Here is the mistake almost every first-year sustainability lead makes. She treats BRSR as an annual report annexure, opens the template in October, and starts collecting data. By November she has discovered that Principle 6 Scope 3 needs supplier data that nobody has ever asked for. By December she is chasing HR for the wages median-by-gender calculation, and payroll categories were changed on 15 September so the current-year data is not directly comparable to last year. By January she is arguing with the assurance provider about evidence sufficiency. By February the Board Report has to be finalised and the BRSR is still being edited. By March the annual report is being printed with BRSR errors that cannot be fixed until the next filing cycle.
BRSR is not an October workstream. It is a nine-month workstream. Here is the calendar.
Q1 (April to June): data-cadence setup
- April: The financial year has just started. Set up (or refresh) the Data Owner Matrix that Module 7 walks through. Every row in the BRSR template needs a name against it: department, role, evidence source. If your matrix from last year had 40 rows unowned by name, close those gaps now.
- May: Confirm the reporting boundary. Standalone or consolidated. If there is any change in subsidiaries or joint ventures, get a written boundary decision from the CFO office. Rating agencies cross-check the boundary against the audited financials.
- June: Kick off monthly data collection with the cadence template. First month of clean data collected against the current-year template. Baseline the intensity denominators (revenue, employees, area) that will be used for FY-end calculations.
Q2 (July to September): assurance provider selection and materiality
- July: If your company is in the BRSR Core reasonable-assurance cohort for the current year (top 500 for FY 2025-26, top 1,000 for FY 2026-27), the assurance provider selection process starts. RFP to three or four ICAI-empanelled sustainability assurance firms. Independence check. Scope agreement. Engagement letter. Give Module 8 lesson 3 a read for the engagement letter template.
- August: Run the materiality assessment. Section 4 of the course walks through this. Two-axis matrix: importance to stakeholders vs importance to business. Refresh from the previous year with any new material topics (climate transition, biodiversity, cyber, EPR compliance).
- September: Half-year data close. Reconcile against Q1 baseline. Fix any data-quality gaps identified in the mid-year check. The assurance provider will do a planning walkthrough in September or October; you want your data collection running cleanly by then.
Q3 (October to December): data collection completion and Section drafting
- October: Assurance planning walkthrough. The provider comes in, reviews the Data Owner Matrix, samples the September evidence, agrees the evidence-collection approach for the FY-end fieldwork.
- November: Section A drafting. Corporate identity, workforce, wages, CSR spend can all be drafted from H1 data with year-to-date extrapolation for a management sense-check. Section B policy audit refresh: confirm every Board-approved policy is still in force, and that no policy that was refreshed mid-year has changed the yes-no-N/A answer.
- December: Section C drafting begins. Non-financial data by principle. Scope 1-2 emissions can be drafted using H1 data with December estimates. Scope 3 categories that need supplier data have to wait until year-end.
Q4 (January to March): year-end close, assurance fieldwork, Board approval
- January: Year-end data close begins. Payroll categories reconciled for the wages median calculation. HR headcount reconciled. Safety metrics reconciled with Occupational Safety, Health and Working Conditions Code 2020 reporting.
- February: Assurance fieldwork peaks. The provider tests evidence against BRSR Core rows. Findings are shared as they emerge. Section C drafting completes.
- March: Year-end (31 March). Full-year Scope 1-2-3 emissions calculated using CEA emission factors for Scope 2 and the GHG Protocol Scope 3 category methodology. Assurance provider issues limited or reasonable assurance opinion (as applicable). Board approves BRSR alongside the Board Report and the audited financial statements.
Q1 of next year (April to June): filing, AGM, rating agency response
- April: Annual report finalised with BRSR inside. XBRL BRSR filing on BSE Listing Centre and NSE NEAPS portals. Module 8 lesson 4 walks the XBRL upload.
- May: Annual report despatched to shareholders (at least 21 clear days before AGM, per Section 101 of the Companies Act 2013).
- June or July: AGM. BRSR is part of the annual report placed before shareholders. Investor calls after AGM. ESG rating agency queries start arriving (MSCI, CRISIL, Sustainalytics, S&P Global). Module 8 lesson 6 gives you the QA prep for rating agency engagement.
The single biggest calendar mistake
Starting Scope 3 supplier data collection in Q4. Scope 3 category 1 (purchased goods and services) needs emissions data from your top-N vendors. Vendor engagement takes twelve weeks minimum. If you start in January, you get vendor data in April, which is after the annual report has been finalised. Start Scope 3 supplier engagement in Q2 (July or August) so the data is available for Q4 close. Module 7 walks through the vendor onboarding template.
The second-biggest calendar mistake
Confusing the CSR-2 filing timeline (under the Companies Act, currently rolling as amended for FY 2023-24) with the BRSR filing timeline. The two are related (BRSR Principle 8 disclosures reference Section 135 CSR spend) but their filing windows are different. CSR-2 goes to MCA; BRSR goes to BSE and NSE inside the annual report. Keep the two workstreams reconciled but distinct.
What to do with this calendar today
Print this lesson. Put a copy on the wall of the sustainability team room. Every month on the first, look at the current month on the calendar and confirm the deliverable is in flight. If any month is behind, escalate immediately. BRSR calendars do not catch up; they compound.
End of the free-preview module. Module 2 begins the Section A deep dive, where the actual number pack starts getting built. Enrol to continue.