Board Diversity in India

Nine of India's top 100 listed banks meet the letter of the law on gender diversity with exactly one woman director each. Under BRSR, that single appointment is enough to check the box, whether or not the board's actual decision-making has changed at all.

This is not a hypothetical concern. Research on Indian family-owned businesses found that gender diversity only produces a measurable performance effect once a board crosses a threshold of three women directors, not one. Yet the regulatory bar most Indian companies are held to, both under the Companies Act's mandatory woman director requirement and under BRSR's own gender diversity metric, was never designed to test for that threshold.

BRSR has meaningfully expanded what Indian companies disclose about gender, but its board diversity picture remains shallow by design, built around workforce-level metrics and a legal minimum rather than the composition depth that governance research shows actually matters.

India's mandatory woman director requirement dates to the Companies Act, 2013, and SEBI's Listing Obligations and Disclosure Requirements, which together require listed companies and certain large public companies to have at least one woman on their board. Enforcement has been inconsistent since; SEBI and NCLT have both intervened in cases where companies delayed appointments or left the position vacant after a resignation, and fines have continued to be issued in cases where companies remain non-compliant nearly a decade after the rule took effect.

BRSR, introduced by SEBI in 2021 and expanded through BRSR Core in 2023, folded gender into its nine core ESG attributes as gender diversity, one of the metrics now subject to mandatory reasonable assurance for large listed companies. In practice, this attribute is built around workforce-level data, the proportion of women employees, and wage parity, rather than board-level composition specifically.

Research groups tracking the framework have noted this gap directly: BRSR's gender-related disclosures remain underdeveloped relative to frameworks like the EU's CSRD, with no mandatory reporting requirement for gender pay gaps, board diversity depth, or workplace safety indicators, and no requirement to disaggregate data by caste, disability, or other intersecting categories that would give the metric more analytical value.

BRSR has done real work in pushing Indian companies to report on gender at all, but its current board diversity picture is shaped more by what the Companies Act already required than by what governance research shows actually changes outcomes.

As BRSR Core assurance extends to the full top 1,000 companies by FY 2026-27, the gap between what gets assured and what actually reflects meaningful board composition is likely to draw more scrutiny, from investors and regulators, than it has so far.