Document Evidence Requirements for BRSR Metrics

What “Acceptable Evidence” Means

For a BRSR Core assurance engagement under ISAE 3000 / SA 3000, the practitioner must obtain sufficient appropriate evidence to support each KPI. Evidence is:

• Sufficient — enough to reduce assurance risk to an acceptable level (reasonable vs. limited assurance has different sufficiency thresholds)
• Appropriate — relevant and reliable; documentary evidence from external sources is more reliable than internally generated records alone

The table below sets out the primary and secondary evidence types for each major KPI category.

Energy and Emissions Evidence

KPI	Primary Evidence	Secondary / Corroborating Evidence
Grid electricity consumed	Monthly EB / DISCOM bills for full FY	Tally ledger — Electricity Charges; meter reading log
Captive DG set fuel (diesel)	Fuel purchase invoices + DG run-log	Fuel consumption register; petty cash vouchers for bulk purchases
Piped natural gas	Gas distribution company invoices	Flow meter reading log
Furnace oil / HFO	Purchase invoices + tank dip readings	Weighbridge records
Captive solar generation	Generation meter logs	Inverter monitoring system export
Scope 2 emission factor	CEA CO2 Baseline Database citation (version + year)	Utility bill showing grid supply zone

Minimum evidence standard: For electricity, all 12 monthly bills must be obtained. Gap months must be explained (e.g., plant shutdown, billing cycle mismatch) and agreed to the Tally ledger balance.

Water Evidence

KPI	Primary Evidence	Secondary / Corroborating Evidence
Municipal / piped water	Water utility bills for full FY	Tally ledger — Water Charges; inlet flow meter log
Groundwater (borewell)	Pump log or borewell meter readings	Electricity consumption of pump motor (proxy)
Tanker water	Tanker delivery challans	Tally — Water Supply expense
Treated / recycled water	STP/ETP plant log	Lab reports for treated water quality
Wastewater discharged	Meter log at outlet / STP outlet	Consent to Operate conditions specifying allowable discharge

Workforce Evidence

KPI	Primary Evidence	Secondary / Corroborating Evidence
Employee headcount	HR master register as of 31 March	Form 16 / EPFO ECR challan showing employee count
Worker headcount	Contractor invoices + attendance records	EPFO ECR for contract workers if covered
Median wages — employees	Payroll register with gender flag	Salary bank transfer statements (sample)
Median wages — workers	Muster roll / wage register	Minimum wage notification applicable to state
PF coverage	EPFO ECR challan	Form 12A / PF contribution statement
ESI coverage	ESIC challan	Form 5 — Return of Contributions
Turnover	HR separation report	Exit clearance records; relieving letters (sample)
Safety incidents	POSH committee report + accident register	Factory Inspector’s report (if any)
Training hours	Training attendance sheets	LMS export (if digital system used)

CSR Evidence

KPI	Primary Evidence	Secondary / Corroborating Evidence
CSR spend	Schedule VII notes in financials + CSR report	Payment vouchers / wire transfer records
2% obligation calculation	Net profit (3-year average) per audited financials	Board resolution approving CSR budget
Impact data	Implementing agency report	Field visit report or beneficiary data (for material programmes)

Governance Evidence

KPI	Primary Evidence	Secondary / Corroborating Evidence
Fines and penalties	Legal register / compliance tracker	Court orders; penalty demand notices; payment challans
Anti-bribery policy	Board-approved policy document	Training attendance records; policy acknowledgement log
Grievance complaints	Grievance register	Resolution letters; closure records

Evidence Adequacy by Assurance Level

Assurance Level	Evidence Standard	Typical Testing Approach
Reasonable assurance (BRSR Core — Top 1,000)	Higher; practitioner must obtain evidence to form a positive opinion	Full-year bill-to-bill reconciliation for energy; payroll register to headcount register reconciliation for workforce; physical verification of plant records
Limited assurance (value chain verification)	Lower; primarily inquiry and analytical procedures	Reconcile annual totals; cross-check to Tally; inquiry with management; no exhaustive bill-level testing

Documents to Request at Engagement Initiation

Send this list to the client at the start of the engagement:

1. All electricity / utility bills for the FY (12 months minimum)
2. Fuel purchase invoices (diesel, gas, coal — all types)
3. Water utility bills and/or borewell pump logs
4. HR master register as at 31 March (with gender field)
5. Payroll register for full FY (masked to salary band if required — anonymised by employee code)
6. EPFO ECR challans for all 12 months
7. ESIC challans for all 12 months
8. CSR Annual Report and Schedule VII note from audited financials
9. Waste disposal manifests / CPCB Form 3 for hazardous waste
10. Legal register / compliance calendar
11. Board-approved BRSR policy documents (anti-bribery, environmental, POSH, etc.)
12. Previous year’s BRSR filing (for comparative KPIs)