferred one year to FY2025-26 and the definition of value chain partners were narrowed from covering 75 percent of purchases and sales to those individually accounting for 2 percent or more of transactions. “Assurance” was replaced with “assessment or assurance” to reduce compliance cost. These changes were formalised in the revised BRSR circular of March 2025.
Critically, these changes came not from lobbying campaigns or courtroom challenges but from a SEBI expert committee that analysed implementation data, identifying what companies found difficult, where data systems lacked, and where compliance burden outweighed the disclosure value.
This deserves recognition. It is calibrated institutional learning, and it is rare in global ESG regulation.
3. Investors with emerging market exposure are flying partially blind
Global investors hold significant exposure to Indian equities, yet the reporting architecture taking shape in London and Brussels is built almost entirely around EU-listed and ISSB-adopting companies.
The Financial Stability Board’s November 2024 progress report made this gap explicit by identifying the difficulties in emerging and developing economies face in implementing ISSB standards and called for new initiatives to address this challenge.
“Global investors hold significant exposure to Indian equities, yet the reporting architecture taking shape in London and Brussels is built almost entirely around EU-listed and ISSB-adopting companies.”
The International Finance Corporation’s 2025 report Elevating ESG Reporting in Emerging Markets surfaced the same tension between global standard ambition and local disclosure realities. Neither of the documents proposed a solution, but both confirmed the problem.
If BRSR – a mandatory third-party assessed, machine-readable framework, covering 1,000 India’s most significant listed companies – is not incorporated into global interoperability conversations, investors will have no comparable ESG risks data for Indian allocations.
The framework to provide that data already exists, so the barrier is not technical but could be institutional.
BRSR has limitations too
BRSR is not without flaws. The CFA Institute/NSE joint study found persistent inconsistencies in data quality and reporting unit standardisation. The framework is yet to embed ISSB’s investor-facing financial materiality architecture or the double-materiality depth of ESRS. Its regulatory anchoring is country-specific, limiting direct global comparability.
The argument is not that BRSR should replace or supersede ESRS, ISSB, SASB or GRI. It is that BRSR’s design philosophy carries lessons and usable information that the global standard-setting community is currently passing over.
This is ultimately a question of design philosophy. What kind of global sustainability reporting ecosystem are we building – one that captures ESG risks wherever the capital flows, or one that captures them wherever standard-setters happen to be headquartered?
The omnibus simplification process drew multiple stakeholders inputs and industry interviews. The ESRS-ISSB interoperability work involved extensive bilateral engagement.
One question still remains: how many inputs came from emerging markets?
If it is close to none, the label “global” sustainability reporting is difficult to justify. Without meaningful representation from emerging markets, the current reform agenda reflects Western standard-setting priorities dressed in global language.
A standard-setting process that structurally excludes the perspectives of emerging market regulators, investors and issuers cannot credibly claim global scope, regardless of its ambitions.
The table needs to be wider. The conversation about who sits at it is long overdue.
Gaurav Singh is an industry practitioner with deep experience in sustainable finance, ESG strategy and reporting. He is the author of An Introduction to Sustainability Reporting Frameworks.
