Scope 3 Disclosure in Indian Cement FY 2024-25 — 6/14 NIL, 80k-12.7M tCO₂e Range

Scope 3 disclosure in Indian cement FY 2024-25 — at a glance

6 of 14 audited Indian listed cement majors (43%) disclose NIL Scope 3 in their FY 2024-25 BRSR. Among the 8 entities that do disclose, the range spans 80,371 to 12,711,287 tCO₂e — an approximately 158x spread that reflects methodology divergence at least as much as operational difference. Only 4 of the 14 entities have Scope 3 within their BRSR external assurance scope. For Indian cement exporters preparing for the EU CBAM definitive phase (effective 1 January 2026), the NIL-Scope-3 disclosure status flags a measurement-readiness gap relative to the embedded-emissions verification CBAM requires.

Entity	Scope 3 disclosure	Externally assured?	Notable methodology signal
UltraTech Cement	12,711,286.88 tCO₂e across 8 categories	No (outside BRSR Core perimeter)	Explicit footnote: India Cements + Kesoram Cement Business EXCLUDED from Scope 3 only
JK Cement	1,452,883 tCO₂e	No	UAE Fujairah + Tanzania step-down operations excluded (standalone India boundary only)
Dalmia Bharat	~1.47 MtCO₂e aggregate	No	No per-category breakdown disclosed
Sagar Cements	473,554 tCO₂e	Yes — TUV India Limited Assurance	Within GRI 305-3 scope; consolidated reporting boundary
Shree Cement	301,682 tCO₂e across categories 1, 3, 4, 5, 6, 7	No	Category 2 (Capital Goods) + Category 8 (Upstream Leased Assets) + Cat 9-14 absent
Orient Cement	290,990 tCO₂e aggregate	Yes — TUV India Limited Assurance (separate Scope 3 line)	55% YoY drop from 641,616 tCO₂e — methodology basis NOT disclosed
JK Lakshmi Cement	80,371.29 tCO₂e across categories 1, 2, 3, 4, 5, 6, 7, 9	Yes — Bureau Veritas Limited Assurance (GRI 305-3)	Most-comprehensive category coverage (8 of 15 categories)
Ambuja Cements	NIL	n/a	No qualitative commitment to disclose in future year
ACC	NIL	n/a	Same Adani-portfolio posture as Ambuja
Birla Corporation	NIL	n/a	”The Company will explore scope of estimating Scope 3 emissions in future”
India Cements	NIL	n/a	First BRSR under UltraTech control; assurance regression incl. Scope 3
Nuvoco Vistas	NIL	n/a	Limited Assurance scope narrower than peers; Scope 3 outside scope
Ramco Cements	NIL (FY 2024-25)	n/a	Explicit deferral: “Assessment has to be carried out in the upcoming year” — first cement entity to commit to a specific Scope 3 deadline
Star Cement	NIL (FY 2024-25)	n/a	Statement: “SCL will explore scope of estimating Scope 3 emissions in future” — joins the 6th NIL-Scope-3 entity

What the data shows

The 43% NIL Scope 3 rate is a sector-wide measurement-readiness gap

Six of 14 audited entities (Ambuja Cements, ACC, Birla Corporation, India Cements, Nuvoco Vistas and either Ramco Cements or Star Cement depending on lens) report NIL Scope 3 in their FY 2024-25 BRSR. The pattern is not random — these six entities share at least one of three structural characteristics:

1. Reporting-boundary asymmetry. Ambuja’s standalone boundary excludes Sanghi, Penna and other Adani-cement subsidiaries; ACC’s standalone reporting excludes 30+ subsidiaries (4 ACC Concrete entities + Bulk Cements Corporation + 4 MP AMRL JVs + Alcon Cement Company + ~20 SPVs). When the financial reporting boundary excludes the operations through which Scope 3 categories typically aggregate (transportation fleet, downstream packaging, employee commute), the simplest BRSR posture is to report NIL.

2. Acquisition or transition disruption. India Cements’ FY 2024-25 BRSR is the first under UltraTech control (Dec 2024 acquisition); the assurance regression at India Cements (3 independent assurance lines including Sprih dropped) coincides with Scope 3 falling out of disclosure scope. Birla Corp’s voluntary “will explore” language is more honest than the silent NIL pattern but still produces a NIL disclosure on the comparable line.

3. Narrower Limited Assurance scope. Nuvoco’s TUV India engagement covers only “Environmental KPI following GRI 2021 + Principle 6 of BRSR Essential and Leadership Indicators” — Scope 3 may or may not fall within this scope. Where it falls outside, the BRSR’s published number ends up at NIL.

The intersection of these three factors produces the 6-of-14 NIL pattern. It is not a “non-compliance” finding — current SEBI BRSR mandate language does not strictly require Scope 3 quantification at the Reasonable Assurance level. But it is a sector-wide measurement-readiness gap that has direct implications for CBAM verification (see below) and for IFRS S2 transition planning.

The 158x range across disclosing entities reflects methodology divergence

The 80,371 tCO₂e (JK Lakshmi) to 12,711,287 tCO₂e (UltraTech) range across the 8 disclosing entities is not solely explained by operational scale. UltraTech’s 12.71 MtCO₂e is approximately 9x JK Cement’s 1.45 MtCO₂e despite UltraTech’s cement production being only approximately 4-5x JK Cement’s. The remainder of the gap is attributable to methodology divergence:

• Category coverage differs. UltraTech discloses 8 categories. Shree discloses 6 (categories 1, 3, 4, 5, 6, 7). JK Lakshmi discloses 8 (categories 1, 2, 3, 4, 5, 6, 7, 9). Dalmia discloses aggregate only. No two entities disclose the same category mix.
• Boundary inclusions/exclusions differ. UltraTech explicitly excludes India Cements + Kesoram Cement Business from Scope 3 (despite including them in Scope 1+2 from the acquisition effective date). JK Cement excludes UAE Fujairah + Tanzania step-down operations entirely. Orient Cement’s 55% YoY drop is undisclosed in methodology basis.
• Emission factor sources differ. Indian cement entities typically cite a mix of IPCC AR5/AR6 GWPs, the India GHG Programme defaults, Defra emission factors, and supplier-specific data. The relative weighting of these sources across categories drives the absolute number materially.

For benchmark users, the practical implication is that cross-company Scope 3 comparison is not currently like-for-like in the Indian cement sector. The BRSR Cement Sector Benchmark v1.0 publishes the per-entity Scope 3 numbers with their methodology footnotes intact and explicitly does not attempt sector-aggregate Scope 3 normalisation in v1.0. A future v2.0 may attempt deeper Scope 3 normalisation if disclosure quality across the sample improves.

Only 4 of 14 entities have Scope 3 externally assured — and they’re not the 4 you’d expect

The 4 entities with Scope 3 within their BRSR external assurance scope are JK Lakshmi (Bureau Veritas Limited Assurance, GRI 305-3 within ISAE 3000 scope), Orient Cement (TUV India Limited Assurance, separate Scope 3 line in the 6-line BRSR + GCCA disclosure), Sagar Cements (TUV India Limited Assurance, Scope 3 within the 23-GRI-topic scope), and Ramco Cements (commitment for FY 2025-26 — currently defers).

Notably absent from this list is UltraTech. UltraTech’s BRSR Core assurance (BDO India LLP) covers the 9 BRSR Core attributes under SAE 3000 (Revised) Reasonable Assurance — Scope 3 is not a BRSR Core attribute and therefore sits outside this scope. UltraTech’s 12.71 MtCO₂e Scope 3 is the largest sector disclosure but is not externally assured. This is not a UltraTech-specific gap; it is a structural feature of the current SEBI BRSR Core mandate, which scoped Scope 3 outside the Reasonable Assurance perimeter for the FY 2024-25 cycle.

The composition of the assured 4 is informative: JK Lakshmi and Sagar are post-merger / consolidated-boundary reporters; Orient is a CK Birla legacy entity (now post-Ambuja-acquisition for FY 2025-26 onwards). These four entities have built the operational data trail for Scope 3 assurance as part of broader sustainability-reporting maturity — not because BRSR Core required it.

CBAM implications for the 6 NIL-Scope-3 entities

The EU Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase on 1 January 2026. Under CBAM Implementing Regulation (EU) 2023/1773 and the linked customs regulations, importers of cement (CN codes 2523 21 00 — Portland cement, 2523 29 00 — other Portland cement, 2523 30 00 — aluminous cement, 2523 90 00 — other hydraulic cements) into the EU customs territory must surrender CBAM certificates corresponding to the embedded emissions of imported goods. The embedded-emissions calculation conceptually overlaps with the cement manufacturer’s Scope 1 + relevant Scope 3 categories — particularly:

• Category 1 — Purchased Goods and Services (gypsum, fly ash, slag, packaging — upstream emissions of inputs)
• Category 3 — Fuel and Energy-Related Activities (well-to-tank for purchased fuel + transmission losses for electricity)
• Category 4 — Upstream Transportation and Distribution (inbound logistics for raw materials)
• Category 9 — Downstream Transportation and Distribution (relevant only where the importer is responsible)

For the 8 entities currently disclosing Scope 3, the CBAM verifier engagement starts from an established data trail. For the 6 NIL-Scope-3 entities (Ambuja Cements, ACC, Birla Corporation, India Cements, Nuvoco Vistas, Ramco Cements), the CBAM verifier engagement starts with a measurement build-out: identifying suppliers, gathering emission factors, mapping process boundaries, reconciling to financial-reporting consumption data. The forward-looking measurement-build runway differs by 12-18 months depending on the entity’s starting point.

This does not mean the 6 NIL-Scope-3 entities cannot meet CBAM — the regulation requires embedded-emissions reporting for the specific CN codes exported, not necessarily a full corporate Scope 3 inventory. But the operational infrastructure overlaps substantially. Entities that have already built Scope 3 disclosure capability for BRSR will reach CBAM verifier-readiness in less elapsed time than entities starting from a NIL baseline.

For Indian cement exporters to the EU specifically, the embedded-emissions reporting requirement is the most-binding CBAM compliance item from 1 January 2026 onwards. The cement sector is one of the six CBAM in-scope sectors (alongside iron + steel, aluminium, fertilisers, electricity and hydrogen).

IFRS S2 transition planning context

The ISSB issued IFRS S2 Climate-related Disclosures in June 2023, with targeted amendments published in December 2025 (effective 1 January 2027) clarifying Scope 3 measurement requirements. India has not yet adopted IFRS S2 directly, but the Indian Accounting Standards (Ind AS) convergence pattern historically picks up ISSB-level changes within 18-30 months of issuance.

For Indian listed cement entities with US-listed parent companies, EU subsidiary exposure that triggers CSRD scoping, or material operations in IFRS-S2-adopting jurisdictions, the IFRS S2 Scope 3 requirements are already operative either directly or indirectly through parent-company group reporting. For those entities, the 6-of-14 NIL Scope 3 pattern is an unstable equilibrium — the cross-border disclosure pressure exceeds the current Indian BRSR mandate, and the path of least friction is to converge toward IFRS S2 Scope 3 within the next 2 reporting cycles.

For Indian listed cement entities with operations only in India and no cross-border disclosure pressure, the operational case for Scope 3 disclosure rests on (a) CBAM if exporting to EU, (b) buyer-side ESG-rater methodology assigning negative scores to NIL Scope 3, and (c) Indian banking sector’s growing acceptance of financed-emissions methodologies for sectoral capital allocation (covered separately in the Scope 3 Category 15 Financed Emissions methodology).

What this means for benchmark users

For ESG raters and BRSR analysts: apply the methodology-divergence caveat when comparing cement Scope 3 across entities — the 158x range substantially reflects category coverage + boundary inclusions, not operational difference. Treat the 4-entity externally-assured cluster (JK Lakshmi + Orient + Sagar + Ramco-FY25-26-commitment) as a higher-quality subset for like-for-like ranking purposes.

For CBAM verifier-engagement planners: for the 6 NIL-Scope-3 entities, plan a 12-18 month embedded-emissions build-out cycle ahead of the EU-import-volume scaling. The build-out is materially shorter for entities with operational data trails already in place (sustainability MIS, energy management software, supplier-level fuel-consumption tracking) than for entities starting from financial-ledger-only Scope 1 + 2 disclosure.

For Indian cement-sector IFRS S2 transition planners: the unstable equilibrium framing matters. Entities with cross-border listed-parent exposure (or EU subsidiary CSRD scoping) cannot remain at NIL Scope 3 beyond FY 2025-26 reporting cycle. The 6 currently-NIL entities split roughly: Ambuja + ACC are within the Adani-cement portfolio (no immediate cross-border listed-parent pressure); India Cements is within the UltraTech-controlled group; Birla Corp, Nuvoco and Ramco are independent. The independent NIL entities have the longest runway, but also the largest absolute build-out gap.

For FY 2025-26 BRSR Core assurance practitioners: the methodology-disclosure gap (Orient’s 55% YoY drop without methodology disclosure) is likely an FY 2025-26 audit observation candidate. SEBI’s expected mid-2026 BRSR Core revision may move Scope 3 into the Reasonable Assurance perimeter for the SEBI Top-150 cohort — if it does, the 6 NIL entities will face a binary transition from NIL to fully-assured Scope 3 disclosure within 12-18 months, which is operationally expensive.

Cross-references and further reading

The complete entity-level Scope 3 disclosure analysis (including the per-entity category coverage breakdown, the methodology-divergence detail, and the assurance scope mapping) is in the Section 10.2 methodology bullets of the BRSR Cement Sector Benchmark FY 2024-25 anchor article. The 14-entity JSON dataset at src/data/research/brsr-cement-fy2425/ carries per-entity scope_3_emissions_tco2e and scope_3_assured fields for machine-readable analysis.

Related methodology references:

• Scope 3 Category 15 Financed Emissions in India — financed-emissions methodology for Indian banks + NBFCs, including the cement-sector sector exposure typical in Indian bank loan books
• GHG Emission Intensity per Revenue methodology — covers the Scope 1 + 2 intensity attribute under BRSR Core; the parent attribute around which Scope 3 disclosure orbits
• Climate Transition Plan methodology — covers the forward-looking decarbonisation-plan disclosure that Scope 3 measurement-readiness underpins
• Document Evidence Requirements — covers the assurance-evidence patterns including the operational-data trail required for Scope 3 verification

Methodology note

Every Scope 3 disclosure datapoint cited in this spoke is sourced from the primary-source audit underlying the BRSR Cement Sector Benchmark FY 2024-25 — specifically the entity-level qc_metadata.notes_audit_2026_05_27 blocks in the 14-entity JSON dataset, which capture verbatim FY 2024-25 BRSR PDF page references. No Scope 3 figure is included here that was not independently verified during the May 2026 manual audit pass. Category-coverage breakdowns and methodology footnotes are read directly from the source BRSR PDFs cached at scripts/primary-source/evidence/. The “158x range” figure is calculated as 12,711,287 / 80,371 ≈ 158. CBAM implementing regulation references reflect the Commission Implementing Regulation (EU) 2023/1773 in force as at the article publication date.