NGRBC Principle 7 (Public Policy and Regulatory Process) — BRSR Disclosures, Trade Affiliations + Anti-Competitive Conduct

What Principle 7 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 7 covers responsible engagement in public policy and regulatory processes — the principle that businesses, when engaged in influencing public and regulatory policy, should do so in a manner that is responsible and transparent.

Principle 7 is structured around three operational areas of business-government engagement:

1. Trade and industry chamber affiliations — disclosure of the entity’s memberships in business associations through which it engages collectively with regulators and policymakers
2. Public-policy advocacy positions — disclosure of policy positions the entity actively advocates for, including the methods of advocacy and the public availability of those positions (Leadership)
3. Anti-competitive conduct — disclosure of corrective action taken on adverse regulatory orders related to anti-competitive conduct, typically Competition Commission of India (CCI) orders under the Competition Act 2002

The contextual legal background for many P7 disclosures is the broader Indian governance regime — the Competition Act 2002 (governing anti-competitive agreements, abuse of dominance, and merger control), the Companies Act 2013 Section 182 (governing political contributions by companies), the Lobbying / advocacy framework (largely informal and self-regulated in India; no statutory disclosure regime analogous to the US Lobbying Disclosure Act), and the Representation of the People Act 1951 Section 29A (defining registered political parties — the only permissible recipients of corporate political contributions). These are background for interpretation; the BRSR P7 disclosures themselves are governed by the SEBI BRSR Format and the Industry Standards on Reporting of BRSR Core (December 2024) circular.

This page is the reference hub for Batchwise’s coverage of P7.

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No BRSR Core KPI under Principle 7

Unlike Principles 1, 3, 5, 6, and 8 — which each have one or more BRSR Core KPIs in the reasonable-assurance set — Principle 7 has no BRSR Core KPI. All P7 disclosures are Essential or Leadership.

This places P7 alongside Principle 2 (Sustainable Products) and Principle 4 (Stakeholder Engagement) as a no-Core-KPI principle. The Core attributes cluster under operational ESG areas where:

• The underlying data is typically already captured in statutory / regulatory compliance systems (payroll for P3 / P5 wage and POSH metrics; environmental compliance for P6 GHG and water; RBI / NIC data for P8 small-town job creation; related-party records for P1 Openness)
• The metric is amenable to standardised methodology and reasonable-assurance procedures

P7 disclosures involve more applicability-judgement and entity-specific narrative (which trade affiliations to list in the top 10, which policy positions to disclose at the Leadership level, how to characterise corrective action on regulatory orders). They remain meaningful for stakeholder use — they signal the entity’s posture on regulatory engagement and competition compliance — but they are not in the Core reasonable-assurance mandate.

Entities that want third-party verification of selected P7 disclosures (commonly the trade-affiliations list or the anti-competitive-conduct corrective-action narrative) can scope this as an extended-scope assurance engagement separate from BRSR Core.

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The Essential indicators (mandatory for every BRSR filer)

The BRSR format Section C, Principle 7 Essential indicators cover the items below — illustrative paraphrases; the SEBI BRSR format itself is the authoritative source for the exact wording and reporting structure of each indicator:

Trade and industry chamber affiliations

The disclosure asks the entity to report:

• Total number of trade and industry chamber / association affiliations the entity holds
• List of the top 10 affiliations, with the reach (national, state, regional, international) of each

In published Indian BRSR submissions, the top-10 list commonly features:

• Cross-sector chambers (national reach) — CII (Confederation of Indian Industry), FICCI (Federation of Indian Chambers of Commerce and Industry), ASSOCHAM (The Associated Chambers of Commerce and Industry of India), PHDCCI (PHD Chamber of Commerce and Industry)
• Sector-specific national associations — NASSCOM (IT services), SIAM and ACMA (automotive OEM and components), IBA (Indian Banks’ Association), IPA / OPPI (pharma), AIFI / FIDC (NBFCs), CMA (cement), FIEO (exporters), IDMA (Indian Drug Manufacturers), AMFI (mutual funds), CII-CEA (energy), IESA (electronics and semiconductor)
• Regional or state chambers — BCIC (Bangalore), Bombay Chamber, MCCI (Madras Chamber), Indo-American Chamber, IndUS Business Council, etc.
• International chambers — Federation of Indian Export Organisations linked international bodies; sector-specific international associations (e.g., WSA World Steel Association for integrated steel entities; ICCA International Council of Chemical Associations for chemicals; GCCA Global Cement and Concrete Association for cement)

The “top 10” framing is the entity’s call on which affiliations are most material to disclose — typically anchored on strategic importance, board-level oversight of the relationship, or quantum of contribution paid.

Anti-competitive conduct — corrective action on adverse orders

The disclosure asks the entity to report corrective action taken or underway based on adverse orders from regulatory authorities on issues related to anti-competitive conduct. In practice, this typically references orders from the Competition Commission of India (CCI) under the Competition Act 2002.

CCI’s enforcement areas relevant to BRSR P7 disclosure:

• Section 3 — anti-competitive agreements (horizontal cartels, vertical agreements with anti-competitive effect)
• Section 4 — abuse of dominant position
• Sections 5, 6, 31 — combination and merger control

The disclosure for each adverse order typically includes:

• The CCI order reference and date
• The issue (cartelisation, abuse of dominance, anti-competitive agreement, merger-control violation)
• The corrective action — payment of penalty, cease-and-desist compliance, behavioural commitments, structural divestments
• Current status — compliance complete, appeal pending before COMPAT / NCLAT / Supreme Court, settlement underway

Where the entity has no adverse anti-competitive-conduct orders during the reporting year, the response is “Not applicable” with a brief substantiating note — typically referencing that there are no pending or recently passed CCI orders against the entity in the reporting period.

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The Leadership indicators (Top 1,000 listed entities)

The Leadership indicators below are part of the BRSR format for the Top 1,000 listed entities, and voluntary for entities outside the Top 1,000.

The Leadership indicators are outside the BRSR Core KPI assurance set — since P7 has no Core KPI at all, P7 is entirely Essential + Leadership. The Leadership disclosures form the more detailed narrative around the entity’s public-policy positioning; entities can request limited-assurance procedures over selected Leadership items as an extended-scope engagement (a separate matter from the BRSR Core mandate).

Public-policy advocacy positions

For each policy position the entity actively advocates for, the Leadership disclosure asks for:

• Name of the policy advocated — for example, “FAME-III scheme for accelerated EV adoption” (automotive); “Production-Linked Incentive (PLI) scheme expansion for electronics manufacturing”; “GST simplification for MSME exemption threshold”; “Sustainable finance taxonomy harmonisation”; “Battery Waste EPR Rules amendment”
• Method advocated — direct engagement with the Ministry, industry-association-led representation, public consultation response, working-group participation, policy paper publication, opinion-piece or thought-leadership content
• Whether the entity’s advocacy position is in the public domain — yes / no
• Frequency of review of the policy position by the board or a board-delegated committee
• Web-link where the policy position is publicly available

Indian listed entities that disclose advocacy positions commonly anchor them on operational or strategic interests — for example, automotive OEMs advocating for FAME / PLI / EV-supportive policies; pharma entities advocating for pricing and patents regime stability; renewable-energy entities advocating for stable RPO obligations and a predictable PPA framework; financial-services entities advocating for taxation and regulatory clarity.

The disclosure is most meaningful when the entity is honest about which positions it actively advocates and which it does not — not when it manufactures an exhaustive list to appear comprehensive. Stakeholders read the Leadership disclosure looking for substantive advocacy patterns, not for completeness ticks.

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P7 and political contributions — what BRSR requires (and what it does not)

A frequent area of confusion: BRSR Principle 7 disclosures do not specifically require itemised disclosure of political contributions or lobbying expenditure as such. Political-contribution disclosure is governed separately by other Indian frameworks:

• Section 182 of the Companies Act 2013 — permits Indian companies (other than government companies and companies less than 3 financial years old) to make political contributions, subject to: a board-resolution approval; contribution only to political parties registered under Section 29A of the Representation of the People Act 1951; disclosure in the profit-and-loss account of the contribution amount and the recipient party.
• Electoral Bond Scheme — a previously used route for political contributions by companies, struck down by the Supreme Court of India on 15 February 2024 in Association for Democratic Reforms vs Union of India. The scheme is no longer operative.
• Electoral Trust route — companies can contribute to Electoral Trusts registered with the CBDT under the Electoral Trusts Scheme 2013; the Electoral Trust then distributes to political parties. The contributing company discloses contribution to the Electoral Trust (not to the ultimate recipient party) in its accounts.

India does not currently have a statutory lobbying-disclosure regime analogous to the US Lobbying Disclosure Act 1995 (which requires registered lobbyists to file detailed disclosures of clients, expenditures, and issues lobbied). Trade-association engagement and advocacy through industry chambers serves as the primary collective-advocacy mechanism. Some BRSR-reporting entities voluntarily disclose lobbying-related expenditure under P7 Leadership narrative as a transparency step, but it is not a SEBI-prescribed item.

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P7 and the broader Indian regulatory engagement landscape

P7 disclosures should be read alongside the broader Indian regulatory framework within which the entity operates:

• Competition Act 2002 — CCI enforcement on anti-competitive conduct (the direct anchor for the Essential anti-competitive disclosure)
• Sector-specific regulators — RBI (banking, NBFCs, payments), IRDAI (insurance), SEBI (capital markets), TRAI (telecom), PNGRB (gas), CERC + state ERCs (electricity), CDSCO (drugs), FSSAI (food safety), DGCA (aviation) — relevant for industry advocacy via sector chambers
• MeitY / DPIIT / Department of Commerce — policy ministries that interface with industry on PLI, FAME, ease-of-business, FDI, export incentives
• Parliamentary Standing Committees — entities or their trade associations regularly submit memoranda to relevant Standing Committees on draft legislation
• NITI Aayog — policy think-tank that hosts cross-sector consultations on industrial policy, sustainability, and ease-of-business

The Leadership disclosure on public-policy advocacy positions allows the entity to anchor its engagement narrative on these specific touchpoints — not in abstraction.

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Evidence checklist for assurance preparation

For an assurance engagement that includes P7 disclosures within its scope (whether as part of an extended-scope BRSR Core engagement or a standalone P7 limited-assurance engagement), the evidence the assurance provider typically expects includes:

• Trade and industry chamber affiliation register — full list with affiliation dates + contribution amounts + the entity’s basis for ranking the top 10
• Board / committee minutes referencing key affiliations + advocacy positions
• CCI / regulatory order register — chronological list of adverse and pending orders, with copies of orders, corrective-action plans, and current status
• Memoranda / consultation responses / position papers submitted to ministries, regulators, Parliamentary committees, NITI Aayog
• Board / committee minutes documenting review of public-policy advocacy positions (relevant for the Leadership disclosure on frequency of review)
• Reconciliation of P7 fines / penalties references with the broader P1 fines-and-penalties disclosure (the same CCI order may reference in both)
• Section 182 political contribution register + board resolutions + P&L disclosure (where applicable)
• Electoral Trust contribution register (where applicable)

See the broader Document and Evidence Requirements guide for the cross-principle evidence framework.

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How P7 disclosures interact with other principles

P7 sits at the intersection of three governance and conduct principles:

• P1 (Ethics, Transparency, Accountability) — the fines-and-penalties Essential disclosure under P1 commonly references the same CCI orders that flow into P7’s anti-competitive-conduct corrective-action disclosure. Cross-references between the two narratives are common and helpful.
• P9 (Customer Value) — industry-policy engagement on customer-facing topics (data protection, consumer protection, product safety) sits at the P7 / P9 boundary. Advocacy positions on data-protection policy (e.g., DPDP Act 2023 implementation), advertising standards (ASCI Code), or consumer-protection rules typically reference both P7 (advocacy) and P9 (customer-facing impact).
• P2 (Sustainable Products) — advocacy positions on EPR rules (Plastic Packaging, E-Waste, Battery, draft ELV) or on sectoral sustainability standards (FAME for EVs, BEE for appliances) often anchor at the P2 / P7 boundary — the underlying policy interest is in product-design or product-sustainability outcomes, but the advocacy mechanism is P7.

For the cross-principle map, see the NGRBC Principles to BRSR Metric Mapping reference.

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How Batchwise fits

Batchwise coordinates BRSR Core Assurance through its partner CA firm network — Core focuses on the assured Core KPIs (none under P7). For entities seeking an extended-scope engagement that includes limited assurance over selected P7 disclosures (typically the trade-affiliations list or the anti-competitive-conduct corrective-action narrative), Batchwise coordinates this as an add-on scope with the partner CA firm.

See also: Materiality Assessment Walkthrough for the upstream scoping step that drives which disclosures the engagement focuses on, and the Document and Evidence Requirements guide for the artifacts framework.