The BRSR Applicability
The top 1,000 listed entities by market capitalisation must file the Business Responsibility and Sustainability Report under Regulation 34(2)(f) of LODR. After a scheme, the transferee’s market capitalisation may change, and its BRSR applicability should be re-tested. A transferee that falls within the top 1,000 must file the BRSR for the first full financial year after the scheme.
The Data Integration
The BRSR requires data on the entity’s operations, including the transferor’s pre-merger operations for the part of the year before the effective date. The transferee must collect the transferor’s data on emissions, energy, water, waste, employee benefits, and community engagement. A data gap can lead to an incomplete or qualified BRSR.
The Assurance
The BRSR’s sustainability data may require assurance under the SEBI’s assurance framework. The transferee should engage an assurance provider early and ensure that the transferor’s data is available for the assurance exercise.
The Governance
The BRSR requires disclosures on the board’s oversight of ESG matters, the committee responsible, and the stakeholder engagement. The transferee’s governance architecture should be updated to reflect the combined entity’s ESG responsibilities.
Call to Action: For post-scheme BRSR preparation, ESG data integration, or assurance coordination, contact office@anujdesaiassociates.com or 9619456656. Website: https://anujdesaiassociates.com. LinkedIn: linkedin.com/in/ca-anuj-desai-122547230.