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

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.