NGRBC Principle 6 — Environment: Disclosures, Evidence, and Audit Findings

What Principle 6 covers

The National Guidelines on Responsible Business Conduct (NGRBC) were issued by the Ministry of Corporate Affairs in 2018 and form the backbone of SEBI’s Business Responsibility and Sustainability Report (BRSR) format. Of the nine NGRBC Principles, Principle 6 covers environmental responsibility — the entity’s footprint on energy, emissions, water, waste, biodiversity, and environmental incidents.

P6 is the most data-heavy of the nine principles. It is also the principle with the highest assurance scope under SEBI’s BRSR Core mandate — four of the nine BRSR Core attributes fall here.

This page is the reference hub for everything Batchwise covers on P6. If you’ve landed here looking for a specific figure (CEA grid factor, XBRL element, evidence checklist), the cross-links below take you straight there.

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The 9 Essential indicators (mandatory for every BRSR filer)

Per SEBI’s BRSR format (Annexure II, Section C, Principle 6 — Essential indicators):

1. Total energy consumed — broken into electricity from grid, electricity from renewables, fuel consumption, and energy from other sources. Reported in joules or multiples (typically GJ).
2. Energy intensity per rupee of turnover — total energy consumed divided by revenue from operations.
3. Disclosure on Performance, Achieve and Trade (PAT) Scheme — applicable to designated consumers under the BEE PAT scheme.
4. Water withdrawal by source — surface water, groundwater, third-party water, seawater/desalinated, others. Plus total water withdrawal in kilolitres.
5. Water intensity per rupee of turnover — total water withdrawal divided by revenue from operations.
6. Water discharge — by destination (surface, groundwater, third-party, seawater) and treatment level (no treatment, with treatment).
7. Air emissions other than GHG — NOx, SOx, particulate matter, persistent organic pollutants, volatile organic compounds, hazardous air pollutants. Reported in metric tons or appropriate units, with measurement methodology.
8. GHG emissions (Scope 1 + Scope 2) — total emissions and intensity per rupee of turnover.
9. Waste generated — by category (plastic, e-waste, biomedical, construction & demolition, battery, radioactive, other hazardous, other non-hazardous), with quantities recycled, re-used, sent for disposal.

Items 2, 5, 8, and 9 (in part — the recycled percentage) are the four BRSR Core attributes that require independent reasonable assurance.

The 7 Leadership indicators (mandatory for Top 1,000)

The seven Leadership indicators below are mandatory disclosure for the Top 1,000 listed entities per SEBI’s BRSR Format. They are voluntary for entities outside the Top 1,000.

The “mandatory” label is on the act of reporting, not on the breadth of the response. Several Leadership indicators have materiality judgement built into the indicator itself — Scope 3 disclosure is required for material categories (not all 15), biodiversity disclosure is required for operations adjacent to sensitive areas (not at every facility), water-stressed-area reporting applies only to facilities in water-stressed regions. The judgement on what is material is the entity’s, but it must be defensible — the practitioner expectation is that the materiality assessment process is itself disclosed (typically under Principle 4 leadership indicators) and references sector benchmarks (SASB, TCFD, GRI 11–17 sector standards) plus stakeholder consultation, not management discretion alone.

Per SEBI’s BRSR format (Annexure II, Section C, Principle 6 — Leadership indicators):

1. Water withdrawal, consumption, and discharge in areas of water stress — per the WBCSD Water Stress Index or equivalent. Applies only to facilities in water-stressed regions per a recognised index.
2. GHG emissions Scope 3 — material Scope 3 categories with the calculation methodology. Materiality determination + the categories deemed immaterial (with rationale) must both be disclosed.
3. Biodiversity impact — operations adjacent to protected or biodiversity-sensitive areas. Conditional on the entity having such operations.
4. Resource-efficiency or low-carbon initiatives — quantified investment and outcomes for the reporting year.
5. Disclosures on environmental impact assessments (EIAs) — for new operations or expansions during the reporting year.
6. Compliance with environmental laws — instances of non-compliance, fines, regulatory notices.
7. Business Continuity and Disaster Management Plan — environmental risk dimensions.

Leadership indicators are not part of BRSR Core assurance scope but form the qualitative narrative around the assured numbers. A clean assurance opinion on Core attributes carries less weight if the Leadership disclosures expose material undisclosed risks — and a “not applicable” against a materiality-conditional Leadership indicator is a flag the assurance partner will want to see substantiated in the underlying materiality assessment.

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The 4 BRSR Core attributes under P6

These four are the Core attributes requiring independent reasonable assurance under SEBI’s March 2023 circular:

Attribute	Calculation	Methodology page (when published)
GHG emission intensity per rupee of turnover	(Scope 1 + Scope 2 in tCO₂e) ÷ Revenue from operations adjusted for PPP	GHG Emission Intensity per Revenue
Water withdrawal intensity per rupee of turnover	Total water withdrawal (KL) ÷ Revenue from operations adjusted for PPP	Water Withdrawal Intensity
Energy consumption intensity per rupee of turnover	Total energy consumed (GJ) ÷ Revenue from operations (₹ Cr)	/methodology/energy-consumption-intensity/
Waste recycled / reused as % of total waste	(Waste recycled + waste re-used) ÷ Total waste generated × 100	/methodology/waste-recycled-reused/

For the assurance engagement that covers these four, see BRSR Core Assurance.

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Source-document evidence — what the assurance partner expects

The full evidence-document inventory is on Document Evidence Requirements. This section lists the P6-specific items the assurance partner needs at the start of the engagement.

Energy

• Electricity — all utility bills for the financial year, broken by facility. If self-generation: meter readings. If renewable: PPA + Renewable Energy Certificates (RECs) for the market-based reporting line.
• Fuel — monthly fuel consumption register (diesel, petrol, LPG, FO, coal as applicable), reconciled to General Ledger fuel-purchase entries. The reconciliation step is what most entities skip in year one and what the auditor will not skip.
• Other energy sources — biomass receipts, district heating contracts (rare in India).

GHG emissions

• All energy data above (used to derive Scope 1 from fuel and Scope 2 from electricity)
• CEA grid emission factor for the relevant FY — see CEA Grid Emission Factors
• For Scope 1 process emissions (cement clinker, ammonia synthesis, electrolysis): facility-specific emission factors with calibration documentation
• For Scope 1 fugitive emissions (refrigerants): refrigerant top-up records by gas type (HFC-134a, R-410A, etc.)
• Owned vehicle fuel consumption — separate from stationary fuel registers

Water

• Withdrawal by source — utility bills (third-party), borewell meter readings (groundwater), surface-water abstraction permit + flowmeter readings, tanker receipts (where applicable)
• Discharge — sewage treatment plant outflow logs, effluent treatment plant outflow logs, third-party trade-effluent contracts
• Water-stressed-area determination — facility GPS coordinates mapped to a recognised water-stress index (WRI Aqueduct or WBCSD)

Waste

• Waste generated — facility-level waste registers by waste category, signed by EHS officer monthly
• Waste recycled / reused — counterparty receipts (waste-handler invoices, scrap-dealer receipts, transfer notes for hazardous waste under the Hazardous & Other Wastes Rules 2016)
• Disposal — Form-13 returns filed under Hazardous Waste Rules, where applicable

Air emissions (non-GHG)

• Stack monitoring reports from a Pollution Control Board–approved laboratory, by source
• Continuous Emission Monitoring System (CEMS) data, where installed

The single highest-value pre-engagement task is building or reconciling the monthly fuel-consumption register. That one document closes the most common audit qualification on P6.

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Calculation methodology

Scope 1 (direct emissions)

Scope 1 = Σ (Activity data × Emission factor) for each fuel/refrigerant/process source.

For combustion sources, emission factors come from the IPCC 2006 Guidelines for National Greenhouse Gas Inventories, by fuel type. For refrigerants, GWP values come from the IPCC AR5 100-year GWP table (the convention applied by GHG Protocol).

Scope 2 (indirect — purchased electricity)

Scope 2 = Electricity consumed (MWh) × Grid emission factor (tCO₂/MWh).

The grid emission factor is the Central Electricity Authority (CEA) state-wise factor for the facility’s location, for the relevant CEA database version. See CEA Grid Emission Factors for the table and rules.

The GHG Protocol Scope 2 Guidance requires dual reporting:

• Location-based — using the CEA factor for everyone
• Market-based — using PPA factors and REC instruments where contracted, CEA factor where not

BRSR Core assurance covers the location-based number; market-based is disclosed alongside.

Scope 3 (value-chain — Leadership indicator only)

Scope 3 covers the 15 categories of the GHG Protocol Scope 3 Standard. Material categories vary by sector — for service exporters, business travel and purchased goods typically dominate; for manufacturers, purchased goods, transportation, and end-of-life dominate.

Scope 3 is not in BRSR Core assurance scope but is mandatory under Leadership indicators for the Top 1,000.

Water + waste intensities

Both follow the same numerator-over-revenue pattern. The denominator (revenue from operations) must match the audited financial statements — using a different revenue figure here (e.g. net revenue, gross revenue with excise) is an immediate red flag in assurance.

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Sector context — what looks different

Sector	P6 emphasis
Cement, steel, aluminium, fertilisers	Scope 1 process emissions dominate (50-90% of footprint). Reasonable assurance hinges on facility-level emission factors and process-output measurement.
IT services, BPO, KPO	Scope 2 (purchased electricity for offices and data centres) dominates. Renewable PPA contracting is the lever — and if claimed, REC documentation must be airtight.
Banking, NBFCs	Direct footprint is modest (Scope 2 for branches + offices). The Leadership indicator on financed emissions (a Scope 3 category) is becoming the focus area for ESG-rating consistency.
FMCG, Pharma, manufacturing	Mixed — Scope 1 (process + fleet) and Scope 2 both material. Scope 3 (purchased agricultural inputs, packaging) is heavy. Water intensity often the tightest scrutiny in dry regions.

The sector-specific industry guides (in /industries/) cover the operational nuances, common data gaps, and assurance pitfalls per sector — those publish over Phase C Weeks 7-8.

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Common audit findings (the practitioner pattern)

In rough order of how often these appear in BRSR Core assurance qualifications, based on the patterns the BRSR practitioner community has surfaced post-FY 2024-25 filings:

1. Scope 1 fuel register gaps — monthly fuel consumption is not centralised; diesel for DG sets, LPG, owned-vehicle fuel sit in three different places. Result: emission factor applied to incomplete activity data → understated Scope 1.
2. Wrong CEA database version — entity uses the prior year’s CEA emission factor because the new one wasn’t out at the time of internal calculation. Audit re-runs with current version, surfaces a delta. See CEA Grid Emission Factors for which version applies to which reporting year.
3. Renewable PPA without REC documentation — entity claims renewable Scope 2 reduction but cannot produce the REC instrument showing retirement. Audit forces back to location-based factor for the unsupported MWh.
4. Water withdrawal source mis-categorisation — third-party tanker water counted as “surface water” in one disclosure cycle, “third-party water” in the next. Affects intensity calculation across years.
5. Waste-recycled percentage including own re-use — some entities count internal re-use without external waste-handler verification. Auditor expects external counterparty documentation for any “recycled” claim above a threshold.
6. Revenue denominator mismatch — intensity numbers calculated on net-of-tax revenue while the financials report gross. Trivial fix but a clean qualification source.
7. Boundary inconsistency vs financial consolidation — environmental data covers the listed entity only; financial revenue covers the consolidated group. Or vice versa. The boundary must match what the BRSR cover note declares.

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How P6 rolls up into BRSR Core Assurance

The four P6-Core attributes (energy intensity, GHG intensity, water intensity, waste recycled %) are the SEBI-mandated reasonable-assurance scope. The signed assurance report attests these four numbers to the highest assurance level under SAE 3000 (Revised), India’s adoption of ISAE 3000 (Revised).

The remaining P6 disclosures (Essential 1, 3, 4, 6, 7 + all 7 Leadership) are filed as part of the BRSR but are NOT in the Core assurance scope. Many entities still ask the assurance partner to apply limited-assurance procedures over selected non-Core P6 items where lender ESG covenants or international rating agencies (MSCI, Sustainalytics) reference them.

For a separate full-scope GHG inventory verification (Scope 1 + 2 + material Scope 3) under the international ISAE 3410 standard, see ISAE 3410 / Standalone GHG Verification — typically engaged alongside BRSR Core for entities with Western enterprise customers.

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Related reading

• Document Evidence Requirements — full per-attribute evidence checklist
• CEA Grid Emission Factors — Scope 2 factor table by Indian state
• Tally Ledger to BRSR Mapping — how to map fuel-purchase ledger entries to Scope 1
• NGRBC to BRSR Metric Mapping — full P1–P9 to BRSR-format metric crosswalk
• XBRL Taxonomy for BRSR — XBRL element names for P6 disclosures
• BRSR Core Assurance — service
• ISAE 3410 / Standalone GHG — service