BRSR for Technology and Data Centre Companies
What to Disclose on Energy, Water and Emissions?
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Introduction
Technology and data centre companies must file BRSR only if they are among India's top 1,000 listed companies by market capitalisation. BRSR then asks for company-level energy, water, emissions and waste data, so facility metrics such as PUE and WUE must be translated carefully.
Reporting expectations are rising, BRSR Core assessment or assurance now reaches the full top 1,000 listed companies in FY 2026-27, and high-energy digital infrastructure is under closer scrutiny. All of this increases the need for reliable operational data.
This article explains who reports, which energy, water, emissions and waste information is relevant, and how to organise evidence without confusing company-level and facility-level data. It is general information, not legal advice.
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Who Reports and What BRSR Core Means?
The Business Responsibility and Sustainability Report (BRSR) is SEBI's disclosure framework for listed companies. It is mandatory for the top 1,000 listed entities by market capitalisation and has applied since FY 2022-23. It depends on listing and size, not on sector, so a data centre company reports only if it is listed and in that group. Private operators may still report voluntarily when customers or investors ask.
BRSR Core is a smaller set of key indicators within BRSR that must undergo assessment or assurance by an independent party. This requirement was phased in by market capitalisation rank, starting with the top 150 companies in FY 2023-24 and reaching the full top 1,000 in FY 2026-27.
Value chain disclosures, which cover major suppliers and customers, are voluntary for the top 250 companies under SEBI's circular of 28 March 2025. PUE and WUE are not BRSR line items. They are operational metrics that help explain energy and water figures.
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BRSR Data Centres: Mapping Operational Data to Disclosures
Energy
BRSR asks for total electricity and fuel consumption, energy from other sources, the share from renewable sources and energy intensity relative to turnover. Facility meter data feeds these totals. PUE helps explain why overhead energy is high or low, but it is supporting evidence, not a disclosure field. Use the same electricity figure for the energy and emissions sections so the two disclosures agree.
Water
BRSR asks for water withdrawal by source, total consumption, discharge by destination and treatment level, and water intensity. Cooling water records and the site water balance feed these figures. WUE helps explain consumption, and any zero liquid discharge arrangement should be described accurately.
Emissions
Scope 1 emissions include backup diesel generators and any refrigerant leaks. Scope 2 emissions come from purchased electricity. Scope 3 covers wider supply chain emissions and appears as a broader disclosure. Emission intensity is reported against turnover, so the calculation method and emission factors should be recorded.
Waste
Waste disclosures cover categories such as hazardous waste and e-waste, along with how each was managed or disposed of. Retired servers and networking equipment are common sources of e-waste, so records of recyclers and disposal routes matter.
Workforce and other Core areas
BRSR Core also covers employee wellbeing and safety, gender diversity, inclusive development, fair dealing with customers and suppliers, and openness of business. These need their own owners and records, separate from the technical teams.
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Organising Evidence and Watching Boundaries
Company versus facility
BRSR is reported on a standalone or consolidated company basis, while operational data usually sits at site level. Decide the reporting boundary first, then add up the sites inside it, and note any site that is excluded or only partly owned.
Build an evidence trail
Keep meter readings, utility bills, fuel logs, the water balance, waste records and the emission calculation method for each figure. A reviewer should be able to trace a number back to its source.
Check consistency
Use the same reporting period, units and boundary across all disclosures. Differences between BRSR, annual report and other sustainability figures invite questions.
Prepare for assurance
Give each data point an owner and a backup. Ask what an assessor is likely to sample, and test that records can be produced quickly. Confirm how requirements apply to your company with your company secretary or legal team.
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Conclusion
BRSR follows listing and size, not sector, so the first question for a technology or data centre company is whether it is in scope. After that, the work is translating site data into company-level disclosures.
Clear boundaries and an organised evidence trail, built before assurance begins, make the process far easier to manage.
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Frequently Asked Questions
What is BRSR for data centre companies, and do data centres have to report under it?
BRSR is SEBI's sustainability disclosure framework for listed companies, and a data centre company must report only if it is among the top 1,000 listed entities by market capitalisation.
What energy data should technology companies disclose in BRSR?
Total electricity and fuel consumption, the renewable share and energy intensity, supported by meter and billing records.
How should water use be reported in BRSR?
Report withdrawal by source, consumption, discharge by destination and treatment level, and intensity, backed by a site water balance.
What is BRSR Core?
It is a focused set of BRSR indicators that require independent assessment or assurance, reaching the full top 1,000 listed entities in FY 2026-27.
How can a data centre prepare for BRSR assurance?
Set the reporting boundary, assign data owners and keep a traceable evidence trail from meters and records to reported figures.
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