Water Withdrawal Intensity per Rupee of Revenue — BRSR Core Attribute

What this attribute is

Water Withdrawal Intensity per Rupee of Revenue is one of the nine BRSR Core attributes that SEBI requires every Top-1,000 listed entity to subject to independent reasonable assurance. It sits within NGRBC Principle 6 — Environment alongside the GHG, energy, and waste-recycled Core attributes.

Water intensity matters disproportionately for sectors operating in water-stressed regions — cement, steel, thermal power, chemicals, textiles. For these entities, even a modest absolute withdrawal can carry substantial regulatory and stakeholder scrutiny. For service-sector entities (IT, BPO, banking) the absolute number is small but the disclosure is no less mandatory.

The attribute structure mirrors GHG Emission Intensity per Revenue — same PPP-adjusted denominator, same boundary alignment requirement, same cross-year comparability framework.

Formula and units

Water Intensity = Total water withdrawal (in kilolitres)
               ÷ (Total Revenue from Operations adjusted for PPP)

The SEBI BRSR Core wording is Total water withdrawal divided by Total Revenue from Operations adjusted for PPP. The PPP adjustment uses a published conversion factor (typically the World Bank International Comparison Program factor for India) so the resulting intensity is internationally comparable across geographies — same convention as the GHG intensity attribute.

Withdrawal is measured in kilolitres (KL) = 1,000 litres = 1 cubic metre. Some entity-internal dashboards report in cubic metres or megalitres for operational convenience; the SEBI BRSR format uses kilolitres.

The numerator: Total water withdrawal

Water withdrawal is the gross volume of water taken into the entity’s boundary from external sources during the reporting period. The BRSR Principle 6 source taxonomy breaks withdrawal into five categories:

Source category	What counts
Surface water	Rivers, lakes, reservoirs accessed under a state-issued surface-water abstraction permit
Groundwater	Borewells, tube wells, dug wells operated on entity-controlled property
Third-party water	Municipal supply via utility connection, tanker-supplied water, water from a private supplier under contract
Seawater / desalinated water	Direct seawater intake for cooling, desalinated water consumed
Other sources	Anything not captured above (e.g., produced water from on-site processes, reclaimed wastewater purchased from a third party)

Each category is reported separately in the BRSR Section C, Principle 6 Essential Indicator 4. The Core intensity uses the total withdrawal across all categories — the per-category split is for the qualitative narrative, not the assured intensity figure.

What’s NOT in withdrawal

Three things commonly get confused into the withdrawal totals — none of them belong:

• Recycled or re-used water inside the boundary. SEBI’s BRSR Principle 6 text distinguishes water withdrawn (gross intake from external sources) from water consumed (which it frames as input minus output). Internal recycled or re-circulated water is not a fresh withdrawal — only the original gross intake from outside the boundary counts. If your facility recycles 40% of process water, withdrawal is still the gross external intake; the recycling rate is reported separately under the Principle 6 essential indicators.
• Rainwater harvested on the entity’s own property. The verified SEBI BRSR text does not explicitly address rainwater harvesting in the withdrawal definition. Treat rainwater harvesting per the entity’s documented policy, disclose the approach in the BRSR notes, and apply it consistently year-on-year. Many entities disclose harvested rainwater as a separate sustainability-narrative item under leadership indicators rather than in withdrawal totals — but the convention is the entity’s, not a settled regulatory rule.
• Steam returned to a closed-loop boiler system. Steam consumed and condensed back into the same loop is not a fresh withdrawal — only make-up water added to compensate for losses counts.

Source category nuances

A few category-classification questions that come up routinely in first-year BRSR engagements. The classifications below stay close to SEBI’s named source-categories without inventing election rules:

Situation	Correct classification
Municipal piped water	Third-party water
Tanker-supplied water	Third-party water
Borewell on leased land used by the entity	Groundwater (if extracted by the entity)
Surface water drawn from a river / irrigation channel under permit	Surface water
Seawater intake for cooling	Seawater / desalinated water (discharge reported separately)
Purchased reclaimed wastewater	Third-party water if bought from an external provider; “other” only if it does not fit any of the named categories

The single most common classification error: tanker water counted as surface or groundwater because the entity reasoned about where the tanker filled up rather than how the entity itself acquired the water. The right test is the entity’s procurement boundary — if the entity received the water from a contractor, municipal utility, or tanker operator, it belongs in third-party water even if that supplier originally drew from a river or borewell elsewhere.

The denominator: Revenue with PPP adjustment

The denominator follows the same convention as the GHG intensity attribute — Revenue from Operations from the audited Statement of Profit and Loss, adjusted for Purchasing Power Parity using a published PPP conversion factor.

See the GHG Emission Intensity per Revenue page for the four denominator rules (exact match to financials, boundary alignment with numerator, apply PPP, no restatement for non-recurring items). Both BRSR Core intensity attributes share the same denominator basis so the values are directly comparable across attributes for the same entity-year.

Boundary

The boundary for the numerator must match what the BRSR cover note declares. The verified SEBI BRSR Core text does not mandate a single consolidation basis for water disclosures (operational control vs financial control vs equity share); the entity’s choice should be a documented governance decision and applied consistently across the numerator (water withdrawal), the denominator (revenue from operations), and across reporting years. The GHG Protocol boundary conventions are widely cited in Indian listed-entity governance policies as the reference framework, but the choice itself is the entity’s to make and disclose.

For groundwater on leased land used by the entity: the borewell is treated as a withdrawal source if extracted by the entity for its own operations, regardless of land ownership. This is a classification call (it goes into the groundwater category, not third-party) rather than a boundary call.

Worked example

Illustrative only — not representative of a typical company. BRSR water intensity varies dramatically by sector, process, and recycling rate (a thermal power plant and an IT services company can differ by several orders of magnitude). The numbers below are constructed to make the calculation structure clear; an actual filing must use the entity’s documented source classifications and metering data with full audit-trail.

Same diversified mid-cap manufacturer used in the GHG intensity worked example — declared operational-control boundary, standalone listed entity, FY 2024-25:

Step 1 — Total water withdrawal by source

Source	Volume (KL)	Notes
Surface water (river abstraction permit)	12,400	Maharashtra plant, monsoon-fed reservoir downstream
Groundwater	8,650	Borewells across both plants, totaliser meter readings
Third-party water (municipal + tanker)	4,200	Includes 1,150 KL summer tanker top-up at Tamil Nadu plant
Seawater / desalinated	0	Neither plant is coastal
Other sources	0	No reclaimed wastewater purchased this year
Total withdrawal	25,250

(Internal recycling of 6,100 KL of process water is reported separately as part of the Principle 6 recycling-rate disclosure — not subtracted from the withdrawal figure above.)

Step 2 — Numerator

Total water withdrawal = 25,250 KL

Step 3 — Denominator (with PPP adjustment, same as GHG intensity page)

Step	Value
Revenue from operations (audited, standalone)	₹1,847 Cr
World Bank India PPP conversion factor (illustrative, FY 2024-25)	~22 INR per international dollar
PPP-adjusted revenue	1,847 ÷ 22 ≈ ₹83.95 Cr equivalent (in PPP-adjusted terms)

Step 4 — Intensity

Water Intensity = 25,250 KL ÷ 83.95 (PPP-adjusted Cr) ≈ 300.8 KL per PPP-adjusted ₹ Cr

The BRSR XBRL filing carries this value in the relevant taxonomy element (verify the current MCA-published BRSR taxonomy for the exact element name and unit reference) with both current-year and previous-year values populated, and the per-source split filed alongside under the Section C, Principle 6 Essential Indicator 4 elements.

Common audit findings specific to this attribute

In rough order of frequency observed in post-FY 2024-25 BRSR Core assurance engagements:

1. Tanker water mis-classified as surface or groundwater. The entity reasons about where the tanker filled up rather than the procurement boundary. Auditor reclassifies to third-party; per-source totals shift even though aggregate withdrawal is unchanged.
2. Recycled water double-counted into withdrawal. Internal recycled-process-water volumes get added to “groundwater” or “third-party” category in error, inflating withdrawal. Auditor reconciles to source-meter readings, surfaces the over-statement.
3. Borewell metering gaps. Some plants don’t have a totaliser meter on every borewell — the volume gets back-calculated from estimated usage, with no audit-trail. Auditor either accepts with disclosure of the estimation basis or qualifies if the gap is material.
4. Boundary mismatch with denominator. Water data covers all operating facilities (including unlisted subsidiaries treated as operational-control); revenue figure is standalone listed entity only. Same pattern as the GHG intensity attribute.
5. Discharge counted as a deduction from withdrawal. Withdrawal is gross intake; discharge is reported separately. Discharge cannot net withdrawal in the BRSR Core intensity calculation.
6. Cooling-tower make-up water under-captured. This is a common operational data-capture gap rather than a SEBI-recognised category of finding: for thermal-process plants, evaporative cooling losses can be a large single water draw and the make-up volumes often sit in maintenance / O&M records rather than the centralised EHS register. Surfacing it during reconciliation depends on whether the maintenance-system records are pulled into the assurance scope.

Water-stressed-area reporting — Leadership, not Core

Water withdrawal in areas of water stress is a Principle 6 Leadership indicator (mandatory disclosure for the Top 1,000 listed entities) — but it is not part of the BRSR Core assurance scope. The assured intensity is built on total withdrawal across all facilities regardless of water-stress location.

If your operations include facilities in water-stressed regions, the Leadership-indicator disclosure references a recognised water-stress index (WRI Aqueduct, WBCSD Global Water Tool, or equivalent) and reports withdrawal/consumption/discharge separately for those facilities. The methodology choice (which index, which threshold) is itself disclosed.

The assurance partner will sometimes apply limited-assurance procedures over the Leadership-indicator water-stressed-area disclosures alongside the BRSR Core engagement — typically at the request of the audit committee or to support lender ESG covenants — but this is an extended-scope engagement, not part of standard BRSR Core.

XBRL filing

This attribute is filed in the BRSR XBRL instance document under the relevant element from the MCA-published BRSR taxonomy module. Element names, namespace prefixes, and unit references should be verified against the current MCA taxonomy version before generating the instance document. Both current-year and previous-year context references must be populated, and the value carried in the XBRL must reconcile to the assured value in the signed BRSR Core report.

The per-source split (surface, groundwater, third-party, seawater, other) is filed alongside the intensity figure under the Section C Principle 6 Essential Indicator 4 elements. See XBRL Taxonomy for BRSR for the structural overview.

How this attribute rolls up into the BRSR Core engagement

This attribute is one of the four Core attributes under Principle 6. The signed BRSR Core assurance report attests this number to reasonable assurance under SAE 3000 (Revised). Workpapers retained by the assurance partner cover the per-source category reconciliation, vouching to source-meter readings or utility bills, and the boundary alignment between numerator and denominator.

For the engagement that produces the signed assurance opinion, see BRSR Core Assurance.

Related reading

• NGRBC Principle 6 — Environment — parent pillar
• GHG Emission Intensity per Revenue — sibling Core attribute (same PPP convention applied)
• Document Evidence Requirements — full evidence checklist including water source documents
• XBRL Taxonomy for BRSR — XBRL filing structure
• BRSR Core Assurance — service
• ISAE 3410 / Standalone GHG — service