BRSR compliance, held through the year · Mitochondria
BRSR compliance · SEBI Regulation 34(2)(f)

BRSR filing, without the annual scramble.

Chaperone holds your ESG evidence through the year and flags what is missing while it can still be retrieved. BRSR Close then drafts the disclosure across all nine principles, with your team approving every figure.

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Evidence status
FY 2026-27
A
M
J
J
A
S
O
N
D
J
F
M
Unit 1 · Electricity
Unit 2 · Electricity
Plant 1 · Water
Plant 2 · Diesel
Branches (41) · Water
Raised this week
Unit 2, April electricity not received, 41 days open. Branches (41) have no water metering, so the agreed benchmark basis applies.
148 of 168 expected records held, nine months closed.
Held
Raised
Not yet due
Gathered all yearDocuments are read and placed as they arrive, rather than chased in the final quarter.
Gaps surfaced earlyWhat has not come in is flagged while the record can still be retrieved.
Nine principles, one threadThe disclosure is drafted in plain language, section by section.
Traceable end to endEvery disclosed figure carries its source, ready for assurance.

Built in consultation with, and validated by, a leading ESG and climate-reporting advisory, part of an established audit and advisory firm that provides BRSR assurance to listed companies.

One system, two halves.

The filing problem has two parts. The evidence has to exist and be findable, and the disclosure has to be drafted from it. Most tools address the second part and assume the first has been solved.

THROUGH THE YEAR CHAPERONE Holds and checks the evidence Electricity · Unit 2 Water · Plant 1 Diesel log · Plant 2 HR export · FY Waste manifest Outstanding · Apr EXPECTED THIS YEAR Anything expected and not received is flagged, while the record can still be retrieved. AT THE FILING WINDOW BRSR CLOSE Drafts the disclosure P1 Integrity P2 Products P3 Employees P4 Stakeholders P5 Human rights P6 Environment P7 Policy P8 Inclusion P9 Consumers In conversation with your nominated representative, who approves each step. TWO WAYS OUT FOR YOUR ASSURANCE PROVIDER Audit-ready, human-readable. Every value carries its source. Traceable end to end. FOR THE EXCHANGE Submission-ready, in SEBI taxonomy. Aligned to the BRSR template. Final validation via the exchange utility.
Through the year
Chaperone
Holds and checks the evidence. Documents are read and placed against the site and period they belong to. Anything expected and not received is flagged, while the record can still be retrieved.
At the filing window
BRSR Close
Drafts the disclosure. All nine principles, in conversation with your nominated representative, who approves each step.
Two ways out
For your assurance provider
Audit-ready, human-readable. Every value carries its source. Traceable end to end.
For the exchange
Submission-ready, in SEBI taxonomy. Aligned to the BRSR template. Final validation via the exchange utility.

This is the year the assurance glide path reaches everyone in scope.

1,000
listed companies by market capitalisation in scope for mandatory BRSR filing, with rank fixed at 31 March each year.
SEBI mandate, in effect since FY 2022-23
2026-27
the year BRSR Core assurance or assessment reaches the full top 1,000, having begun with the top 150 in FY 2023-24.
SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122, 12 July 2023
Reasonable
the level of assurance BRSR Core requires on nine ESG attributes, a higher bar than the limited assurance the EU's CSRD initially sets.
SEBI framework on BRSR Core, assurance specifications
75%
of purchases and sales by value disclosable through value chain partners contributing 2% or more individually.
SEBI master circular, as amended December 2024

Most of a filing is assembly.

A BRSR filing is a judgement exercise that runs mostly on clerical work. Collecting records, chasing what did not arrive, and reconciling what did will absorb the bulk of the hours, and the parts that need expertise get whatever is left. Holding the evidence through the year moves that balance.

TODAY The hours in a filing ASSEMBLY Advisory what it is for WITH MITOCHONDRIA The same hours Advisory and strategy Emission boundaries, estimation bases, what a figure means and whether it will hold up. JUDGEMENT Scope and set up Collect and chase Clean and reconcile Draft and review Advisory and strategy
Today
Assembly takes the hours. Collecting and chasing records, then cleaning and reconciling what comes back, occupy the bulk of the time. The parts that need expertise get whatever is left.
With Mitochondria
Judgement
The same hours, differently spent. Collection and reconciliation contract. Emission boundaries, estimation bases and what the figures mean expand to fill the time. The filing is unchanged. The work inside it is not.

Illustrative of where effort concentrates in a BRSR filing, drawn from how the work is commonly described. Proportions are not a measured benchmark and will differ by footprint and scope.

01
Less of it clerical.
The filing itself does not change. How much of it is assembly does. Weeks of chasing branch records becomes a system that has already collected, leaving the people responsible to review rather than compile.
02
Expertise where it is needed.
Hours spent reconciling spreadsheets are hours not spent on emission boundaries, estimation bases, and whether a figure will survive review. That is where experience earns its keep.
03
Through the season, not against it.
Filing concentrates into a few months, and the constraint is experienced people. When collection is not consuming them, that window can be carried without borrowing from the rest of the year.
04
The second year opens ahead.
A first filing loses time where the organisation does not yet hold its own data. When the evidence builds from the outset, the following cycle starts from a position rather than a standstill.

And the review exposure. Reasonable assurance tests the trail rather than the template. A filing that produces provenance as the work happens raises fewer queries and needs less rework, which is time nobody plans for.

And it compounds. The operational profile, the estimation bases and the approvals given are recorded once. Each subsequent cycle inherits them, so the work reduces year on year rather than resetting to a blank template.

A year that keeps its own records.

Today · Annual

Everything happens at the end.

The filing window opens and the collection begins. Bills for months that closed a year ago are requested from branches where the person who filed them has since moved on. Sites with no water meter become a figure arrived at under time pressure.

Someone senior spends weeks coordinating people who do not report to them. When the assurance provider asks where a number came from, the answer is reconstructed from memory and email.

With Mitochondria · Continuous

The evidence is already in.

Documents arrive through the year and are read, classified, and placed against the site and period they belong to. What has not come in is flagged early enough to be chased while the record still exists.

Sites without metering are known in advance, with the estimation basis agreed once and applied consistently. By the time the window opens, most of the disclosure is drafted and every figure has its provenance attached.

Chaperone

An AI compliance manager for ESG evidence.

Chaperone reads documents where they arrive, places each record against the site and period it belongs to, and knows what has not come in. It runs continuously rather than at filing time.

01
Reads what arrives, as it arrives.
Utility bills, meter records, fuel logs, waste manifests, HR exports, policy files. Any format, any language. No pre-sorting, and no naming convention for anyone to maintain.
02
Places each record where it belongs.
One drop point for the whole organisation. The system determines the location, the period, and which disclosure the record serves, then keeps the file linked to the figure it supports.
03
Knows what is still outstanding.
Your operational profile is captured once: the sites, the utilities each draws, the billing cycles, and where no meter exists. Anything expected and not received is raised while it can still be found.
04
Settles estimation in advance.
Locations without metering are a known condition rather than an annual discovery. The benchmark, the assumption, and the approval are recorded once and applied consistently across periods.

What it covers, and what it does not. Chaperone works on the disclosures that rest on documents: energy, water, fuel, waste, emissions, and the HR and spend records behind the quantitative fields. That is where the volume sits, and Principle 6 alone usually takes more of a filing than any other section. Policies, board composition and the narrative disclosures have no document to gather, so BRSR Close asks your representative for those directly.

BRSR Close

The disclosure, drafted in conversation.

BRSR Close works through all nine principles with your nominated representative, drafting from the evidence Chaperone already holds and asking only for what the documents cannot answer.

01
Drafts from what is already held.
Values are extracted, converted, consolidated across sites, and placed in the correct field. Your representative confirms rather than types, and never needs to know which field maps where.
02
Asks before it assumes.
Where a figure turns on a judgement, the qualifying question comes first. An estimate is labelled as an estimate, carries the standard it rests on, and is never recorded as a measurement.
03
Shows the form at each gate.
The filled disclosure is rendered for review as the work progresses, so your representative sees how the submission reads well before anything is treated as final.
04
Carries the thread forward.
The conversation survives interruption and resumes where it stopped. In the following cycle it opens with what has changed, rather than asking the organisation to start again.

Who holds the pen. The system carries the template structure, the unit conversions, the consolidation arithmetic, and the cross-references. Your representative carries the judgement, and the filing remains the company's throughout.

A conversation, not a form.

An excerpt from a demonstration session. A site has no water meter, so a figure has to be estimated. What follows is how the system handles a number that cannot simply be read off a bill.

Session · Principle 6 · Water
You
We have 4 factories with 45 engineers each. What is our water consumption?
Agent
To estimate this accurately I need to confirm three points first.
  1. Are bathing or shower facilities available for the engineers?
  2. Is the water used only for domestic purposes such as drinking, sanitation and cleaning, or also in industrial processes, cooling or manufacturing?
  3. Do you have meter readings or tanker supply logs, or shall I proceed on benchmark data under IS 1172:1993 (Reaffirmed 2021), Code of basic requirements for water supply, drainage and sanitation?
You
No bathing or shower, domestic only, and no meter readings.
Agent
That fits the domestic-use benchmark under IS 1172:1993 (Reaffirmed 2021). For a workplace without bathing facilities the standard allows 45 litres per person per day.

→ 4 factories × 45 engineers = 180 people
→ 8.1 kilolitres per day
→ approximately 2,958 kilolitres per year, at full-time operation

I will record this as an estimated domestic water figure, on IS 1172:1993 (Reaffirmed 2021). Can your assurance provider accept an estimated benchmark value for water use in this section?
You
Confirmed, thank you.
Agent
Recorded, with the standard and the approval attached to the figure.

Returning to energy. Could you confirm whether the Pune office units cover the whole company's electricity use, or whether other sites and operations also consume electricity or fuel that should be added before we finalise the total?

Three things are happening here. The system qualifies before it calculates, because the same standard allows 45 or 135 litres depending on facilities and the difference is threefold. It separates domestic water from process water, which cannot be inferred from headcount at all. And it will not let an estimate pass as a measurement without the standard cited and the assurance provider's position on record.

Coordination is solved. Judgement is not.

Reporting software has become good at moving work around an organisation: owners assigned, templates issued, reminders sent, entries validated, progress shown on a dashboard. None of that decides what the number should be.

THE WORK WIDELY AVAILABLE TODAY WITH MITOCHONDRIA STAGE 01 Getting the evidence in. Owners assigned, templates issued, reminders sent, entries validated on the way in, progress shown on a dashboard. Well served. Workflow tooling here is mature and broadly comparable. STAGE 02 Knowing what the number should be. Which unit. Renewable or grid. Domestic water or process water. What basis applies where no meter exists, and whether it will hold. Left to your team. Validation rules catch a typo. They do not make a judgement. STAGE 03 Getting it into the filing. Mapped to the SEBI template, exported for the exchange, with an audit trail attached to the submission. Well served. Template mapping and export are largely standard. ALL THREE STAGES Held evidence, recorded reasoning. Evidence held all year Gaps raised, not awaited Qualifies before it computes Estimates labelled and cited Approvals kept with figures Drafted for the SEBI template The middle stage is the one that reasonable assurance now tests.
Stage 01 · Getting the evidence in
Well served today. Owners assigned, templates issued, reminders sent, entries validated, progress on a dashboard. Workflow tooling here is mature and broadly comparable.
Stage 02 · Knowing what the number should be
Left to your team. Which unit. Renewable or grid. Domestic water or process water. What basis applies where no meter exists, and whether it will hold. Validation rules catch a typo, and do not make a judgement.
Stage 03 · Getting it into the filing
Well served today. Mapped to the SEBI template, exported for the exchange, audit trail attached. Template mapping and export are largely standard.
With Mitochondria
All three stages
Held evidence, recorded reasoning. Evidence held all year. Gaps raised rather than awaited. Qualifying questions before any calculation. Estimates labelled and cited. Approvals kept with the figures they belong to. Drafted for the SEBI template. The middle stage is the one reasonable assurance now tests.

Reasonable assurance changes what a good answer looks like. It is a higher bar than the limited assurance the EU's CSRD initially sets, and it asks for source-traced evidence: calculation sheets, plant-level records, emission factors, and approval trails. Four quarters of it, rather than a figure reconstructed in the final month.

That is a burden of reasoning, not of coordination. An assurer does not ask whether a reminder was sent. They ask which standard the water estimate rests on, who accepted it, and why the same basis was used across sites. Those answers have to be recorded when the figure is made, because they cannot be recovered afterwards.

Sources: SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023, establishing the BRSR Core assurance glide path from the top 150 listed entities in FY 2023-24 to the top 1,000 in FY 2026-27; SEBI master circular for listed entities as amended December 2024. Characterisation of currently available tooling reflects publicly published product descriptions across the category, and names no individual vendor.

Operated by you, not around you.

A good deal of this work is run by advisory firms on behalf of their clients, and a firm carrying twenty filings carries the same collection problem twenty times over. Where that applies, four things matter.

Many clients
Each client kept apart.
Records, filings and the completeness position are held separately for every client, with separate access. Whoever oversees the portfolio sees which are ready and which are short, without opening each one.
Your people
Your consultant signs the work.
BRSR Close drafts for the person who is accountable for it. The client relationship, the sector judgement, and the assurance conversation stay with the practice throughout.
White label
Your brand on the surface.
Where a firm prefers it, the client-facing surface carries their identity rather than ours. Mitochondria remains the technology layer, and the engagement stays visibly theirs.
Licensing
One licence, many filings.
A single listed entity is priced per filing. A firm carrying several moves to an annual licence covering its engagements, rather than a charge per seat or per client.

Worth asking.

Does our data leave our environment?

No data is retained by Mitochondria. Documents are processed transiently through our cloud infrastructure, encrypted in transit and at rest, and the output is returned to your nominated workspace. Mitochondria is ISO 27001:2022 certified, and the connection model and data handling terms are set out in our DPA, aligned with the GDPR, UK GDPR, and India's DPDP Act. Where a sector requires it, deployment within your own environment is available.

We are already mid-year. Do we have to wait to start?

No. Chaperone can be pointed at what you already hold, which establishes where you stand for the current year and what is missing from it. The continuous model then applies from that point forward. Starting mid-cycle means the first year captures less than a full one, and the gaps it surfaces are still worth knowing before the window opens.

How does this help with BRSR Core assurance?

Reasonable assurance asks for source-traced evidence rather than a completed template. Because every figure is linked to the document or conversation it came from, and because estimates carry the standard applied and the approval given, the trail an assurer asks for is produced as the work happens rather than assembled afterwards. Where the same basis is used across sites and periods, that consistency is on the record too.

What about sections that no document can answer?

Much of the BRSR, including board composition, policies, stakeholder engagement, and ethics disclosures, is answered in conversation. The system asks your representative directly, explains what each field requires, and records the response against the field. Documents are one input path rather than the only one.

How does estimation work where there is no meter?

The system asks what it needs in order to choose the right basis, then states the standard it is applying, shows the calculation, labels the result as an estimate, and asks whether your assurance provider accepts an estimated value for that field. The assumption and the approval are recorded alongside the figure, so the same basis is applied in later cycles rather than reopened each year.

How does the SEBI taxonomy alignment work?

The output is aligned to the SEBI BRSR taxonomy used by the exchange submission utility. Final validation against the current taxonomy happens through the exchange's own utility. Where SEBI amends the schema, the field mapping is updated to follow it.

How well does the system understand the disclosure itself?

It was built in consultation with, and validated by, a leading ESG and climate-reporting advisory, part of an established audit and advisory firm that provides BRSR assurance to listed companies. Its leadership reviewed the working demonstrations and approved both the approach and the output. The disclosure expertise and the engineering sit in the same build, which is why the system asks the questions an assurance review would.

How does this work with our assurance provider?

Every value is traceable to a specific document, a recorded conversation, or a calculated field with its inputs visible. Your assurance provider reviews the same artefact your team does, with no parallel workflow to reconcile.

What happens next year, and what if we leave?

The prior year's context carries forward, so the following cycle opens with what has changed rather than a blank template. Your completed filings and your evidence estate are exportable at any point. If you do not return, you keep everything.

What does it cost?

A single listed entity is priced per filing, annually. An advisory practice running filings for several clients moves to an annual practice licence. The range depends on operational footprint and document volume, and is discussed during the walkthrough.

See it running on your template.

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