BRSR Cement Sector Benchmark FY 2024-25 — A Cross-Company Disclosure Study of 14 Indian Listed Cement Producers

Executive summary

This study reconstructs the FY 2024-25 Business Responsibility and Sustainability Report (BRSR) disclosure of 14 Indian listed cement producers from primary BRSR PDFs filed with the company, with NSE, or embedded in the Integrated Annual Report. The 14-entity sample covers UltraTech Cement, Ambuja Cements, ACC, Shree Cement, Dalmia Bharat, JK Cement, Nuvoco Vistas, Birla Corporation, JK Lakshmi Cement, The India Cements, Orient Cement, The Ramco Cements, Sagar Cements and Star Cement. Two further originally shortlisted entities — HeidelbergCement India and NCL Industries — are excluded with documented reasons that are themselves substantive findings. Across approximately 200 fields per entity, the dataset reveals six cross-sectoral patterns that recur whether the lens is environment, social, governance or assurance posture.

Headline findings at a glance:

• 40% spread in Scope 1+2 emissions intensity across disclosed entities, from 462 kg CO2 per tonne cementitious material (Nuvoco Vistas) to 645 kg CO2/t (Sagar Cements). Sector median 549 kg/t against a Global Cement and Concrete Association (GCCA) 2030 target of approximately 465 kg/t — only two of the disclosed entities are inside that range. This spread is partially driven by reporting-boundary differences — Nuvoco excludes 58 RMX plants + Modern Building Materials operations while revenue is consolidated, Birla Corporation includes Captive Power Plant emissions in Scope 1, and UltraTech reports both gross and net-of-avoided-emissions figures. Section 10 (Limitations) details the comparability caveats.
• Four-tier assurance landscape. One entity (Dalmia Bharat) holds Reasonable Assurance over the entire Integrated Report including the BRSR. Five entities meet the SEBI Top-250 BRSR Core Reasonable Assurance standard. Four hold Limited Assurance only. Four disclose no external assurance at all — including a same-FY assurance regression at India Cements coinciding with its acquisition by UltraTech.
• Thermal Substitution Rate (TSR) is the most under-disclosed cement-specific decarbonisation lever. Half the sample (7 of 14) does not disclose TSR numerically in BRSR, including both Adani-group cement entities (Ambuja and ACC), Birla Corporation, Dalmia Bharat, India Cements, Orient Cement and Ramco Cements. Among those that do disclose, the range is 2.41% (Shree Cement) to 12.6% (Star Cement) — a more-than-5x spread.
• Renewable energy share is reported on two non-comparable bases. BRSR Section C Q1 reports renewable share on a total-energy basis (includes kiln thermal fuel in the denominator); MD narratives report renewable share on an electricity-mix basis. The two numbers diverge by a factor of 5-10x for the same entity in the same FY, complicating cross-company comparison.
• Net-zero target stratification spans 30 years. Dalmia Bharat targets carbon-negative operations by 2040 — the most ambitious in the sample. JK Lakshmi targets 2047. UltraTech, Ambuja and ACC target 2050 (aligned with the GCCA Concrete Future Roadmap). Nuvoco, Ramco and Orient target 2070 (aligned with India’s national net-zero commitment). Six entities do not disclose a target year cleanly.
• The SEBI Top-1,000 mandate boundary itself is a structural finding. Of 16 originally shortlisted listed Indian cement entities, NCL Industries was excluded because its Directors’ Report explicitly states that BRSR is not applicable — NCL is outside the Top 1,000 by market capitalisation as on 31 December 2024 per SEBI Gazette dated 17 May 2024. Mid- and small-cap cement entities below the threshold have no BRSR-filing obligation under current SEBI LODR Regulation 34(2)(f).

Who should read this. This study is written for Indian listed cement CFOs and sustainability heads benchmarking their FY 2024-25 disclosures against immediate peers; BRSR Core assurance providers calibrating engagement scope ahead of the Top-500 phase-in for FY 2025-26; ESG analysts and rating providers needing primary-source reconciliation of intensity, assurance posture and acquisition-context discontinuities; Indian cement exporters preparing for the EU CBAM definitive phase from 1 January 2026; and journalists covering Indian decarbonisation, industrial consolidation and disclosure-quality regression. The full dataset and methodology are published under MIT licence in the BatchWise repository at the URL in the Reproducibility kit section.

1. Methodology

1.1 Sample frame

The universe was defined as Indian listed cement producers as on 31 March 2025 meeting four cumulative criteria: (i) listed on NSE and/or BSE; (ii) primary business classification “Cement & Cement Products” (NIC 2-digit 23, NSE Industry “Construction Materials”); (iii) domestic cement capacity ≥ 1 MTPA as on 31 March 2025; (iv) cement-related revenue ≥ 50% of total revenue from operations FY 2024-25. Sixteen entities passed these inclusion criteria. Fourteen are in the v1.0 statistical sample; two are documented exclusions:

• HeidelbergCement India — excluded under the acquisition-cliff category. The German parent Heidelberg Materials (69.39% holder) was in advanced talks with UltraTech Cement in January 2025 to divest its Indian operations in an approximately ₹3,381 crore transaction. As of 27 May 2026, HeidelbergCement India has not published a FY 2024-25 BRSR on its own investor relations page; the only BRSR available on mycemco.com is undated and the sitemap timestamps suggest FY 2022-23 / FY 2023-24 vintage. Including non-FY-consistent data would violate the year-consistency requirement.
• NCL Industries — excluded under the SEBI Top-1,000 mandate exemption category. NCL Industries meets every other inclusion criterion (NSE/BSE listed, NIC 23-classified, 3.30 MTPA capacity, cement revenue 80.51% of turnover). However, the Directors’ Report at page 33 of the FY 2024-25 Annual Report explicitly states: “Your company did not figure in the top 1000 listed entities based on market capitalization as on 31st December, 2024 as per notification issued by Securities Exchange Board of India vide Gazette notification dated 17th May, 2024 under SEBI (LODR)(Amendment) Regulations, 2024. Hence the requirement to furnish BRSR is not applicable to the company.” No Section A / B / C disclosures were filed; the Annual Report contains only Directors’ Report, MD&A and financial statements.

The two exclusions are materially different in mechanism — one is an acquisition-context transient, the other is a structural mandate boundary — and both are revisited in Sections 8 and 9 of this study.

1.2 Data sources

This study uses primary BRSR sources only. The priority order is (a) the company’s standalone BRSR PDF as filed on its investor relations page; (b) the BRSR section within the company’s Annual Report or Integrated Report for FY 2024-25; (c) NSE/BSE filings of the BRSR; (d) SEBI filings of the BRSR Core assurance report where applicable. Cross-validation sources used (without data substitution) include the company’s separately-published sustainability report, GRI Content Index, and publicly available CDP responses. Secondary aggregators (S&P Global ESG, Sustainalytics, MSCI ESG and similar rating providers) and sell-side analyst notes are strictly excluded. Every BRSR PDF used in this study was fetched via the BatchWise primary-source pipeline at scripts/primary-source/fetch.ts, cached with a fetch timestamp at scripts/primary-source/evidence/{domain}/{path}/{timestamp}/, and is independently re-fetchable from the URLs listed in the Sources frontmatter. The full list of 14 cached BRSR PDF URLs plus the NCL Annual Report appears in the frontmatter sources field above.

1.3 Coding rules

Five coding principles are applied per the v0.5 methodology document:

1. Verbatim where possible. Numeric values and named entities are recorded exactly as disclosed in the source BRSR; no inference, no rounding at the source-data layer.
2. Source page cited per data point. Every field value in the underlying JSON carries a _source_page reference to the BRSR PDF page number, enabling page-level verification.
3. “Not disclosed” flagged explicitly. Missing disclosure is treated as a data point (a disclosure-quality signal), not as zero. The dataset uses null rather than 0 for not-disclosed fields.
4. Unit consistency enforced post-collection. Companies report water in kL, m³, ML or million m³; energy in TJ, GJ, MWh, MJ or kcal; emissions in tonnes, kt or MtCO2e. All values are normalised during analysis with the original unit retained in source_unit. Indian-format ₹ amounts (lakhs, crores) are normalised to ₹ crore for cross-company comparison.
5. Restatements separately tracked. Where the company restates a prior-year figure (typically following SEBI Industry Standards Forum (ISF) guidance on BRSR Core issued in 2024 or the 20 December 2024 SEBI circular on PPP methodology), the restated value is captured and the original first-disclosed value retained in restated_from with a restatement_log_ref. Restatements were detected in Shree Cement, Dalmia Bharat, JK Lakshmi (UCWL merger), Star Cement, Ambuja Cements (RPT regrouping), Birla Corporation, Sagar Cements and Ramco Cements.

1.4 Disclosure Quality Score (DQS)

A 5-point ordinal Disclosure Quality Score is applied per BRSR Core attribute and aggregated to an entity-level DQS:

DQS	Definition
5	Quantitative + assured + restated for prior year + with methodology citation
4	Quantitative + assured (limited or reasonable) + with methodology citation
3	Quantitative + with methodology citation OR + with assurance (but not both)
2	Quantitative-only (no methodology, no assurance)
1	Qualitative description only
0	Not disclosed

Across the 14-entity sample, aggregate DQS ranges from 2.0 (Ramco Cements — quantitative-only across BRSR Core with zero external assurance) to 4.89 (UltraTech Cement — quantitative + Reasonable Assurance + restatement disclosure + methodology citation across all Core attributes). Sector median DQS is approximately 3.6.

1.5 Statistical treatment

For intensity metrics, 1.5 × Inter-Quartile Range (IQR) outliers are reported but excluded from sector medians and percentile bands; outliers are retained in the raw dataset with outlier=true flag. Where N ≤ 8 entities have disclosed a sub-cut, the IQR rule is suspended (all values reported with caveat). Sector median, P25, P75, min and max are reported for every numeric KPI alongside sample size (N) and missing-rate. Plain arithmetic averages are not reported (distort sector picture). Where weighted averages are useful, the weighting basis is disclosed. No company-vs-company “best-in-class” framing is used; rankings are reported only against objective decarbonisation thresholds (e.g., GCCA 2030 kg CO2 / t cement target) or against company-disclosed targets.

1.6 Known limitations

The methodology declares the following limitations up-front:

1. Self-reporting bias. BRSR is self-reported; companies optimise disclosure for narrative and competitive positioning.
2. Format variation. Not all 14 cement entities use identical BRSR formats. Some bury Scope 2 in narrative; others publish a clean Section C Principle 6 table.
3. Assurance variability. BRSR Core Reasonable Assurance was mandatory for Top 150 in FY 2023-24 and Top 250 in FY 2024-25. Not every cement entity in the sample is in the Top 250; where assurance is voluntary, the assurance level differs (Reasonable vs Limited).
4. Scope 3 patchy. Scope 3 disclosure across the 14 entities is highly inconsistent in both categories disclosed and methodology used. Sector-level Scope 3 aggregation is not attempted in v1.0.
5. Sub-segment disclosure variability. Where a cement entity is multi-business (Birla Corporation cement + jute + steel castings; Nuvoco cement + RMC + Modern Building Materials; Ramco cement + construction chemicals + windfarms), cement-segment-only data is preferred but not always disclosed separately. Where consolidated data is used, this is flagged.
6. Captive vs grid electricity boundary. Companies disclose location-based Scope 2 using grid emission factors of varying vintages; the sample is normalised to CEA V21.0 / V20.0 where possible, with company-disclosed values retained as primary. Captive Power Plant (CPP) emissions are sometimes counted as Scope 1 (Birla Corporation explicitly includes CPP) and sometimes not — flagged inline.
7. No representation of unlisted cement. Approximately 20-30% of Indian cement capacity (regional producers and unlisted players) is outside this benchmark, and an additional cohort of listed cement entities below the SEBI Top-1,000 market-cap threshold (such as NCL Industries) has no BRSR-filing obligation under current rules.

1.7 Reproducibility kit

Published alongside this anchor article: (a) the methodology document at docs/research/brsr-cement-benchmark/methodology.md; (b) the dataset at src/data/research/brsr-cement-fy2425/*.json (14 entity JSONs in v1.0 + the NCLIND.json artefact documenting the mandate exemption); (c) the aggregation working at docs/research/brsr-cement-benchmark/aggregation-v1.md; (d) the primary-source evidence cache at scripts/primary-source/evidence/ containing all 14 BRSR PDFs plus the NCL Annual Report. All are published under MIT licence. Vintage date for this v1.0 release is 27 May 2026; future versions will preserve v1.0 as a historical anchor rather than retroactively revising published statistics.

2. Cross-sectoral emissions intensity ranking — the 40% variance finding

The Scope 1 + Scope 2 emissions intensity per tonne of cementitious material is the single most material decarbonisation KPI in cement, given the chemistry of calcination (limestone → clinker releases approximately 540 kg CO2 per tonne of clinker before any fuel combustion) and the energy intensity of the kiln. Across the 14-entity sample, ten entities disclose this metric directly; four do not. The ten disclosed values span a 40% range.

Rank	Company	Scope 1+2 kg CO2 / t cementitious	Notes
1	Nuvoco Vistas	462	BRSR Section C Q7 figure; MD narrative reports 453.8 kg/t (post-audit). Boundary excludes 58 RMX plants while revenue denominator is consolidated.
2	ACC	506	Down from 534 in prior FY per the company disclosure. Scope 1 net 484 + Scope 2 22 = 506.
3	Ambuja Cements	555 per BRSR (Scope 1 537 + Scope 2 17, with intensity-rounding)	22% above own 2030 target of 440 kg/t Scope 1 + 10 kg/t Scope 2. Down from 581 kg/t in FY 2023-24. Reporting boundary verified by TUV India (Project Reference 8123494651, signoff 15 May 2025): 6 integrated cement plants + 9 grinding units, all national. Ambuja transparently self-discloses one FY 2024-25 environmental non-compliance: an Air Act (Prevention and Control of Pollution) 1981 fine of ₹6.6 lakh at the Rauri plant (pre-heater duct rupture; remediated).
4	Dalmia Bharat	538	Close to global cement industry average of approximately 456 kg/t (per Dalmia disclosure).
5	Shree Cement	546	Close to own 2030 target of 510 (Scope 1 net) + 5 (Scope 2). Calculated per tonne cement (not cementitious) is 648.5 kg/t — the denominator difference matters.
6	UltraTech (net)	549	Net of avoided emissions from blended cements. Gross Scope 1+2 = 609 kg/t. Down from 632 baseline 2017 (13% reduction). SBTi target 27% by 2032.
7	JK Cement	565	Above GCCA 2030 net Scope 1 target of 465 kg/t (currently at 517 net Scope 1; +44 Scope 2 = 565 gross). SBTi-validated 20.4% Scope 1 reduction by 2030 vs 2020 base.
8	Orient Cement	583	Down 2% YoY (594 → 583). Last independent BRSR before Ambuja Cements consolidation (April 2025).
9	Birla Corporation	594	Includes Captive Power Plant emissions in Scope 1 — inflates vs peers that may exclude CPP.
10	UltraTech (gross)	609	Gross Scope 1+2 pre-avoided-emissions; net figure of 549 quoted above.
11	Sagar Cements	645 (per cement) / 650 (per cementitious)	Highest disclosed; coincident with consolidated loss after tax of ₹216.68 cr FY 2024-25 and capacity utilisation decline.

Sector statistics (10 disclosed entities, excluding UltraTech gross to avoid double-counting): median 549 kg CO2/t cementitious; IQR 506-594; range 462 to 645 = 40% variance.

Four entities do not disclose intensity per tonne directly: India Cements (BRSR Section C reports absolute Scope 1 of 5,224,846 tCO2e + Scope 2 of 492,365 tCO2e and intensity per tonne cementitious of 0.637 tCO2/t = 637 kg/t, which is high but the BRSR does not headline this figure; calculated from disclosed values); JK Lakshmi (607.77 kg/t cementitious is derivable from the disclosed absolute Scope 1+2 of 7,244,535 tCO2e divided by implied cementitious output of 11.92 MT); Ramco Cements (calculated 578 kg/t cement from disclosed intensity per tonne of 5.78e-7 MMT/t); and Star Cement (calculated 580 kg/t cementitious from absolute Scope 1+2 of 2,744,630 tCO2e). For all four, the underlying numbers are present in the BRSR but the per-tonne intensity is not headlined — a disclosure-completeness gap on the most decision-relevant cement KPI.

Cross-reference to GCCA Concrete Future Roadmap. The GCCA 2030 cement-sector target is approximately 465 kg CO2 per tonne cementitious. Only Nuvoco Vistas (462) and ACC (506) are inside or within striking distance of that range as on FY 2024-25. The sector median of 549 kg/t implies an 18% reduction is required across the remaining decade to align with the GCCA 2030 trajectory — a gap that is most directly closed via three levers: (a) higher Thermal Substitution Rate (Section 4); (b) lower clinker factor (more blended cement); and (c) higher renewable electricity share. None of the three levers, however, addresses the calcination-process CO2 that is intrinsic to limestone-based cement chemistry; that gap requires carbon capture, which only two entities in the sample (UltraTech via ZeroCAL / UCLA partnerships and JK Cement via the DST-NCCBM-IIT Roorkee CCU pilot at Mangrol) have moved to pilot stage.

What explains the 40% spread. The lowest-intensity entities share three characteristics: (a) high blended-cement portfolio share (Nuvoco low-carbon cement portfolio is not separately disclosed but RMX-heavy operations imply blended share; ACC discloses 93% blended cement; Dalmia 84%; Ambuja 78%); (b) significant WHRS (Waste Heat Recovery System) capacity reducing grid-electricity Scope 2 (UltraTech 351 MW; Shree 242.5 MW; Dalmia approximately 2% of energy from WHRS; JK Lakshmi 45.4 MW); and (c) some TSR adoption (UltraTech 5.7%, JK Cement 11.34%, JK Lakshmi 10.39%, Star Cement 12.6%). The highest-intensity entities (Sagar at 645, Birla Corp at 594 including CPP) tend to have either utilisation-driven inefficiency (Sagar’s FY 2024-25 loss and capacity-utilisation issues) or boundary inflation (Birla Corp’s CPP inclusion). The 40% spread is therefore real but partly attributable to disclosure-boundary differences — a flag for any cross-company benchmark user.

3. Assurance compliance heterogeneity — the 4-tier landscape

The SEBI BRSR Core framework circular dated 12 July 2023 introduced a phased Reasonable Assurance mandate on 9 BRSR Core attributes: Top 150 listed entities by market capitalisation from FY 2023-24; Top 250 from FY 2024-25; Top 500 from FY 2025-26; Top 1,000 from FY 2026-27. The SEBI 28 March 2025 circular (CIR/CFD/CFD-PoD-1/P/CIR/2025/42) subsequently made the BRSR Value Chain ESG disclosure voluntary and introduced ease-of-doing-business measures, but the BRSR Core assurance phase-in remained in place. In FY 2024-25, 5 of the 14 cement entities in the sample fall within the Top 250 mandatory pool; the remaining 9 had elective options.

Across the 14-entity sample, four assurance tiers emerge:

Tier	Description	Companies (count)
Best-in-class	Reasonable Assurance over the entire Integrated Report including BRSR (exceeds Top-250 mandate scope)	Dalmia Bharat (1)
Standard mandate	Reasonable Assurance on BRSR Core 9 attributes	UltraTech, Ambuja, ACC, Shree Cement, JK Cement (5)
Limited only	Limited Assurance (voluntary; typically below the Top-250 mandate threshold)	JK Lakshmi, Nuvoco, Orient Cement, Sagar Cements (4)
No external assurance	”Not Applicable” / Nil disclosed in BRSR Section A items 14-15	Birla Corporation, Ramco Cements, India Cements, Star Cement (4)

3.1 Best-in-class: Dalmia Bharat

Dalmia Bharat is the only entity in the sample where the assurance scope extends to the entire Integrated Report including the BRSR. The assurance provider is TUV India Private Limited; the standard is ISAE 3000; the level is Reasonable; the scope covers overall non-financial performance for 1 April 2024 to 31 March 2025 on a sample basis. This exceeds the SEBI Top-250 BRSR Core mandate (which only covers the 9 Core attributes) and approaches the disclosure-quality standard that international integrated-reporting investors associate with European CSRD-grade reporting.

3.2 Standard mandate: 5 of 14

Five entities meet the Top-250 mandate with Reasonable Assurance on the 9 BRSR Core attributes — UltraTech (BDO India LLP, signed 10 September 2025 by Indra Guha), Ambuja Cements (TUV India Private Limited), ACC (TUV India Private Limited), Shree Cement (Intertek India Private Limited) and JK Cement (TUV India Private Limited, with separate Limited Assurance on remaining indicators). All five use ISAE 3000 (Revised) + ISAE 3410 as the assurance standard.

3.3 Limited only: 4 of 14

Four entities hold Limited Assurance only — JK Lakshmi Cement (Bureau Veritas India Private Limited under ISAE 3000, with separate Limited GHG-specific assurance from Bureau Veritas Industrial Services under ISO 14064-1:2018), Nuvoco Vistas (TUV India under GRI 2021 + BRSR Principle 6 scope, with Reasonable Assurance not obtained as Nuvoco is not in the Top 250 pool), Orient Cement (TUV India under ISAE 3000 (Revised), TUVI Project Reference 8123319161, with a separate standalone independent CO2 assurance also at Limited level), and Sagar Cements (TUV India under ISAE 3000 (Revised) for full BRSR voluntary assurance at Limited level).

3.4 No external assurance: 4 of 14

Four entities disclose no external assurance on the BRSR. Per BRSR Section A items 14-15, each of the four states “Not Applicable” or “Nil” against assurance provider and type:

• Birla Corporation Ltd — Section A Q14/Q15 explicitly: “Name of assessment or assurance provider — Not Applicable; Type of assessment or assurance obtained — Not Applicable.” Each Principle 6 Essential Indicator carries the note: “Indicate if any independent assessment/evaluation/assurance has been carried out by an external agency? (Y/N) If yes, name of the external agency — No.” Birla Corp is a multi-business entity with cement at 96% of revenue plus jute and steel castings; the BRSR is on a consolidated basis covering parent + RCCPL Pvt Ltd only.
• The Ramco Cements Ltd — BRSR page 104: “Name of assessment or assurance provider — Nil; Type — NA.” Every environmental disclosure (energy, water, emissions, waste) carries an explicit “No” to the assurance question. Ramco’s market capitalisation of approximately ₹19,157 crore as on 31 March 2024 (FY 2024-25 turnover ₹8,539.10 cr; consolidated cement output ~18.2 MT) places it within the likely SEBI Top-250 range by market cap — the BRSR Core Reasonable Assurance mandatory cohort for FY 2024-25. If Top-250 inclusion is confirmed against the SEBI list, the absence of any external assurance would represent a material mandate-compliance question. The company narrative does note an intent to engage external audit for data validation as a Principle 1 target — but the FY 2024-25 BRSR as filed carries no assurance.
• The India Cements Ltd — Section A items 14-15 explicitly state assurance provider and type as “Not Applicable.” Principle 6 KPIs (energy, water, GHG) all show “No” external assessment for FY 2024-25. This is a regression from FY 2023-24, in which Sprih provided independent assessment on energy, water and GHG. The regression is detailed in Section 9.
• Star Cement Ltd — Section A Q14 explicitly states “Not Applicable” for assurance provider and type. The company is below the Top-250 by market capitalisation as on 31 March 2024 per its own BRSR field flag (is_top_250_brsr_core_assurance_fy_2425: false), so the absence of assurance is consistent with mandate exemption.

3.5 Critical sub-findings

India Cements assurance regression — covered in Section 9 as a standalone case study. As filed, FY 2023-24 carried Sprih external assessment on Principle 6; FY 2024-25 BRSR Section A items 14-15 state “Not Applicable.” The same FY also saw a board reconstitution (25 December 2024; 9 directors ceased, 8 new appointed) following UltraTech’s controlling-stake acquisition, and a 17% YoY revenue decline. This study reports the temporal coincidence as disclosed; it does not infer causation between the acquisition event, the board reconstitution, the revenue decline, and the assurance change.

Ramco Cements mandate-gap candidate — Ramco’s market capitalisation of approximately ₹19,157 crore as on 31 March 2024 places it within the likely SEBI Top-250 range by market cap, yet the FY 2024-25 BRSR carries zero external assurance. The SEBI Top-250 list as published on the BSE / NSE websites for FY 2024-25 should be the authoritative reference; if Ramco is on that list, the absence of Reasonable Assurance would represent a mandate-compliance question requiring company explanation. The BRSR record as it stands documents the absence of assurance verbatim (“Name of assessment or assurance provider — Nil; Type — NA”; Principle 6 environmental disclosures all flagged “No” external assessment).

Assurance adoption tracks mandate boundaries strictly; voluntary assurance is rare. Of the 14 cement entities, 4 (29%) have no third-party verification of their BRSR (Birla Corp, Ramco Cements, India Cements, Star Cement — three of the four are below the SEBI Top-250 cohort for FY 2024-25 and therefore exempt from the BRSR Core Reasonable Assurance mandate; Ramco is the one within likely Top-250 range pending SEBI list verification). A further 4 (29%) have only Limited Assurance (JK Lakshmi, Nuvoco, Orient, Sagar). Combined, more than half the sample (8 of 14 = 57%) does not have BRSR Core Reasonable Assurance — the level that the SEBI 12 July 2023 circular treats as the assurance gold standard for the Top-250 mandate. For 7 of these 8, the absence is a consequence of being below the mandatory cohort; for the eighth (Ramco), it is a verification question. The structural finding is that voluntary uptake of Reasonable Assurance by entities outside the mandatory cohort is rare — only Dalmia Bharat exceeds the mandate (Reasonable over entire Integrated Report). The phased SEBI mandate is the binding constraint on assurance adoption; market-led voluntary assurance, on the evidence of the FY 2024-25 BRSRs of this sample, has not emerged.

4. TSR — the cement-specific decarbonisation lever

Thermal Substitution Rate (TSR) is the share of total thermal energy used in clinker production that comes from alternative fuels (industrial waste, biomass, refuse-derived fuel (RDF), municipal solid waste, plastic waste, tyres) rather than fossil fuels (typically pet coke or coal). For Indian cement, thermal energy in the kiln accounts for approximately 70-80% of the total energy footprint; TSR is therefore a more material decarbonisation lever than renewable electricity for the cement-specific Scope 1. The GCCA global cement-sector TSR target is approximately 25% by 2030; Europe’s leading cement majors are at 50-60%.

Among the 14-entity sample, seven entities disclose TSR numerically; seven do not.

Rank	Company	TSR FY 2024-25	Own target	Notes
1	Star Cement	12.6%	4% (already over-achieved)	Operations in Meghalaya; AFR processing unit operationalised FY 2024-25
2	JK Cement	11.34%	35% by 2030 (gap: -23.66 pp)	RDF + MSW + plastic + biomass; DST-NCCBM-IIT Roorkee CCU pilot at Mangrol
3	JK Lakshmi	10.39% (up from 4.1% in FY 2022-23)	20% by FY30 (gap: -9.61 pp)	Industrial waste + spent oil; AFR 22.20% of input raw material
4	Nuvoco Vistas	9.6%	Not disclosed	”Alternative Fuel and Raw Materials (AFR) Mix”; 69 kt RDF co-processed
5	UltraTech	5.7% (YoY increase 9.6%)	10% by 2030 (gap: -4.3 pp)	Cited in three independent locations in the IR (p.39 risk register, p.47, ESG Factbook); 2.1 Mt alternative fuel consumed
6	Sagar Cements	5.4% (Bayyavaram plant 43%)	25% by 2030 (gap: -19.6 pp; ~5x gap)	Industrial waste + biomass + tyres + belts
7	Shree Cement	2.41%	Not a TSR-led strategy (RE-led: 56.09% green electricity)	Renewable-electricity-led decarbonisation strategy; low TSR is consistent
—	Ambuja Cements	Not disclosed numerically	”Waste-derived resources consumed 8.08 MT FY 2024-25; target 21 MT by 2030”	Qualitative reference only in BRSR; CEO statement page 308
—	ACC	Not disclosed numerically	”Ambitious targets for TSR by using alternate fuels”	Qualitative reference only; same Adani-group pattern as Ambuja
—	Birla Corporation	Not disclosed numerically	”Optimal Thermal Substitution Rate by 2030 (On Track)“	Qualitative voluntary target only
—	Dalmia Bharat	23% disclosed via GCCA Sustainable Fuels including Biomass	Not disclosed cleanly	Per GCCA Table page 411: “Sustainable fuels including Biomass 23%” — highest disclosed if treated as TSR
—	India Cements	Not disclosed numerically	Not disclosed	Multiple alternative fuel types listed qualitatively (agro-waste, plastic, biomass, rice husk, fly ash)
—	Orient Cement	18% company-wide (Jalgaon 20%)	25% by 2030 (gap: -7 pp)	Up from 12% prior FY (Jalgaon up from 6%); disclosed in MD Statement narrative
—	Ramco Cements	Not disclosed numerically	Not disclosed	Narrative refers to increasing alternative fuels share; quantitative TSR absent

TSR median (7 cleanly-disclosed entities, excluding Dalmia GCCA proxy): 9.6% · Range: 2.41% to 12.6%.

Disclosure-completeness gap. Seven of fourteen entities (50%) do not disclose TSR numerically in the BRSR Section C Principle 6 table, including both Adani-group cement entities (Ambuja and ACC), Birla Corporation, India Cements and Ramco Cements. For an Adani-consolidated reader, TSR for Ambuja + ACC + Sanghi + Orient Cement (consolidating from FY 2025-26) would be the single most material decarbonisation KPI — and it is the one consistently absent from BRSR Section C. The pattern is sector-wide rather than promoter-specific: TSR disclosure is a sector-level disclosure-completeness gap. The recurrence across both promoter-controlled and independent entities suggests it is a BRSR-template gap (the SEBI BRSR Section C Principle 6 essential indicators do not explicitly mandate a TSR field) rather than a per-entity choice.

Two decarbonisation strategy patterns visible in the disclosed cohort. The alternative-fuel-led pattern (Star Cement, JK Cement, JK Lakshmi, Nuvoco) targets high TSR alongside moderate renewable electricity share. The renewable-electricity-led pattern (Shree Cement, with 56.09% green electricity and 2.41% TSR; UltraTech with 1.02 GW captive renewables and 351 MW WHRS) targets the Scope 2 footprint more aggressively while accepting moderate TSR. Both pathways are GCCA-aligned in principle; the strategy choice tends to map to the geography (Star Cement’s Meghalaya operations benefit from local biomass availability) and the existing fuel-supply infrastructure.

5. Renewable share — the metric divergence problem

Renewable energy share is reported in BRSR Section C Principle 6 Q1 on a total-energy basis (renewable energy in TJ ÷ total energy consumption in TJ, where total energy includes the kiln thermal fuel denominator). MD narratives and Sustainability Report sections typically report renewable share on an electricity-mix basis (renewable electricity ÷ total electricity, excluding thermal fuel). For cement — where thermal fuel is approximately 70-80% of energy — these two bases produce numbers that differ by a factor of 5 to 10 for the same entity in the same FY.

Examples from the 14-entity sample:

• Shree Cement — BRSR Section C Q1: 5.83% renewable share (6,143.73 TJ renewable ÷ 105,274.69 TJ total). MD narrative: 56.09% green electricity share of power mix. The 56.09% figure is widely cited in Shree’s investor communications; the 5.83% figure is what appears in the BRSR Section C table. Ratio: 9.6x.
• Dalmia Bharat — BRSR Section C Q1: 5.7% (4,355 TJ ÷ 76,394 TJ). Company narrative: 36% renewable share on electricity-mix basis. Ratio: 6.3x.
• JK Cement — BRSR Section C Q1: 6.04% (2,756,265 GJ ÷ 45,663,365 GJ). Company narrative: 51% green power share of electricity. Target: 75% by 2030. Ratio: 8.4x.
• UltraTech — BRSR Section C: 2.68% (9,568.20 TJ renewable ÷ 357,164.77 TJ total). Renewable electricity capacity 1.02 GW + 351 MW WHRS. The electricity-mix share is not headlined identically in the BRSR but the company reports being EP100 (energy productivity doubling) target-achieved ahead of 2035.
• Ambuja Cements — BRSR Section C Q1: 8.54% (6,187,752 GJ ÷ 72,494,325 GJ). CEO statement page 308: green power share 28% in FY 2024-25; target 60% by FY 2027-28. Ratio: 3.3x.
• JK Lakshmi — BRSR Section C Q1: 7.9%. Renewable share of electricity: 48.57%. Target: 60% by FY 2030. Ratio: 6.1x.

A small number of entities are now disclosing both bases explicitly (Shree Cement, Dalmia Bharat, JK Cement narrative + BRSR table), which is the disclosure-quality direction of travel. Several entities still report only one basis — either narrative or BRSR table — without reconciliation, creating apparent inconsistency for an analyst reading both documents.

WHRS treatment compounds the divergence. Waste Heat Recovery System (WHRS) — recovering kiln exhaust heat to generate electricity — is sometimes counted within renewable share (when reported as “green energy”); sometimes counted as recovered process heat outside the renewable category; and sometimes counted in Scope 1 as avoided combustion. UltraTech reports avoided emissions from WHRS at 1,678,175 tCO2e separately from avoided emissions from renewable energy at 1,135,864 tCO2e — a cleanly separated treatment. Other entities do not separate the two. Where a benchmark user is comparing renewable shares across entities, the total-energy basis from BRSR Section C Q1 is the only consistent base because it is the SEBI-prescribed calculation; the narrative electricity-mix figures are operationally meaningful but not cross-company comparable without additional context.

Methodology recommendation for cross-company comparison. Use BRSR Section C Q1 (total-energy basis) as the primary basis. Footnote the narrative electricity-mix basis where the company reports it. Where WHRS is in scope, note explicitly whether the entity counts it as renewable, as recovered heat, or as avoided emissions. The dataset published with this study uses the total-energy basis as the primary renewable_share_pct field with the electricity-mix basis retained as renewable_share_pct_company_disclosed_electricity_basis where available.

6. Net-zero target landscape

Net-zero target year disclosures span a 30-year range across the sample, from 2040 (carbon-negative) to 2070 (national alignment). Six entities do not disclose a target year cleanly.

Target year	Companies	Alignment basis
2040 (carbon negative)	Dalmia Bharat	More ambitious than net-zero; RE100 + energy productivity doubling by 2030; SBTi-validated 14% Scope 1 reduction by 2030 vs FY 2019, 48% Scope 2 reduction
2047	JK Lakshmi	Aligned with India’s 100-year-of-independence framing; SBTi committed (not validated); RE100 with 100% renewable electricity by 2040
2050 (GCCA-aligned)	UltraTech, Ambuja Cements, ACC	UltraTech GCCA Concrete Future Roadmap; Ambuja + ACC GCCA-aligned via Adani Cement
2070 (national alignment)	Nuvoco Vistas, Ramco Cements, Orient Cement	Indian cement sector net-zero CO2 by 2070; aligned with India’s NDC under Paris Agreement
Not disclosed cleanly	Birla Corporation, India Cements, Sagar Cements (no explicit net-zero year), Shree Cement (100% renewable electricity by 2050 — implied net-zero by 2050 but not explicitly stated as such), JK Cement (no explicit net-zero target year despite SBTi-validated near-term targets), Star Cement (no SBTi, no net-zero target)	Various

SBTi-validated targets — UltraTech (Scope 1 27% intensity reduction by 2032 from 2017 base, Scope 2 69% by 2032; near-term target validated), Ambuja Cements (near-term 2030, long-term 2050; validation date not disclosed in BRSR), JK Cement (Scope 1 -20.4% by 2030 vs 2020 base, Scope 2 -44.7%; near-term validated), JK Lakshmi (committed, not validated per BRSR), Dalmia Bharat (validated). Sagar Cements committed to SBTi 1.5°C aligned reductions (validation date not disclosed). Shree Cement BRSR states “established Science Based Targets” without an explicit validation date or formally-validated target year. The remaining 7 entities do not disclose SBTi engagement.

Internal carbon price disclosed — UltraTech (USD 10 per tCO2 shadow price; under review post India Carbon Credit Trading Scheme notification); Dalmia Bharat (referenced in the Integrated Report but specific USD per tonne figure not extracted to the dataset). The remaining 12 entities do not disclose an internal carbon price.

Climate ambition stratification. The sample reveals three climate-ambition clusters: (a) Leaders — Dalmia Bharat (carbon-negative 2040), UltraTech, Ambuja, JK Cement (SBTi-validated, internal carbon price for UltraTech); (b) Mid-pack — JK Lakshmi, Shree Cement (RE100 by 2050 implied); ACC (GCCA 2050 via Adani Cement); (c) National-alignment — Nuvoco, Ramco, Orient at 2070 (consistent with India’s national NDC but not a 1.5°C-aligned pathway for the sector). The remaining 4 entities (Birla Corp, India Cements, Star Cement, Sagar Cements) do not disclose a net-zero target year clearly enough to cluster. For an institutional investor screening for climate-transition alignment, the cluster distinctions matter; for an EU CBAM-exposed exporter, the cluster maps to embedded-emissions intensity which is in turn a function of TSR + WHRS + renewable share rather than just the target year.

7. Social disclosure quality

The BRSR Core attribute set includes three social KPIs: spend on wellbeing (% of revenue); Lost Time Injury Frequency Rate (LTIFR) per million person-hours; gross wages paid to women (% of total wages). The BRSR Section A workforce disclosure additionally permits derivation of female workforce share.

7.1 Female workforce share

Female share of total workforce (including contract workers) varies widely across the sample:

Rank	Company	Female workforce share %	Notes
1	Star Cement	9.66% (permanent only 9.85%)	Highest in sample. Meghalaya/North-East workforce dynamics; gender disclosure pattern materially different from peninsular peers.
2	UltraTech (permanent only)	6.0% (employees permanent female 1,390 of 21,456)	Total workforce 90,167; permanent workforce share 5.06% per dataset calculation
3	Dalmia Bharat	4.1% (calculated total workforce)	Permanent share approximately 4.30% from disclosure
4	Nuvoco Vistas	3.76%	Matches disclosed gross wages paid to females share
5	Orient Cement	3.53% (all workforce) / 4.52% (permanent only)	Corrected from initial parser figure of 1.33% — parser excluded the 97 contractual female workers
6	ACC	3.28%	Permanent employees female 5.53%; permanent workers female 0.68%
7	JK Lakshmi	3.17% (all) / 1.86% (permanent only)
8	Sagar Cements	3.15%	All contract workmen classified by Sagar as “Other than Permanent Employees” (not Workers); affects comparability
9	Ramco Cements	2.78% (all) / 1.35% (permanent only)
10	JK Cement	2.37% (all) / 4.12% (permanent only)	Zero female permanent workers in production roles
11	Ambuja Cements	2.73% (calculated total workforce)	Female workforce 123 of 4,509; POSH rate 0.8% of female workforce
12	India Cements	2.11%	Corrected from initial parser 1.11% — total female 61 of 2,885
13	Shree Cement	1.34% (calculated total workforce)	Workforce 21,278; gross wages to women 1.42% of total
14	Birla Corporation	0.86%	Lowest disclosed; jute-division skew distorts cement-only comparison (jute mills contribute 8,240 contract workers, predominantly male)

Sector statistics: range 0.86% (Birla Corp) to 9.66% (Star Cement); median approximately 3.15%. Women are systematically under-represented in Indian cement; the decarbonisation transition toward AFR processing, WHRS operations and renewable energy operations may incrementally shift workforce composition, though no entity in the sample explicitly maps a workforce-transition projection to its decarbonisation roadmap.

Context for the highest and lowest values. Star Cement’s 9.66% female share is materially higher than the rest of the sample and reflects the company’s Meghalaya operations base — the female labour-force participation rate in Meghalaya is the highest among Indian states. Birla Corporation’s 0.86% is the lowest in the sample and reflects the consolidated jute-division workforce (Birla Jute Mills at Durgapur, West Bengal contributes substantial male contract worker headcount that dilutes the cement-segment female share); cement-segment-only female workforce share is not separately disclosed in the BRSR.

7.2 Gross wages paid to women (BRSR Core attribute 7)

Gross wages paid to women as a percentage of total wages is one of the 9 BRSR Core attributes subject to Reasonable Assurance (where the company is in the Top-250 mandate pool). Across the sample:

• JK Cement: 3.70% — among the highest disclosed. Permanent female share 4.12%.
• JK Lakshmi: 6.59% — highest disclosed; corresponds to female share of permanent workforce of 1.86% (so the per-capita female remuneration is meaningfully above the male median).
• UltraTech: 4.06% — Reasonable Assurance.
• Orient Cement: 3.44% — up from 2.81% in prior FY.
• ACC: 3.20% — Reasonable Assurance.
• Dalmia Bharat: 2.72% — Reasonable Assurance.
• Ambuja Cements: 2.59% — Reasonable Assurance.
• Sagar Cements: 1.85% — Limited Assurance.
• Birla Corporation: 1.50% — no external assurance.
• Shree Cement: 1.42% — Reasonable Assurance.
• India Cements: 0.81% — likely lowest in sample, down from 1.34% in prior FY. No external assurance for FY 2024-25.
• Ramco Cements: 0.80% — no external assurance.
• Star Cement: 5.0% — no external assurance; reflects higher female participation.
• Nuvoco Vistas: 3.76% — Limited assurance only.

7.3 Critical safety signals

The single most material safety signal in the sample is Ambuja Cements: 2 worker fatalities in FY 2024-25, sustained at the same level as FY 2023-24 (also 2 worker fatalities). Per the BRSR Core 9 attributes disclosure, Ambuja’s LTIFR per million person-hours is 0.31 (employees) and 0.44 (workers); the absolute fatality count of 2 is reported separately. The BRSR also discloses one POSH complaint received and upheld in FY 2024-25 at Ambuja (versus zero in FY 2023-24). These are material adverse social signals — disclosed verbatim in the BRSR — that coexist with the company’s Reasonable BRSR Core Assurance from TUV India. The point is methodologically important: Reasonable Assurance attests to the accuracy of the reported numbers; it does not attest to operational outcomes. The 2 fatalities and the POSH complaint are accurately reported; they are also material.

UltraTech: 8 total fatalities (2 employees + 6 workers) reported in FY 2024-25, with 92 recordable injuries (15 employees + 77 workers) and 47 high-consequence injuries (9 employees + 38 workers). The aggregate workforce is large (90,167) and the LTIFR per million person-hours is 0.21 (employees) and 0.19 (workers); both within sector norms. Health-and-safety complaints received: 57.

Nuvoco Vistas: 1 worker fatality (0 employees) FY 2024-25; LTIFR employees 0.81, workers 0.38; 30 total recordable injuries.

Ramco Cements: 1 contract-worker fatality + 6 recordable injuries (1 employee + 5 workers); LTIFR disclosed as blank ”-” despite the recordable injuries and fatality. This is a material disclosure-quality gap. The blank LTIFR cell appears in BRSR Principle 3 Essential Indicator 11; the text-extracted PDF shows the cell as empty rather than showing zero or a numeric value. The dataset records this as ltifr_disclosed_as_blank: true with DQS = 1 for the LTIFR attribute (qualitative-only disclosure where the fatality and injury counts are listed but the LTIFR computation is absent). For an investor or assurance reader, the absence of a computed LTIFR despite reportable injuries is itself a signal.

India Cements: 1 worker fatality + LTIFR for workers 3.41 per million person-hours (FY 2024-25). The prior-FY narrative inconsistency (a fatality was reported in FY 2023-24 but the LTIFR was reported as Nil) is noted in the dataset.

Dalmia Bharat: 3 fatalities (all contractors) — the BRSR notes employee + permanent worker LTIFR of 0, with contract worker LTIFR of 0.16.

Other entities report zero fatalities in FY 2024-25 (JK Cement, Shree Cement, JK Lakshmi, Sagar Cements, Star Cement, Birla Corp, ACC reports zero employee fatalities with workers fatalities not separately broken out, Orient Cement reports zero).

7.4 Wellbeing spend (BRSR Core attribute 5)

Spend on employee wellbeing as a percentage of revenue ranges from 0.05% (Birla Corporation) to 0.73% (India Cements; up from 0.54% prior FY despite the consolidated loss); sector median approximately 0.20-0.25%. The India Cements increase is anomalous given the 17% YoY revenue decline and likely reflects a relatively-stable absolute wellbeing spend divided by a smaller denominator. Dalmia Bharat reports 0.43% (₹60.11 cr); UltraTech 0.29%; Ambuja 0.28%; JK Cement 0.24%; Sagar 0.26% (₹5.87 cr on consolidated revenue ₹2,257.64 cr); Orient 0.10%; Nuvoco 0.11%; JK Lakshmi 0.17%; Ramco 0.20%; Star Cement 0.08%; Shree Cement 0.08%.

8. The SEBI Top-1,000 mandate boundary — the NCL Industries case study

Of 16 originally shortlisted listed Indian cement entities, NCL Industries Limited was excluded from the v1.0 sample with a documented reason that is itself a structural finding for the sector. NCL Industries — a Telangana-based cement and building-materials producer (cement, boards, RMC, doors, hydel power) with 3.30 MTPA cement capacity and FY 2024-25 cement production of 2.71 MT — meets every BRSR-applicable inclusion criterion of this study except the BRSR-filing obligation itself.

NCL’s FY 2024-25 Directors’ Report at page 33 states verbatim:

“Your company did not figure in the top 1000 listed entities based on market capitalization as on 31st December, 2024 as per notification issued by Securities Exchange Board of India vide Gazette notification dated 17th May, 2024 under SEBI (LODR)(Amendment) Regulations, 2024. Hence the requirement to furnish BRSR is not applicable to the company.”

NCL therefore did not publish a BRSR for FY 2024-25. No Section A / B / C disclosures exist in the Annual Report. The cement production tonnage, hydel capacity (16 MW Tungabhadra) and 999-employee headcount are disclosed in the MD&A and corporate-information sections of the Annual Report — but these are not BRSR Section C Principle 6 disclosures, so they cannot feed BRSR-comparable benchmarking tables (no Scope 1/2/3 split, no kL water units, no DQS-scoreable methodology citation, no LTIFR per million person-hours).

Cement-revenue share confirms inclusion intent. NCL’s cement-division gross turnover is ₹1,739.68 cr (80.51% of total turnover ₹2,160.75 cr). The inclusion-criterion failure is BRSR exemption, not segment mix.

8.1 Structural finding for Indian listed cement

The NCL case is the most direct documented evidence of the SEBI Top-1,000 mandate boundary in Indian cement: listed mid- and small-cap cement entities below the Top-1,000 market-capitalisation threshold have no BRSR-filing obligation under current SEBI LODR Regulation 34(2)(f). This creates a systematic disclosure gap in the segment of Indian cement that is, on the available evidence, the most exposed to grid-decarbonisation transition risk: smaller producers tend to have lower TSR, less WHRS capacity, lower renewable electricity share, and less in-house ESG infrastructure to navigate the CBAM transition (definitive phase from 1 January 2026) or the IFRS S2 disclosure landscape (ISSB targeted amendments published December 2025, effective 1 January 2027).

The Indian listed cement universe contains approximately 25-30 entities total (including the unlisted RMC and grinding-only entities). Only approximately 14 of these are inside the SEBI Top 1,000. The Top-1,000 threshold therefore captures approximately half of the listed cement universe by entity count — but a disproportionately larger share by capacity (the Top-1,000 includes all the cement majors that contribute the bulk of Indian cement production). The disclosure-gap segment is the mid- and small-cap tail.

8.2 Policy implication

The Top-1,000 threshold is a market-capitalisation cut, not a sector-materiality cut. For hard-to-abate sectors like cement, steel and aluminium, the IFRS S2 framework and the EU CBAM regime both make the case that even mid-cap producers in these sectors are material to transition planning at the national level. Whether the SEBI Top-1,000 threshold is the right boundary for cement is a policy question that this benchmark cannot resolve, but the v1.0 dataset documents the boundary as it exists in FY 2024-25 and flags the resulting disclosure gap. The NCL Industries Annual Report is retained in the research evidence cache at scripts/primary-source/evidence/nclind-com/ as documented evidence of the mandate boundary; the NCLIND.json artefact in the dataset captures the 28 fields that are derivable from the non-BRSR portions of the Annual Report (cement production, hydel capacity, employee count, plant locations, women director count) for any user who wants to reconstruct what an exempt-entity disclosure looks like.

9. Acquisition disruption on assurance posture — three case studies

Three entities in or adjacent to the sample illustrate how M&A activity disrupts BRSR continuity in materially different ways. The pattern matters for any user benchmarking the sector across multiple FYs, because acquisition consolidation either removes an entity from the disclosed-population entirely or transfers its disclosure under a new (typically larger) entity with different boundary and assurance posture.

9.1 HeidelbergCement India — acquisition-cliff

HeidelbergCement India is excluded from the v1.0 sample. The German parent Heidelberg Materials (69.39% holder) was in advanced talks with UltraTech Cement in January 2025 to divest its Indian operations in an approximately ₹3,381 crore transaction. As of the v1.0 publication date (27 May 2026), no FY 2024-25 BRSR has been published on the company’s investor relations page (mycemco.com only carries an undated BRSR, sitemap timestamps suggest FY 2022-23 / FY 2023-24 vintage). This is the cleanest case of acquisition-cliff discontinuity: the parent decision to exit the Indian market disrupts the regular BRSR publication cycle for the listed Indian subsidiary, leaving the FY 2024-25 disclosure absent until either (a) HeidelbergCement India publishes a stand-alone BRSR; or (b) the acquisition closes and the operations are captured under UltraTech’s consolidated reporting.

9.2 India Cements — assurance regression within sample

India Cements is within the v1.0 sample. UltraTech Cement acquired a controlling stake (now 81.49% via intermediary; ultimate holding Grasim Industries) in late 2024 / early 2025. The board was reconstituted on 25 December 2024 — 9 directors ceased and 8 new directors were appointed, reflecting the change of management/control. The FY 2024-25 BRSR was filed independently by India Cements as a separately-listed entity on 26 April 2025, signed by Kailash Chandra Jhanwar (Director, DIN 01743559) and E.R. Raj Narayanan (Director, DIN 00469886).

The material disclosure-quality finding is the same-FY assurance regression:

• FY 2023-24 — Energy, water and GHG carried independent assessment by Sprih (a third-party ESG assurance provider). Each P6 disclosure carried a “Yes” to the assurance question with Sprih named as the external agency.
• FY 2024-25 — Section A items 14-15: “Name of Assurance Provider: Not Applicable / Type of Assurance Obtained: Not Applicable.” Every Principle 6 disclosure carries a “No” to the assurance question. Sprih is referenced only in the historical comparator context, not as the FY 2024-25 provider.

The regression is coincident in time with the UltraTech acquisition. FY 2024-25 also reflects a sharp financial decline at India Cements — Revenue from Operations down 17% YoY (from ₹4,942 cr to ₹4,088 cr); Return on Net Worth -8.89% (worsened from -3.68% prior FY); energy intensity worsened from 2.66 to 2.81 GJ per tonne cementitious (suggesting lower capacity utilisation). The cementitious output (calculated from disclosed Scope 1+2 intensity and absolute emissions) is approximately 9.0 MT FY 2024-25.

This study does not infer causation between the acquisition and the assurance regression. The facts as disclosed are: (a) FY 2023-24 had Sprih assurance; (b) FY 2024-25 BRSR Section A items 14-15 state “Not Applicable”; (c) the board reconstitution and acquisition occurred during FY 2024-25. Future-year India Cements BRSR will likely consolidate under UltraTech, at which point the standalone disclosure ceases to exist. The FY 2024-25 BRSR is therefore the last independent BRSR filed by India Cements pre-consolidation — and it carries no external assurance.

9.3 Orient Cement — last independent BRSR pre-Ambuja consolidation

Orient Cement is within the v1.0 sample. Ambuja Cements (Adani Group) completed acquisition of approximately 46.66% promoter-group stake in April 2025 — post the FY 2024-25 reporting period end of 31 March 2025, but pre the Annual Report board approval. The Board of Directors who approved the FY 2024-25 Annual Report on 13 April 2025 (the CK Birla group board) was replaced effective 22-23 April 2025 by an Ambuja/Adani-nominated board comprising Vinod Bahety (Chairman), Vaibhav Dixit (WTD & CEO, ex-Ambuja Cements Head of Manufacturing), Rakesh Kumar Tiwary (Non-Executive Director, ex-Adani Group CFO Airports), Sudhir Nanavati (ID, senior advocate), Ravi Kapoor (ID, Company Secretary) and Shruti Shah (ID, tax advisory).

The FY 2024-25 BRSR captured at orientcement.com/wp-content/uploads/2019/05/2024-2025.pdf is therefore the last independent BRSR filed by Orient Cement as a CK Birla-group entity. Orient discloses Limited Assurance from TUV India Private Limited under ISAE 3000 (Revised) (TUVI Project Reference 8123319161); a separate standalone Limited CO2 assurance is also obtained. Scope 1+2 intensity per tonne cementitious is 583 kg CO2/t (down 2% YoY from 594 kg/t); TSR is 18% company-wide (Jalgaon plant 20%; both materially up from 12% and 6% respectively in FY 2023-24). FY 2025-26 reporting is likely to consolidate Orient under Adani Cement / Ambuja Cements; the 8.5 MTPA Orient Cement capacity becomes part of the Adani Cement portfolio reaching approximately 100.3 MTPA per Ambuja’s own AR FY 2024-25 disclosure.

9.4 Industry consolidation reshapes the benchmark sample

The three case studies above are not isolated — they fit a broader Indian cement consolidation pattern visible in the FY 2024-25 reporting cycle:

• Adani Cement portfolio consolidating — Ambuja Cements + ACC (since 2022 Holcim-to-Adani deal) + Orient Cement (April 2025) + Sanghi Industries (Ambuja subsidiary, 58.08% stake disclosed in Ambuja BRSR identity section) + Penna Cement Industries (Ambuja subsidiary, 99.94%). FY 2025-26 BRSR may see consolidated Adani Cement narratives across the four+ entities.
• UltraTech portfolio consolidating — UltraTech + India Cements (acquired 81.49% via intermediary late 2024) + Kesoram Cement Business (Scope 3 footnote in UltraTech BRSR explicitly excludes both India Cements and Kesoram from FY 2024-25 Scope 3 — flagged as material exclusion) + HeidelbergCement India (acquisition target Jan 2025).
• JK Lakshmi merger — Udaipur Cement Works Ltd (UCWL), Hansdeep Industries & Trading Company Ltd and Hidrive Developers and Industries Ltd merged with JKLC w.e.f. 31 July 2025 (Appointed Date 1 April 2024). FY 2024-25 non-financial information includes UCWL operations; not comparable to FY 2023-24 originally reported. The company explicitly states FY 2023-24 and FY 2024-25 are not comparable.

The pattern is that approximately one-third of the v1.0 sample is involved in active M&A or post-merger consolidation as on FY 2024-25 reporting date. For any user benchmarking the sector across multiple FYs, the FY 2024-25 sample composition will not match the FY 2025-26 sample composition. v2.0 of this benchmark (scheduled annually) will document the sample-frame evolution explicitly.

10. Limitations and reproducibility

10.1 Restated limitations

Restating the seven limitations from the methodology Section 7 above (Section 1.6 of this article): self-reporting bias; BRSR format variation; assurance variability across the Top-150 / Top-250 / Top-500 / Top-1,000 phase-in; Scope 3 disclosure inconsistency; sub-segment disclosure variability for multi-business entities; captive vs grid Scope 2 boundary variation including CPP treatment; no representation of unlisted cement nor of the Top-1,000-excluded segment (per Section 8).

10.2 Methodology-specific notes

• Sub-agent extraction. The dataset was assembled via sub-agent extraction per entity, with each sub-agent reading the cached BRSR PDF and populating the ~200-field JSON schema. Cross-validation between sub-agents and against external published benchmarks is documented in qc-log.md; mismatches >5% trigger full re-read of the source page. Cross-validation status is marked “pending” or “pass” per entity in qc_metadata.cross_validation_status. v1.0 publishes with cross-validation incomplete for several entities; v1.1 will close the gap.
• CPP inclusion inconsistency. Captive Power Plant emissions are explicitly included in Birla Corporation’s Scope 1 disclosure (per the dataset note scope_1_includes_cpp: true); for other entities the inclusion or exclusion is not always disclosed cleanly. Where this affects intensity-per-tonne rankings, it is flagged inline in Section 2.
• Scope 3 patchiness. Scope 3 disclosure across the 14 entities is highly inconsistent. UltraTech discloses 8 categories totalling 12,711,286.88 tCO2e (and explicitly excludes India Cements and Kesoram per a documented footnote). JK Cement discloses 1,452,883 tCO2e total. Dalmia Bharat discloses 1.47 MtCO2e aggregate (no category breakdown). JK Lakshmi discloses 80,371.29 tCO2e across categories 1, 2, 3, 4, 5, 6, 7, 9 (categories listed but per-category figures not all disclosed). Shree Cement discloses 301,681.91 tCO2e across categories 1, 3, 4, 5, 6, 7. Orient discloses 290,990 tCO2e aggregate (55% YoY drop from 641,616 tCO2e — methodology basis for the drop is not disclosed). Sagar discloses 473,554 tCO2e aggregate. Several entities (Ambuja, ACC, Birla Corporation, India Cements, Nuvoco, Ramco Cements, Star Cement) do not disclose Scope 3 in the BRSR; Ramco explicitly defers to a future year (“Assessment has to be carried out in the upcoming year”). BRSR-format Scope 3 disclosure is therefore not comparable across entities in v1.0; v2.0 may attempt deeper Scope 3 normalisation if the disclosure quality improves.
• Restatement detection. The dataset detects restatements per entity in qc_metadata.restatement_detected and notes the restated lines in restatement_log_ref. The most common restatement trigger across the sample is the SEBI Industry Standards Forum (ISF) guidance on BRSR Core issued mid-2024 (affecting Shree Cement, Dalmia Bharat) and the SEBI BRSR circular dated 20 December 2024 changing PPP methodology (affecting Star Cement). JK Lakshmi’s restatements relate to the UCWL merger (Section 9.4).
• CEO statement boilerplate. ACC’s CEO statement on page 307 appears to reference “Ambuja Cement” — using the same boilerplate language as the Ambuja BRSR. This is flagged in the dataset notes for ACC but does not affect the underlying data extracted from Section A / B / C.
• BRSR Core Reasonable Assurance scope explicitly excludes forward-looking claims. Per TUV India’s Independent Assurance Statement on Ambuja Cements’ FY 2024-25 BRSR (Project Reference 8123494651, signed 15 May 2025 by Manojkumar Borekar, Product Head – Sustainability Assurance Service): “TUVI did not perform any assurance procedures on the prospective information disclosed in the Report, including targets, expectations, and ambitions. Consequently, TUVI draws no conclusion on the prospective information”; “TUVI did not verify any ESG goals and claim through this assignment”; “This assurance statement does not endorse any environmental and social claims … TUVI does not permit use of this statement for Greenwashing or misleading claims.” This is the standard scope-limitation across BRSR Core Reasonable Assurance engagements in the sample (TUV India is the assurance provider for Ambuja, ACC, Dalmia Bharat, JK Cement, Nuvoco, Sagar Cements, and Orient Cement; BDO India LLP for UltraTech; Intertek for Shree Cement; Bureau Veritas for JK Lakshmi). Reasonable Assurance attests to the accuracy of the FY 2024-25 actual figures disclosed in BRSR Section C and the 9 BRSR Core attributes — it does NOT attest to the company’s 2030 targets, net-zero ambitions, or directional claims. Readers using BRSR Core Reasonable Assurance as a signal of disclosure rigour should understand this boundary.

10.3 Future v2.0 enhancements

The v2.0 refresh (planned for the FY 2025-26 disclosure cycle, target publication date 31 December 2026) will incorporate: (a) deeper Scope 3 normalisation if disclosure quality across the sample improves; (b) a CBAM exposure overlay mapping each entity’s EU export footprint to the CBAM in-scope cement sector; (c) HeidelbergCement India if a FY 2024-25 (delayed) or FY 2025-26 BRSR is published; (d) revised sample-frame to reflect M&A consolidation as described in Section 9; (e) three additional mid-cap cement entities flagged for v2.0 inclusion subject to BRSR availability — Sanghi Industries Ltd (SANGHIIND; ~6.1 MTPA capacity; 58.08% owned by Ambuja Cements during FY 2024-25 but separately listed and filing its own independent BRSR — confirmed in this study’s primary-source PDF audit of Ambuja’s FY 2024-25 BRSR, in which Ambuja lists Sanghi as a subsidiary in Section A item 23 while Ambuja’s own reporting boundary is standalone and explicitly excludes subsidiaries; the NCLT-approved Sanghi-Ambuja merger has accounting appointed date 1 April 2024 with legal scheme implementation effective from the NCLT order of 12 June 2025, so Sanghi’s FY 2024-25 BRSR exists as the final independent filing pre-consolidation); Mangalam Cement Ltd (MANGLMCEM; BK Birla affiliate; approximately 4 MTPA capacity); and Andhra Cements Ltd (ANDHRACEMT; majority-owned by Sagar Cements but separately listed and may file separately). v1.0 will be preserved as the historical anchor rather than retroactively revised.

10.4 Reproducibility kit

Component	Path
Methodology (v0.5, locked)	docs/research/brsr-cement-benchmark/methodology.md
Dataset (14 entity JSONs + NCLIND exemption artefact)	src/data/research/brsr-cement-fy2425/*.json
Aggregation working	docs/research/brsr-cement-benchmark/aggregation-v1.md
Sources tracker	docs/research/brsr-cement-benchmark/sources-tracker.md
Primary-source evidence cache	scripts/primary-source/evidence/ (all 15 PDFs cached with fetch timestamps)
Anchor article (this document)	src/content/methodology/brsr-cement-sector-benchmark-fy2425.mdx

All published under MIT licence. Cite as: “BatchWise BRSR Cement Sector Benchmark FY 2024-25, v1.0 (2026-05-27).“

11. Cross-references to BatchWise content and further reading

11.1 BatchWise methodology library

• BRSR Core 9 Attributes — KPI Formula Reference — formula-level reference for all 9 BRSR Core attributes used in this benchmark
• GHG Emission Intensity per Revenue (BRSR Core) — formula and assurance-readiness checklist
• Energy Footprint Disclosure (BRSR Core) — energy intensity per turnover methodology
• Female Wages Disclosure (BRSR Core) — gross wages paid to women % methodology
• Job Creation in Smaller Towns (BRSR Core) — rural/semi-urban wage-share methodology
• POSH Complaints Disclosure (BRSR Core) — Ambuja POSH complaint case context
• CEA Grid Emission Factors (all-India) — grid emission factor reference for Scope 2 location-based calculation
• Climate Transition Plan Disclosure — net-zero target year landscape context

11.2 BatchWise comparison library

• BRSR Core vs IFRS S2 — comparison of BRSR Core 9-attribute assurance scope vs IFRS S2 climate-related disclosure requirements (ISSB targeted amendments effective 1 January 2027)
• BRSR Core vs CSRD for Indian Listed with EU Subsidiary — for cement entities with EU customer exposure (CBAM)
• GRI vs BRSR Standards mapping — for entities reporting under both frameworks (Shree Cement, Dalmia Bharat, JK Cement, Sagar Cements, Nuvoco, JK Lakshmi)

11.3 BatchWise industry methodology

• BRSR for Cement Industry — sector-specific disclosure expectations and material topics
• BRSR for Manufacturing — comparative methodology for hard-to-abate sectors
• BRSR for Steel — adjacent CBAM-exposed sector

11.4 Spoke articles — 15-week publication roadmap

This anchor article is the lead of a 15-week spoke-publication program. Each spoke (1.5-2.5k words) drills into one finding from this study and cross-links back to the anchor and dataset. The 15 spokes — published one per week from the anchor publication date — are:

1. Top 10 Indian cement companies by Scope 1+2 emissions intensity FY 2024-25 (ranking + analysis)
2. Adani Cement double-counting risk — Ambuja + ACC + Orient Cement consolidation map
3. The SEBI Top-1,000 mandate boundary in Indian cement — NCL Industries case study
4. Why TSR is the most under-disclosed decarbonisation metric in Indian cement
5. Cement assurance maturity tiers — what the 14 BRSRs reveal about voluntary vs mandated discipline
6. India Cements — a case study in acquisition-driven assurance regression
7. JK Cement’s BRSR Core deep dive — SBTi-validated Indian cement disclosure
8. Shree Cement’s renewable-electricity-led strategy vs UltraTech’s TSR-led strategy
9. The fatality-LTIFR disclosure problem in Indian cement — Ambuja, Ramco, sector-wide trend
10. Net-zero target alignment in Indian cement — Dalmia 2040 vs national 2070
11. Gender and wage disclosures across 14 Indian cement majors — BRSR Core 7 analysis
12. Captive vs purchased renewable energy in Indian cement — boundary issues
13. CBAM exposure overlay on the 14-entity dataset — which Indian cement makers face EU price-cost from 1 January 2026
14. HeidelbergCement India — the acquisition-cliff case study
15. The Top-250 BRSR Core mandate boundary — Ramco, Birla Corp, Star Cement, India Cements as compliance-gap candidates

Each spoke URL will be added to this section as it publishes.

12. Citation and invitation

12.1 How to cite this study

APA format: BatchWise. (2026). BRSR Cement Sector Benchmark FY 2024-25: A cross-company disclosure study of 14 Indian listed cement producers (v1.0). https://batchwise.ai/methodology/brsr-cement-sector-benchmark-fy2425/

Chicago format: BatchWise. 2026. “BRSR Cement Sector Benchmark FY 2024-25: A Cross-Company Disclosure Study of 14 Indian Listed Cement Producers.” Version 1.0, May 27. https://batchwise.ai/methodology/brsr-cement-sector-benchmark-fy2425/.

Plain-text: BatchWise BRSR Cement Sector Benchmark FY 2024-25, v1.0 (27 May 2026). Available at batchwise.ai/methodology/brsr-cement-sector-benchmark-fy2425/. Dataset and methodology under MIT licence at github.com/ravirdp/batchwise.

12.2 Invitation

Journalists, analysts, consultants and academic researchers are invited to use the dataset under the MIT licence. The complete 14-entity JSON dataset plus the NCL Industries mandate-exemption artefact are at src/data/research/brsr-cement-fy2425/ in the BatchWise repository. Each entity JSON carries _source_page references to the underlying BRSR PDF page numbers, enabling page-level verification. Cross-validation queries, errata and additional data points can be submitted via pull request to the repository.

For BRSR Core assurance engagements, BRSR Value Chain Verification (ISAE 3000), or sector-specific advisory work, contact BatchWise via the consult form at batchwise.ai/contact. BatchWise is a coordination platform; assurance engagements are executed by partner CA firms under their own DSC.

Appendix A — 14-entity dataset summary

Company	State	Revenue ₹ cr	Workforce	Scope 1+2 kg CO2/t	TSR %	Renewable share % (BRSR)	Assurance posture	Net-zero year
UltraTech Cement	Maharashtra	75,955.13 (consol) / 70,857 (standalone)	90,167	549 net / 609 gross	5.7%	2.68%	Reasonable BRSR Core (BDO India LLP)	2050
Ambuja Cements	Gujarat	18,857	4,509	554 (537+17)	Not disclosed	8.54%	Reasonable Core + Limited other (TUV India)	2050
ACC	Gujarat	20,594 turnover	3,171	506 (484+22)	Not disclosed	8.68%	Reasonable Core + Limited other (TUV India)	2050
Shree Cement	Rajasthan	18,037.33	21,278	546 cementitious / 648.5 cement	2.41%	5.83% (total) / 56.09% (electricity)	Reasonable Core + Limited other (Intertek)	2050 implied (RE100)
Dalmia Bharat	Tamil Nadu	13,980	22,579 (consol) / 5,763 (perm)	538	23% (GCCA proxy)	5.7% (total) / 36% (electricity narrative)	Reasonable on entire Integrated Report (TUV India ISAE 3000)	2040 (carbon negative)
JK Cement	Uttar Pradesh	11,093	11,792	565 gross / 517 net	11.34%	6.04% (total) / 51% (electricity)	Reasonable Core + Limited other (TUV India)	Not disclosed cleanly
Nuvoco Vistas	Maharashtra	10,356.67	11,408	462 / 453.8 (narrative)	9.6%	4.22%	Limited only (TUV India under GRI + BRSR P6)	2070
Birla Corporation	West Bengal	9,214.49	16,272 (incl jute)	594 (incl CPP)	Not disclosed	0.59% (total) / 11.13% (electricity)	No assurance	Not disclosed
Ramco Cements	Tamil Nadu	8,539.10 turnover	10,865	578 (calculated)	Not disclosed	4.17%	No assurance	2070
JK Lakshmi Cement	Rajasthan	6,245.70	4,863	607.77 (calculated cementitious)	10.39%	7.9% (total) / 48.57% (electricity)	Limited only (Bureau Veritas under ISAE 3000)	2047
The India Cements	Tamil Nadu	4,088.47	2,885	637 (calculated)	Not disclosed	0.77%	No assurance — REGRESSION from FY 2023-24 (Sprih)	Not disclosed
Star Cement	Meghalaya	3,173.96	4,381	580 (calculated)	12.6%	15.41%	No assurance	Not disclosed
Sagar Cements	Telangana	2,257.64 (consol)	3,677	645 (cement) / 650 (cementitious)	5.4% (Bayyavaram plant 43%)	3.31%	Limited only (TUV India)	Not disclosed
Orient Cement	Odisha (regd) / Telangana (corp)	2,708.83	4,421	583 (down from 594)	18% (Jalgaon 20%)	12.66%	Limited only (TUV India)	2070

Appendix B — Excluded entities and reasoning

HeidelbergCement India Ltd (HEIDELBERG)

• Inclusion-criterion status: Meets criteria (i) NSE/BSE listed, (ii) NIC 2-digit 23 classification, (iii) capacity ≥ 1 MTPA, (iv) cement revenue ≥ 50% of total revenue.
• Exclusion reason: Acquisition-cliff. As of January 2025, Heidelberg Materials (German parent, 69.39% holder) was in advanced talks with UltraTech Cement to divest its Indian operations in an approximately ₹3,381 crore transaction. As of 27 May 2026 (anchor publication date), HeidelbergCement India has not published a FY 2024-25 BRSR on its own investor relations page (mycemco.com only carries an undated BRSR, likely FY 2022-23 / FY 2023-24 vintage based on sitemap timestamps).
• Why included would violate methodology: Combining FY 2023-24 data alongside FY 2024-25 disclosures from other entities would violate year-consistency.
• Re-inclusion criteria for v2.0: Re-included if (a) HeidelbergCement India publishes a standalone FY 2024-25 BRSR, or (b) the acquisition closes and the operations are captured under UltraTech’s consolidated reporting with separate Heidelberg-operations disclosure.

NCL Industries Limited (NCLIND)

• Inclusion-criterion status: Meets criteria (i) NSE/BSE listed, (ii) NIC 2-digit 23 (CIN-disclosed NIC code is 33130, an older NIC 1987 / NIC 2004 code mapping to cement, lime and plaster), (iii) capacity 3.30 MTPA ≥ 1 MTPA threshold, (iv) cement revenue 80.51% of turnover ≥ 50% threshold.
• Exclusion reason: SEBI Top-1,000 mandate exemption. Directors’ Report at page 33 of the FY 2024-25 Annual Report explicitly states: “the requirement to furnish a BRSR is not applicable to your company.” NCL is outside the SEBI Top 1,000 by market capitalisation as on 31 December 2024 per SEBI Gazette dated 17 May 2024 (Regulation 34(2)(f) of SEBI LODR 2015).
• Why included would violate methodology: No Section A / B / C disclosures were filed; the Annual Report contains only Directors’ Report, MD&A and financial statements. The 200-field benchmark cannot be populated for an entity that has not filed a BRSR.
• Substantive finding documented: The NCL exclusion is itself a finding about the SEBI Top-1,000 mandate boundary in Indian listed cement. See Section 8 of this article.
• Evidence retained: The NCL Annual Report PDF is cached at scripts/primary-source/evidence/nclind-com/wp-content-uploads-2024-08-ncl-ar-2025-final-pdf/2026-05-27T05-47-59-779Z/ and the partial (non-BRSR) data extracted is preserved in src/data/research/brsr-cement-fy2425/NCLIND.json.

Appendix C — Methodology version history

Version	Date	Status	Description
v0.1	2026-05 (early)	Initial draft	Pre-data-collection methodology design
v0.2	2026-05-27 (morning)	Sign-off pre-scraping	Methodology approved by Ravi Patel; 5 open methodology decisions resolved at defaults; 15-entity sample frame confirmed
v0.3	2026-05-27 (post-fetch round 1)	Sample refined	Sample frame refined post-sourcing to 14 entities + 1 documented exclusion (HeidelbergCement India — acquisition-cliff)
v0.4	2026-05-27 (post-fetch round 2)	Sample interim 15	Sample interim at 15 entities including NCL Industries (pre-Directors’-Report-discovery)
v0.5	2026-05-27 (final)	Sample finalised at 14 + 2 exclusions	NCL Industries Directors’ Report page 33 discovered, documenting SEBI Top-1,000 mandate exemption. Sample finalised at 14 entities + 2 documented exclusions (HeidelbergCement India — acquisition-cliff; NCL Industries — SEBI Top-1,000 mandate exemption). Methodology v0.5 locked at anchor publication date.
v1.0 (planned)	2026-05-27	Anchor publication	This article; v0.5 methodology locked as v1.0 reference methodology. Future minor corrections (typos, formatting) will not retroactively edit any published statistic.
v2.0 (planned)	2026-12-31	Annual refresh	FY 2025-26 dataset; v1.0 preserved as historical anchor; v2.0 published as parallel anchor with sample-frame evolution noted in changelog.