Reforming India's ESG Reporting: Lessons from the EU and South Africa

Indian Journal of Energy and Energy Resources (IJEER) ISSN: 2583-1186 (Online), Volume-5 Issue-1, November 2025 9 Published By: Lattice Science Publication (LSP) © Copyright: All rights reserved. Retrieval Number:100.1/ijeer.A105405011125 DOI: 10.54105/ijeer.A1054.05011125 Journal Website: www.ijeer.latticescipub.com Abstract: India has committed to reaching net-zero emissions by 2070 and reducing emissions intensity by 45% by 2030, requiring a credible system of corporate Environmental, Social, and Governance (ESG) disclosure. The introduction of the Business Responsibility and Sustainability Report (BRSR) in 2021 has made progress toward enhancing transparency, though its reach remains limited. Currently, the BRSR applies only to the top 1,000 companies, lacks robust assurance measures, and suffers from fragmented oversight, resulting in critical gaps in credibility, comparability, and investor confidence. This paper evaluates India’s framework against the European Union’s Corporate Sustainability Reporting Directive (CSRD) and the Johannesburg Stock Exchange Guidance in South Africa. Drawing on policy-mix theory and the multi-level perspective, the analysis highlights how the CSRD benefits from statutory assurance and integrated legislation. In contrast, the JSE illustrates the inherent weaknesses of voluntary alignment without enforcement. The findings indicate that BRSR is feasible but weak in credibility and alignment, leaving India vulnerable to reputational and investment risks. Three reform pathways are assessed: maintaining the status quo, adopting a CSRD-style framework, or enhancing BRSR with phased mandatory assurance. The analysis recommends the enhanced BRSR option as the most practical pathway, as it balances ambition with feasibility while facilitating eventual convergence with global standards. Keywords: Carbon Accounting, ESG, Sustainability, Transition Pathways. Nomenclature: BRSR: Business Responsibility and Sustainability Report CSRD: Corporate Sustainability Reporting Directive JSE: Johannesburg Stock Exchange BRR: Business Responsibility Report SMEs: Small and Medium-Sized Enterprises MoF: Ministry of Finance MCA: Ministry of Corporate Affairs GRI: Global Reporting Initiative ISSB: International Sustainability Standards Board MLP: Multi-Level Perspective SEBI: Securities and Exchange Board of India ESG: Environmental, Social, and Governance MoF: Ministry of Finance I. INTRODUCTION India’s goal of reaching net zero emissions by 2070 has heightened the need for corporate accountability and Manuscript received on 03 November 2025 | Revised Manuscript received on 08 November 2025 | Manuscript Accepted on 15 November 2025 | Manuscript published on 28 November 2025. *Correspondence Author(s) Katrine Nair*, Department of Sustainability, University of Sussex, Benniworth, Lincolnshire (LN86JH), United Kingdom, Email ID: [email protected], ORCID ID: 0009-0004-1683-8016 © The Authors. Published by Lattice Science Publication (LSP). This is an open-access article under the CC-BY-NC-ND license (http://creativecommons.org/licenses/by-nc-nd/4.0/) transparency in sustainability reporting [1]. To operationalize responsible business conduct, the Securities and Exchange Board of India (SEBI) introduced the Business Responsibility and Sustainability Report (BRSR) in 2021, mandating disclosures for the top 1,000 listed companies [2], [3]. The BRSR replaced the earlier Business Responsibility Report (BRR), representing a progressive step toward integrating environmental, social, and governance (ESG) metrics into corporate reporting [4]. Although the BRSR was designed with strong intentions, it has faced criticism for becoming largely a compliance exercise, functioning more as a reporting tool than a framework that drives meaningful change [5]. The current ESG reporting system struggles to deliver the reliability and comparability expected of a well-established disclosure regime. Its voluntary structure for smaller firms, along with minimal assurance requirements and fragmented oversight, makes it difficult to produce data that investors can trust [4]. As a result of inadequate verification processes, companies can selectively present their positive achievements, thereby increase the risk of greenwashing, and negatively affect investor confidence and broader policy objectives [6]. Globally, the European Union’s Corporate Sustainability Reporting Directive (CSRD) and South Africa’s Johannesburg Stock Exchange (JSE) disclosure regime provide valuable comparisons. Each represents a distinct strategy for integrating assurance and maintaining regulatory coherence [5], [6]. This study uses these two regimes to evaluate India’s ESG framework through a comparative policy lens, focusing on credibility, feasibility, and alignment. The paper contributes to growing literature on ESG governance by integrating transition theory and policy-mix analysis, offering actionable recommendations to improve India’s ESG disclosure system. It aims to identify pathways for strengthening credibility while maintaining administrative feasibility and political viability. II. LITERATURE REVIEW The BRSR has been described as a step forward in corporate transparency; however, research shows it essentially operates as a tick-box exercise [3], [7]. Disclosures focus heavily on governance metrics, with environmental and social indicators remaining underdeveloped [6]. This imbalance, coupled with limited independent verification, has raised concerns over the framework’s credibility. Market capitalization thresholds further exclude many carbon-intensive firms, including India’s 63 million small and medium-sized enterprises (SMEs), which collectively contribute significantly to national emissions [3]. Capacity limitations intensify these existing problems. Several Reforming India’s ESG Reporting: Lessons from the EU and South Africa Katrine Nair Reforming India’s ESG Reporting: Lessons from the EU and South Africa 10 Published By: Lattice Science Publication (LSP) © Copyright: All rights reserved. Retrieval Number:100.1/ijeer.A105405011125 DOI: 10.54105/ijeer.A1054.05011125 Journal Website: www.ijeer.latticescipub.com studies have reported a shortage of trained ESG professionals, poor data quality, and the lack of standardized assurance practices [8], [9]. These gaps make it difficult for companies to interpret requirements consistently or for regulators to enforce them effectively. Institutional fragmentation across SEBI, the Ministry of Corporate Affairs (MCA), and the Ministry of Finance (MoF) also creates jurisdictional ambiguity and inconsistent enforcement. These weaknesses mirror findings from other emerging economies such as Brazil and Indonesia, where divided oversight undermines regime credibility [10]. In contrast, the EU’s CSRD mandates independent assurance, double materiality assessment, and digital tagging for approximately 50,000 firms [11], [12]. Although compliance costs are high, the CSRD’s comprehensive scope supports comparability and credibility. South Africa’s JSE framework, in place since 2010, integrates the Global Reporting Initiative (GRI) and the International Sustainability Standards Board (ISSB) guidelines, though enforcement remains weak [13]. Together, these challenges align with Rogge and Reichardt’s [14] policy-mix framework, which highlights the significance of credibility, coherence, and comprehensiveness for successful policy execution [14]. Geels’ multi-level perspective (MLP) reinforces this point by illustrating how existing institutional frameworks can impede systemic transformation [15]. Collectively, the literature indicates that for India's ESG reporting framework to operate effectively, it requires enhanced assurance systems, more precise metrics, and better-coordinated governance structures. III. METHODOLOGY A. Analytical Framework This study employs a qualitative comparative policy analysis drawing on two theoretical lenses: i. Policy-Mix Framework: Following Rogge and Reichardt [14], this framework evaluates the policy landscape using three core criteria: credibility, feasibility, and alignment. ii. Transition Theory Framework: Using Geels’ [15] MLP, ESG reforms are placed within the broader sustainability transition landscape for analysis. B. Data Sources and Evaluation The analysis is based on regulatory material such as SEBI guidelines, EU Commission directives, and JSE disclosure notes, complemented by academic literature, consultancy reports (SES, CRISIL), and international policy databases. A qualitative coding approach was employed, assigning each framework a score ranging from 0 to 5 based on the three evaluation criteria. Scores were derived from documentary evidence rather than aggregated indices to preserve nuance and reflect policy trade-offs. Supporting evidence used to score each criterion is detailed in Table S1 (Appendix), which provides the underlying documentary sources for the comparative evaluation of the BRSR, CSRD, and JSE frameworks. IV. RESULTS This section presents the comparative evaluation of India’s BRSR against the EU’s CSRD and South Africa’s JSE frameworks, followed by a system-level analysis of India’s regime using the MLP. A. Comparative Evaluation of ESG Disclosure Frameworks i. Comparative Performance Overview The assessment applied three criteria: credibility, feasibility, and alignment. These were drawn from Rogge and Reichardt’s [14] policy-mix framework. Table I summarises the relative performance. The CSRD performs strongest in terms of credibility and alignment due to its statutory assurance, double materiality, and integration with EU climate and finance law. India’s BRSR ranks highest in feasibility, reflecting its phased rollout and limited coverage; however, it scores poorly in credibility due to weak verification and fragmented oversight. The JSE sits between the two, moderately aligned with international standards but weakened by its voluntary nature. Table I: Comparative Evaluation of ESG Disclosure Frameworks Criteria India: BRSR EU: CSRD South Africa: JSE Credibility 2 (Weak assurance) 5 (Mandatory assurance) 3 (Partial verification) Feasibility 4 (Phased rollout) 3 (High compliance cost) 4 (Moderate enforcement) Alignment 2 (Limited convergence) 5 (Full interoperability) 4 (Voluntary alignment) Fig. 1 visualises these differences, showing the CSRD as the most balanced framework, while the BRSR remains feasible but least credible. [Fig.1: Comparative Evaluation of ESG Disclosure Regimes Across Six Criteria] ii. Empirical Evidence from Indian Firms Firm-level data reinforce these structural limitations. Stakeholders Empowerment Services [16] found that fewer than 80% of India’s top 100 listed firms published ESG reports, only half disclosed carbon-reduction goals, and 35% set carbon-intensity targets. CRISIL [17] reported that only 11% of companies disclosed Scope 3 emissions. Fig. 2 summarizes these outcomes, highlighting procedural compliance and low assurance coverage. Indian Journal of Energy and Energy Resources (IJEER) ISSN: 2583-1186 (Online), Volume-5 Issue-1, November 2025 11 Published By: Lattice Science Publication (LSP) © Copyright: All rights reserved. Retrieval Number:100.1/ijeer.A105405011125 DOI: 10.54105/ijeer.A1054.05011125 Journal Website: www.ijeer.latticescipub.com [Fig. 2: ESG Performance Among India’s Top 100 Listed Companies] iii. Trade-Off Analysis The results reveal an inverse relationship between credibility and feasibility (Fig. 3). The CSRD achieves credibility but faces challenges with cost and capacity; the BRSR achieves feasibility but compromises trust and comparability; and the JSE sits in between. This confirms the structural policy tension predicted by Rogge and Reichardt [14]: credible systems often exceed institutional capacity, while feasible systems risk superficial compliance. [Fig.3: Trade-Offs Between Credibility and Feasibility Across ESG Disclosure Frameworks] [Fig.4: Multi-Level Perspective Mapping of India’s ESG Disclosure Regime] B. Multi-Level Perspective Analysis i. Analytical Overview To explain these outcomes, the MLP framework [15] is applied to situate India’s BRSR within its broader transition context: Fig. 4 maps pressures and feedback loops across landscape, regime, and niche levels. ii. Findings At the landscape level, global pressures, including the Paris Agreement, the ISSB, and India’s Net Zero 2070 pledge, demand credible and assured data. At the regime level, overlapping mandates, weak assurance capacity, and a compliance-oriented culture sustain path dependency. At the niche level, voluntary initiatives by ESG rating agencies and civil society promote innovation but lack statutory force. This configuration traps India’s ESG system between external pressure for credibility and domestic constraints on feasibility. The Enhanced BRSR, discussed in the following section, is proposed as a transitional bridge to resolve these opposing demands. V. DISCUSSION AND RECOMMENDATIONS The results indicate that a tension between credibility and feasibility hinders India’s ESG framework. While the phased implementation of the BRSR makes it manageable, the limitations in assurance, overlapping mandates, and a lack of alignment with international standards detract from its overall credibility [3], [18]. This section analyzes these results using both comparative insights and transition theory perspectives. A. Interpreting the Credibility-Feasibility Trade-Off The comparative analysis reveals that while India’s BRSR excels in terms of feasibility, it ranks low on credibility. In contrast, the EU’s CSRD demonstrates how mandatory assurance, penalties, and a focus on double materiality significantly enhance the quality of disclosures; however, this approach imposes substantial demands on institutional capacity and increases compliance costs [19], [11]. South Africa’s JSE model occupies a middle ground, with voluntary alignment to global Reforming India’s ESG Reporting: Lessons from the EU and South Africa 12 Published By: Lattice Science Publication (LSP) © Copyright: All rights reserved. Retrieval Number:100.1/ijeer.A105405011125 DOI: 10.54105/ijeer.A1054.05011125 Journal Website: www.ijeer.latticescipub.com standards enhancing coherence, yet it lacks enforcement mechanisms to ensure accountability [10], [20]. Rogge and Reichardt emphasise that the effectiveness of policy depends on coherence and comprehensiveness, a concept evident in India’s case [14]. The fragmented nature of India’s system, divided among SEBI, the MCA, and the MoF, often results in procedural compliance rather than integrated policy implementation [8]. From an MLP, the global demand for assured ESG data conflicts with domestic institutional constraints, such as a shortage of trained verifiers and overlapping responsibilities, which together contribute to inertia within the system [15], [17]. Without reform, India risks further eroding investor trust, which, in turn, will result in missed opportunities in global capital markets that are now prioritising assured, comparable ESG information [5]. Therefore, the credibility gap is both an administrative and strategic constraint, limiting India’s ability to benefit from sustainable finance and strengthen climate diplomacy [21]. B. Policy Learning from Comparative Models The EU and South African experiences provide key lessons. The CSRD highlights the importance of establishing a coherent legislative framework that integrates climate, finance, and corporate governance policies, with assurance embedded within [11], [22]. However, its high compliance costs demonstrate how smaller markets can be strained by overly ambitious transitions. Although the recent delay in implementation under the EU’s “stop-the-clock” highlights the importance of pacing and institutional readiness [23]. Conversely, South Africa’s JSE guidance indicates that only partial progress can be achieved when alignment is provided without enforcement. It shares many of India’s challenges, as coherence with GRI, TCFD, and ISSB standards improved disclosure quality; however, it fails to ensure reliability [13]. [16]. These cases suggest that India needs a transitional pathway to achieve successful ESG reform. This would strengthen credibility through assurance and alignment, without compromising feasibility. The proposed Enhanced BRSR, presented in the next section, is an upgraded version of the current system and offers this balance [24], [25]. Table II: Comparative Evaluation of Policy Options for India’s BRSR Criteria Option 1: Status Quo + Incremental Reform Option 2: Enhanced BRSR + Mandatory Assurance Option 3: Comprehensive ESG Framework (CSRD-Style) Credibility Poor - weak assurance, greenwashing persists Reasonable assurance for BRSR Core strengthens trust Excellent - mandatory assurance and penalties Feasibility Excellent - low cost, politically easy Reasonable - moderate costs, requires capacity-building Fair - high costs, institutional overhaul needed Alignment Poor - weak ISSB/CSRD comparability Good - partial CSRD/ISSB convergence Excellent - full interoperability with global standards C. Enhanced BRSR as a Transitional Bridge Building on these insights, a three-stage reform sequence is recommended to strengthen India’s ESG framework while maintaining administrative realism [7], [26]. Table II summarizes three policy options for India’s BRSR, ranging from incremental reform to full statutory convergence, and evaluates them against the three policy-mix criteria. i. Short-term: Institutional Coherence and Expanded Coverage Clarify mandates across SEBI, MCA, and MoF to reduce duplication and enhance coordination. Expand the BRSR’s scope to include carbon-intensive mid-tier industries through a tiered reporting structure [16]. ii. Medium-term: Assurance and Verifier Capacity. Introduce phased third-party assurance for BRSR Core disclosures and establish accreditation for ESG verifiers. Partnerships with bodies such as ISSB, GRI, and relevant professional associations could support training and standardization [8], [9]. iii. Long-term: Legislative Integration and Global Alignment Gradually evolve the BRSR into a statutory ESG disclosure law, harmonized with international frameworks such as the CSRD and ISSB. Integrate ESG metrics more directly with India’s sustainable finance taxonomy and emerging carbon market rules to ensure that the system develops more coherently and consistently over the long term [21], [12]. D. Broader Implications Improving India’s ESG reporting framework will facilitate access to sustainable finance, boost investor confidence, and establish India as a credible leader in climate action [18]. A phased, credible disclosure system can also serve as a model for other emerging economies facing similar institutional and resource challenges [27]. By sequencing reforms, India can effectively bridge the gap between credibility and feasibility, while simultaneously advancing economic and environmental objectives within a broader just transition framework [28]. E. Summary Incremental institutional improvements must be combined with gradual alignment to global standards for an effective ESG reform strategy in India. The Enhanced BRSR approach promises better assurance and coherence without overwhelming firms or regulators. As a result, it represents the most practical and politically viable option, functioning as a valuable transitional bridge that offers a feasible strategy for aligning India’s sustainability governance with international credibility benchmarks. VI. CONCLUSION This paper uses comparative analysis and transition theory to evaluate the extent to which the BRSR enhances the credibility of ESG reporting in India. The findings indicate that while the BRSR signifies a noteworthy advancement toward more organized sustainability disclosures, its limited scope, inadequate assurance processes, and fragmented oversight continue to undermine investor confidence and impede meaningful comparability. The lessons learned from the EU’s CSRD and South Africa’s JSE framework highlight the vital importance of credibility and enforcement in any effective ESG regime. The CSRD illustrates that Indian Journal of Energy and Energy Resources (IJEER) ISSN: 2583-1186 (Online), Volume-5 Issue-1, November 2025 13 Published By: Lattice Science Publication (LSP) © Copyright: All rights reserved. Retrieval Number:100.1/ijeer.A105405011125 DOI: 10.54105/ijeer.A1054.05011125 Journal Website: www.ijeer.latticescipub.com mandatory assurance and cohesive legislation can significantly promote transparency but require substantial institutional capacity. In contrast, the JSE shows that while voluntary alignment with global standards enhances consistency, it often falls short in realizing full accountability. For India, the primary challenge is achieving a practical balance between credibility and feasibility, which is crucial to both regulatory integrity and economic competitiveness. The Enhanced BRSR offers a realistic transitional pathway. By gradually expanding coverage, strengthening assurance capacity, and aligning with standards such as ISSB and the CSRD, India can improve the reliability of ESG reporting without overextending its institutions. A sequenced approach provides a practical way to enhance credibility while allowing steady convergence with international best practice. Ultimately, credible ESG disclosure is more than a reporting exercise; it is a strategic component of India’s broader sustainable development ambitions. A strengthened BRSR can foster investor trust, attract sustainable finance, and reinforce India’s standing in global climate governance. Thus, the Enhanced BRSR not only represents a feasible national reform but also offers a model that other emerging economies can adopt as they strive for credible and equitable sustainability transitions. ACKNOWLEDGMENT K. Nair thanks the University of Sussex for its support in the completion of this article. DECLARATION STATEMENT The reference [15] predates the journal’s 10-year guideline. It is retained because Geels’ work provides a foundational theoretical framework, the Multi-Level Perspective, that remains essential for analyzing sustainability transitions and is directly relevant to the aims of this study. I must verify the accuracy of the following information as the article's author. ▪ Conflicts of Interest/ Competing Interests: Based on my understanding, this article has no conflicts of interest. ▪ Funding Support: This article has not been funded by any organizations or agencies. This independence ensures that the research is conducted with objectivity and without any external influence. ▪ Ethical Approval and Consent to Participate: The content of this article does not necessitate ethical approval or consent to participate with supporting documentation. ▪ Data Access Statement and Material Availability: The adequate resources of this article are publicly accessible. ▪ Author’s Contributions: The authorship of this article is contributed solely. REFERENCES 1. G Midha, A. & Tomar, A. (2024) ‘Towards Achieving Net Zero Emissions in India by 2070’, in Malik, H., Mishra, S., Sood, Y.R., Iqbal, A. and Ustun, T.S. (eds) Renewable Power for Sustainable Growth. ICRP 2023. Lecture Notes in Electrical Engineering, vol 1086. Singapore: Springer, pp. 981-991. DOI: https://doi.org/10.1007/978-981-99-6749-0_66 2. SEBI (Securities and Exchange Board of India) (2021) Guidance Note for Business Responsibility & Sustainability Reporting Format. Available at: https://www.sebi.gov.in/sebi_data/commondocs/may-2021/Business% 20responsibility%20and%20sustainability%20reporting%20by%20list ed%20entitiesAnnexure2_p.PDF (Accessed: 12 August 2025). 3. Gupta, R. & Motwani, A. (2022) ‘ESG Reporting in India: Current Scenario’, Corporate Governance Insight, 4(2), pp. 88-1-4. Available at: (Accessed: 15 August 2025). DOI: https://doi.org/10.58426/cgi.v4.i2.2022.88-104 4. Sharma, N. & Chahar, R. (2023) ‘Sustainability Reporting Practices in India: An Analysis of Compliance Level of Business Responsibility and Sustainability Reporting Requirements in Metal and Mining Sector Companies’, Journal of Research in Business and Management, 11(7), pp. 145-150. Available at: (Accessed: 15 August 2025). https://www.questjournals.org/jrbm/papers/vol11-issue7/1107145150.p df 5. Verma, D. & Chakarwarthy, Y. (2025) ‘Impact of CSR Practices on the Performance of ESG Companies: A Comparative Study of India and Europe’, IUP Journal of Accounting Research & Audit Practices, 24(2), pp. 156-172. Available at: (Accessed: 19 August 2025). DOI: https://10.71329/IUPJARAP/2025.24.2.156-172 6. Sharma, P., Panday, P. & Dangwal, R. C. (2020) ‘Determinants of environmental, social and corporate governance (ESG) disclosure: a study of Indian companies’, International Journal of Disclosure and Governance, 17, pp. 208-217. Available at: (Accessed: 14 August 2025). DOI: https://doi.org/10.1057/s41310-020-00085-y 7. Birla, P. & Motwani, C. (2025) ‘Beyond BRSR: Chartering India’s Path to ESG Leadership’, Rajiv Gandhi National University of Law Financial and Mercantile Law Review, 12, pp. 204. Available at: (Accessed: 15 August 2025). https://heinonline.org/HOL/LandingPage?handle=hein.journals/rlfladm e12&div=14&id=&page= 8. Chourasia, S. & Pandey, S.M. (2025) ‘Stimulus Towards ESG in India and GHG Protocol with Measurable Metrological Tools: Progresses and Challenges’, MAPAN 40, pp. 175–201. Available at: (Accessed: 20 August 2025). DOI: https://doi.org/10.1007/s12647-024-00798-3 9. Khorala, M., Goyal, S. & Saxena, S. (2025) ‘Mandatory ESG Reporting in India: Legal Obligations and Management Strategies’, Journal of Marketing & Social Research, 2(2), pp. 167-177. Available at: (Accessed 20 August 2025). https://www.jmsr-online.com/article/mandatory-esg-reporting-in-indialegal-obligations-and-management-strategies-63/ 10. Singhania, M. & Saina, N. (2021) ‘Institutional framework of ESG disclosures: comparative analysis of developed and developing countries’, Journal of Sustainable Finance & Investment, 13(1), pp. 516-559. Available at: (Accessed: 15 August 2025). DOI: https://doi.org/10.1080/20430795.2021.1964810 11. European Commission (2023) Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU of the European Commission, 2024 and of the Council as regards sustainability reporting standards. Official Journal of the European Union, L 2023/2772. Available at: (Accessed: 16 August 2025). http://data.europa.eu/eli/reg_del/2023/2772/oj 12. Vázquez Harkiv, M. (2024). Double Materiality in CSRD: Transcending Challenges, Uncovering Opportunities. Master’s thesis. Management in Sustainable Business. Available at: https://www.theseus.fi/bitstream/handle/10024/875059/Vazquez_Harki vi_Mily.pdf?sequence=2&isAllowed=y (Accessed 20 August 2025). 13. Johannesburg Stock Exchange (JSE) (2022) Leading the way for a better tomorrow. Available at: (Accessed: 16 August 2025). https://www.jse.co.za/sites/default/files/media/documents/JSE%20Sust ainability%20Disclosure%20Guidance%20June%202022.pdf 14. Rogge, K.S. & Reichardt, K. (2016) ‘Policy mixes for sustainability transitions: An extended concept and framework for analysis’, Research Policy, 45(8), pp.1620-1635. Available at: (Accessed: 17 August 2025). DOI: https://doi.org/10.1016/j.respol.2016.04.004 15. Geels, F.W. (2002) ‘Technological transitions as evolutionary reconfiguration processes: a multi-level perspective and a case-study’, Research Policy, 31(8-9), pp. 1257-1274. Available at: (Accessed: 15 August 2025). DOI: https://doi.org/10.1016/S0048-7333(02)00062-8 works remain significant, see the declaration 16. Stakeholders Empowerment Services (SES) (2020) ESG Scores Top 100 Listed Companies India. Available at: (Accessed: 19 August 2025). 1649043402_ESG-Scores---Top-100-Listed-Companies-in-India.pdf 17. Credit Rating Information Services of India Limited (CRISIL) (2022) CRISIL Sustainability Yearbook, 2022. Available at: (Accessed: 16 August 2025). Reforming India’s ESG Reporting: Lessons from the EU and South Africa 14 Published By: Lattice Science Publication (LSP) © Copyright: All rights reserved. Retrieval Number:100.1/ijeer.A105405011125 DOI: 10.54105/ijeer.A1054.05011125 Journal Website: www.ijeer.latticescipub.com https://apar.com/wp-content/uploads/2023/03/APAR_CRISIL_REPOR T_2022.pdf 18. Dakshina, C. & Navajyoti, S. (2025) ‘Between Compliance and Commitment: Evaluating India’s ESG Regulatory Framework’, Amicus Curiae, 6(3), pp. 743-772. Available at: (Accessed: 16 August 2025). DOI: https://doi.org/10.14296/ac.v6i3.5795 19. Aboud, A., Saleh, A. & Eliwa, Y. (2023). Does mandating ESG reporting reduce ESG decoupling? Evidence from the European Union's Directive 2014/95’, Business Strategy and the Environment, 33(2), pp. 1305-1320. Available at: (Accessed: 12 August 2025). DOI: https://dio.org/10.1002/bse.3543 20. Viratha, H. (2023). Evaluation of the JSE’s Environmental Reporting Requirements of South African Listed Companies. PhD thesis. University of the Witwatersrand, Johannesburg. Available at: (Accessed: 17 August 2025). https://www.proquest.com/openview/52df02a8d221a7267bb09b9537ce 664a/1?pq-origsite=gscholar&cbl=2026366&diss=y 21. Ministry of Environment, Forest and Climate Change (MEFCC) (2023) Year-end Review - Ministry of Environment, Forest and Climate Change. Press Information Bureau, Government of India, 31 December. Available at: (Accessed: 17 August 2025). https://www.pib.gov.in/PressReleaseIframePage.aspx?PRID=1989495 22. Martinčević, I., Primorac, D. & Dorić, B. (2024) ‘Corporate Sustainability Reporting Directive (CSRD): Obligations, Challenges and Requirements for Companies’, ENTRENOVA - ENTerprise REsearch InNOVAtion, 10(1), pp. 317-327. Available at: (Accessed: 12 August 2025). DOI: https://doi.org/10.54820/entrenova-2024-0026 23. Normative (2025) Corporate Sustainability Reporting Directive (CSRD), explained. Available at: (Accessed: 21 August 2025). https://normative.io/insight/csrd-explained/ 24. Howlett, M. and Mukherjee, I. (2018) ‘Policy design and non-design: Towards a spectrum of policy formulation types’, in Howlett, M. and Mukherjee, I. (eds) Routledge handbook of policy design. Abingdon: Routledge, pp. 55–72. DOI: https://doi.org/10.17645/pag.v2i2.149 25. Vaghela, S. (2024) ‘Corporate Accountability and Climate Governance through the lens of Global Reporting Frameworks’, Anusandhanvallari. 249-262. Available at: (Accessed: 16 November 2025). DOI: https://doi.org/10.52783/anuval.278 26. Kakran, S. & Kumar, A. (2023) ‘ESG Reporting Landscape in India: Contrasting Approaches and Institutional Frameworks’, Proceedings of the Global Summit – 2023 Unlocking Sustainability: G20 Paves the Way for an ESG-driven New World Order, New Delhi, India, July. Volume 02. Available at: https://www.researchgate.net/publication/372289464_ESG_REPORTI NG_LANDSCAPE_IN_INDIA_CONTRASTING_APPROACHES_A ND_INSTITUTIONAL_FRAMEWORKS (Accessed: 19 August 2025). 27. Sovacool, B.K. & Dworkin M.H. (2015) ‘Energy justice: Conceptual insights and practical applications’, Applied Energy, 142, pp. 435-444. Available at: (Accessed: 20 August 2025). DOI: https://doi.org/10.1016/j.apenergy.2015.01.002 28. Mayne, R., Green, D., Guiht, I., Walsh, M., English, R. & Cairney, P. (2018) ‘Using evidence to influence policy: Oxfam’s experience’, Palgrave Communications, 4, pp.122. Available at: (Accessed: 20 August 2025). DOI: https://doi.org/10.1057/s41599-018-0176-7 AUTHOR’S PROFILE Katrine Nair has several years of experience in the sustainability sector, leading carbon accounting projects and supporting clients in achieving ISO 14064 audits. Her work spans the UK, EU, and US, and she is currently delivering ESG consultancy services in India. Katrine’s experience includes supporting corporate accreditations such as SBTi, CDP, UN Global Compact, and EcoVadis, as well as designing and delivering employee ESG training programmes. She holds a BSc in Wildlife Conservation and an MSc in Energy Policy from the University of Sussex, reflecting an interdisciplinary approach that bridges environmental science and sustainable business consulting. Her previously published research on the Smooth-Coated Otter (Lutrogale perspicillata) highlights the breadth and diversity of her professional interests. Disclaimer/Publisher’s Note: The statements, opinions and data contained in all publications are solely those of the individual author(s) and contributor(s) and not of the Lattice Science Publication (LSP)/ journal and/ or the editor(s). The Lattice Science Publication (LSP)/ journal and/or the editor(s) disclaim responsibility for any injury to people or property resulting from any ideas, methods, instructions, or products referred to in the content. APPENDIX Table S1: Evidence Base for ESG Disclosure Framework Scores Criteria India – BRSR EU – CSRD/ESRS South Africa – JSE Guidance Credibility Score: 2 (Poor). Only the top 150 firms require third-party assurance; the majority rely on self-reported data. Evidence of tick-box compliance and greenwashing undermines investor confidence (Gupta & Motwani, 2022; Birla & Motwani, 2025). Score: 5 (Excellent). Mandatory third-party assurance with penalties for non-compliance; limited assurance evolving toward reasonable assurance. Standardised digital tagging (XBRL) strengthens comparability and credibility (European Commission, 2023). Score: 3 (Fair). Voluntary alignment with ISSB/GRI enhances credibility somewhat, but the absence of statutory assurance and weak enforcement reduces trustworthiness (Singhania & Saina, 2021; JSE, 2022). Feasibility Score: 4 (Good). Phased rollout (BRSR Lite 2022, BRSR Core 2023) keeps compliance manageable. Politically feasible due to the limited scope and exclusion of SMEs. However, auditor shortages and industry pushback on political economy constrain expansion (Chourasia & Pandey, 2025; Kharola, Goyal & Saxena, 2025). Score: 3 (Fair). High compliance costs, verifier shortages, and SME burden reduce feasibility. EU Parliament (2025) delayed implementation by 2 years for large firms and SMEs (stop-the-clock proposal) due to capacity concerns (European Commission, 2023; Normative, 2025). Score: 4 (Good). Moderate costs and feasible for listed companies. Supported by JSE training, disclosure guidance, and carbon market services, extension to SMEs would require significant institutional strengthening (UN SSE, 2024; JSE, 2022). Alignment (Global) Score: 2 (Poor). Weak convergence with ISSB and CSRD; divergence in metrics reduces comparability and investor confidence—limited interoperability with global standards (Martinčević, Primorac & Dorić, 2024). Score: 5 (Excellent). Full interoperability with ISSB and GRI; EU seen as setting the global benchmark for ESG disclosure standards (European Commission, 2023). Score: 4 (Good). Voluntary alignment with ISSB, TCFD, and GRI provides comparability for investors across markets, though the absence of statutory force limits influence (JSE, 2022).