Water Stewardship for Indian Listed Entities 2026 — BRSR Principle 6 + SBTN Freshwater + CDP Water + AWS Standard + CGWA Compliance

Corporate water stewardship is the use of water in a way that is socially and culturally equitable, environmentally sustainable, and economically beneficial — achieved through stakeholder-inclusive site and basin actions. It moves beyond compliance-only water management to active engagement with the basin context. For Indian listed entities, 2026 is the inflection point: BRSR Principle 6 has matured into operative disclosure expectation, BRSR Core's Water Footprint attribute requires audit-ready data, India is among the world's most water-stressed economies (per WRI Aqueduct, 17 of 30 most water-stressed cities globally are in India), and the SBTN Freshwater V2 framework (targets available in 2026) is the first global science-based-target architecture for water. The convergence forces a disclosure + management response that's distinct from carbon — the cycles are local, the data is harder, and the stakeholder map is more concentrated.

BRSR Principle 6 (Environment) requires both quantitative disclosure (Section A Essential Indicators) and narrative disclosure (Section C Principle-wise). **Quantitative under Section A:** total water withdrawal by source (surface, groundwater, third-party, seawater desalinated, others) in kilolitres; total water consumption in kilolitres; water intensity per revenue (kL / ₹ crore); details of operations in water-stressed areas (defined by CGWA / Aqueduct mapping). **BRSR Core:** Water Footprint is one of the nine quantitative attributes requiring assessment or assurance — captures water withdrawal intensity per revenue with year-on-year change. **Section C narrative:** approach to water management; water-stressed area operations and mitigation; water reuse / recycling rate; community water management approach; site-level water-stewardship commitments. The SEBI March 2025 amendment also introduced green credits as a Leadership Indicator on Principle 6, which can include credits earned through water-related interventions.

Science Based Targets Network (SBTN) is the consortium led by CDP, WWF, World Resources Institute (WRI), Pacific Institute, and The Nature Conservancy (TNC) — extending the science-based-target architecture beyond climate to nature (freshwater, land, oceans, biodiversity). The SBTN Freshwater Hub publishes Technical Guidance for setting science-based freshwater targets. **Version 1 (current methodology):** focuses on water quantity (withdrawal targets at basin level) and water quality (basic pollution targets), with a basin-prioritisation step using the Step 1 (assess) methodology. **Version 2 (draft 2025, targets available 2026):** expands scope to include groundwater use targets explicitly (a major change for India given CGWA-regulated groundwater dependency) and toxic chemical pollution targets. SBTN-validated targets are increasingly required for CDP A-list scoring on Water Security and for Western enterprise procurement programs that screen on nature targets alongside climate.

Strong alignment, intentionally exploitable. CDP Water Security (one of CDP's three scored themes) covers: water withdrawal volumes by source, water discharge volumes and pollutant data, water-related risks and opportunities, water-related targets and governance, water-stressed-area operations. BRSR Core's Water Footprint attribute captures water withdrawal intensity per revenue; the underlying volumetric data is the same as CDP Water Security feeds. Recommended data architecture: build a single site-level water inventory (withdrawal by source per site + discharge volumes + pollutant concentrations + intensity calculation) under a shared GHG-Protocol-style data taxonomy; feed BRSR Core Water Footprint disclosure, CDP Water Security response, IFRS S1 / S2 (where water is material), ESRS E3 Water (for CSRD-in-scope groups), and SBTN Freshwater target progress from the single source. The CDP 2026 questionnaire (released 27 April 2026) deepened wastewater and pollutant disclosures — see [CDP Reporting India 2026](/methodology/cdp-reporting-india-2026/).

The Alliance for Water Stewardship (AWS) is a global, multi-stakeholder body that publishes the AWS Standard 2.0 — the globally applicable site-level water-stewardship certification standard. AWS certification requires a site (factory, agricultural operation, etc.) to demonstrate good water stewardship across five outcomes: good water governance; sustainable water balance; good water quality status; healthy status of important water-related areas; and safe water, sanitation, and hygiene (WASH) for all. Certification levels: Core (entry), Gold, Platinum. **When to pursue:** sites in water-stressed basins with material throughput; sites supplying Western enterprise customers that screen on AWS certification (Coca-Cola, Diageo, Nestlé, Unilever value chains); sites where stakeholder context (community, NGO, regulator) is contested. **When not to pursue:** small operations in low-stress basins; sites with no value-chain or stakeholder driver. AWS certification is more substantive than ISO 14046 (water footprint) or ISO 46001 (water efficiency) — those are management-system standards, AWS is an outcome-based stewardship standard.

Three regulatory layers an Indian listed entity must comply with before voluntary frameworks are relevant. **Central Ground Water Authority (CGWA):** NOC required for groundwater extraction in notified areas (over-exploited, critical, semi-critical blocks per CGWA classification); annual water-conservation-fee applicable; ban on new groundwater extraction in over-exploited blocks. The CGWA NOC framework underwent significant revisions in recent years and is now digital-first via cgwa-noc.gov.in. **Central Pollution Control Board (CPCB) and State Pollution Control Boards (SPCBs):** consent under the Water (Prevention and Control of Pollution) Act 1974 — Consent to Establish + Consent to Operate; effluent discharge standards by industry category (ranged from 30 mg/L BOD for general industry to industry-specific limits); zero-liquid-discharge (ZLD) mandates for certain industries (textiles, tanneries, distilleries, pulp and paper) in stressed regions. **State-level water-pricing and allocation:** varies — Maharashtra, Karnataka, Tamil Nadu, Gujarat all have specific industrial-water pricing and allocation frameworks. Voluntary stewardship (SBTN, AWS, CDP) is layered on top of mandatory compliance with these three.

For BRSR Core Water Footprint assessment-or-assurance under SAE 3000 (Revised), the practitioner expects: (a) **Site-level water inventory** — withdrawal by source (surface / groundwater / third-party / desalinated / produced water from operations) per site with measurement methodology (metered, calculated, estimated); (b) **Discharge inventory** — volume by destination (surface / sewer / ZLD recycling) with pollutant concentrations where required by CPCB consent; (c) **CGWA NOC documentation** for sites extracting groundwater + payment evidence of water-conservation fees where applicable; (d) **CPCB / SPCB Consent to Operate** with current validity for every operating site; (e) **Water-stressed area mapping** — site list with stress classification (Aqueduct overlay or CGWA block classification) and justification of stress designation; (f) **Reconciliation to financial reporting** — water-related costs disclosed in financial statements should reconcile to the operational water-data inventory; (g) **YoY movement bridge** distinguishing operational reductions from data-quality improvements from divestments / acquisitions. Without (g), water-related YoY claims (e.g. '15% water reduction this year') are not assurable.

TNFD (Taskforce on Nature-related Financial Disclosures) published final recommendations in September 2023, providing the LEAP approach (Locate, Evaluate, Assess, Prepare) for nature-related disclosure across four pillars (Governance, Strategy, Risk Management, Metrics and Targets). Water is one of four realms TNFD covers (alongside land, oceans, atmosphere). For Indian listed entities, the TNFD entry point is typically water — because it's the realm with the strongest BRSR / CDP / regulatory disclosure base already in place. Sequence: build BRSR Principle 6 water disclosure; layer CDP Water Security; set SBTN Freshwater V2 targets; apply TNFD LEAP for the locate + evaluate + assess steps on water — and you have a substantial subset of a TNFD disclosure already complete. TNFD adoption by Indian listed entities is still early (10-15 large-cap entities had piloted at the 2024-25 baseline); the trajectory points toward mandatory or strongly-expected disclosure within 3-5 years. Early adopters get the disclosure narrative under control while the methodology is still being refined.

Five phases, typically 9-15 months end-to-end. **Phase 1 (4-6 weeks): Baseline.** Map operating sites; identify water-stressed sites via Aqueduct + CGWA block classification; document existing CGWA NOCs and CPCB consents; build a site-level water inventory v1 with withdrawal-by-source and discharge data. **Phase 2 (4-6 weeks): Materiality + risk assessment.** Apply TNFD LEAP locate + evaluate steps; identify priority basins; map stakeholder context per priority basin (regulators, community, NGOs, other water users). **Phase 3 (8-12 weeks): Targets.** Set SBTN Freshwater V2 targets where applicable (basin-level water quantity + quality + groundwater). Validate via SBTN process. **Phase 4 (6-8 weeks): Disclosure integration.** Prepare BRSR Principle 6 Section A + Section C content; CDP Water Security response; integrate into IFRS S1 / S2 / ESRS E3 disclosure where applicable. **Phase 5 (4-6 weeks): Assurance.** Engage partner CA firm under SAE 3000 (Revised) for the BRSR Core Water Footprint scope. Output: signed assurance bundled with the broader BRSR Core engagement. Indian companies that have published mature water-stewardship disclosure (HUL, Coca-Cola India, ITC, Mahindra, Hindustan Zinc, NTPC) report 12-18 months from kick-off to first-disclosed inventory.

The Green Credit Programme — notified by the Ministry of Environment, Forest and Climate Change under the Green Credit Rules 2023 — is a market-based instrument for incentivising voluntary environmental actions. Initial scope covers tree plantation and water management; expansion to other domains is staged. Companies can earn or procure green credits by undertaking eligible activities (e.g. afforestation on designated land; water-management interventions in defined hydrogeological areas). The SEBI March 2025 amendment introduced green credits as a new Leadership Indicator under BRSR Principle 6, allowing listed companies to disclose green credits generated and procured. The intersection with water stewardship: water-related green credits earned through interventions (rainwater harvesting at scale, watershed development, aquifer recharge) can be reported under BRSR Principle 6 alongside the rest of the water disclosure. This is a relatively new instrument with limited initial pricing transparency; companies pursuing it should treat it as a voluntary supplement to mainstream water-stewardship architecture, not a substitute.