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Carbon DisclosureAugust 20264-5 min

State of Carbon Disclosure in India 2026

Scope 3 Depth Lags Far Behind Headline Reporting Rates

State of Carbon Disclosure in India 2026

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5 min

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01

Article Section

Introduction

Part 01

On 20 August, Climes published The State of Carbon Disclosure in India 2026, an analysis of 1,247 BRSR filers, predominantly covering FY2024-25 filings. The research found that 86.8% of companies disclosed both Scope 1 and Scope 2 emissions, but only 42.1% disclosed Scope 3, and just 19 companies, or 1.5% of the sample, broke that figure down into GHG Protocol categories.

The finding lands as SEBI's BRSR framework places growing emphasis on the credibility and depth of sustainability information, not merely its presence. Depth is also what external users of this data, assurance providers, EU buyers under CBAM and lenders calculating financed emissions under PCAF, actually require.

This article sets out what the research found, how the figures were verified, and what the disclosure gap means for filers, exporters, lenders and regulators.

02

Article Section

Background: How BRSR Got Here?

Part 02

SEBI's Business Responsibility and Sustainability Reporting framework applies to the top 1,000 listed companies by market capitalisation. A subset of nine attributes, BRSR Core, was later introduced with a phased assurance requirement that extends to the full top 1,000 entities in FY2026-27. Scope 1 and Scope 2 emissions were specified tightly under this framework from the start, while Scope 3 has historically required only assessment rather than assurance.

Momentum around carbon disclosure has been building independently of this specific research. ICRA ESG Ratings reported in January 2026 that Scope 3 disclosures among India's top 200 listed companies had risen by roughly 59% year-on-year, attributing the shift to rising ESG data maturity. Separate research tracking BRSR reporting broadly has also found steadily expanding energy and emissions disclosure coverage, with investors increasingly using this data to assess climate-risk exposure and transition preparedness.

External pressure has grown in parallel. CBAM's definitive regime took effect on 1 January 2026, and India's RBI climate-risk disclosure framework now includes Scope 3 expectations for select financial institutions, though it has yet to specify assurance requirements. Both depend on the same category-level Scope 3 data that BRSR does not yet mandate in detail.

03

Article Section

The Research in Detail

Part 03

The Mandate Worked: Scope 1 and 2 at 86.8%

1,083 of the 1,247 companies in the index, or 86.8%, disclosed both Scope 1 and Scope 2 emissions. Between them, these companies disclosed 1.29 billion tCO2e of Scope 1 emissions and 101.7 million tCO2e of Scope 2, though the totals are sums of disclosed figures rather than a national inventory, given the double counting that occurs between power generators and their customers.

The Scope 3 Cliff

525 companies, 42.1%, disclosed a Scope 3 figure, while 722, or 57.9%, did not. Climes separated genuine company disclosures from internally modelled estimates after an extraction error had temporarily misclassified a portion of the dataset, confirming the 42.1% figure by identifying which entries followed fixed sector-ratio patterns typical of modelling rather than original disclosure.

Category-Level Depth: Nineteen Companies

Only 19 companies, 1.5% of the index, disclosed Scope 3 broken into GHG Protocol categories, the level of detail an assurer or a buyer can trace back to procurement records, freight invoices or product-use assumptions. Ten of them, including Infosys, Wipro, Apollo Tyres, Balrampur Chini Mills, Dr. Reddy's Laboratories and HCL Technologies, disclosed ten or more of the fifteen categories, and Adani Energy Solutions disclosed all fifteen.

Assurance Still the Exception

Confirmed reasonable assurance on BRSR Core reached 302 companies, or 24.2% of the index, while assurance status could not be determined for 880 companies, or 70.6%, from the filings reviewed. Reasonable assurance requirements extend to the top 1,000 listed entities in FY2026-27.

Sector Variance

Among the eleven largest classified sectors, textiles and apparel disclosed Scope 3 at 15.4%, less than a third of the 54.2% rate recorded in steel and metals. Chemicals and fertilisers recorded the lowest confirmed assurance rate at 9.4%, and automobiles disclosed Scope 3 at 50.0% but confirmed assurance at only 10.0%.

04

Article Section

Implications and What to Watch

Part 04

For BRSR Filers

Companies preparing for wider assurance mandates face a shift from collecting direct operational data to establishing reliable value-chain boundaries, methodologies, supplier information and audit trails, since assurers require source documentation behind each Scope 3 figure.

For EU-Facing Exporters

CBAM's definitive regime, live since 1 January 2026, requires product-level embedded emissions data from EU importers, with the first declaration covering 2026 imports due on 30 September 2027. Only 19 Indian listed companies currently disclose Scope 3 at a granularity close to that requirement.

For Banks and Investors

Financed emissions calculations under PCAF depend on counterparties' own numbers. With Scope 3 disclosure at 42.1%, confirmed assurance at 24.2% and category-level detail at 1.5%, a large share of an Indian loan book's carbon exposure currently rests on figures that are either unavailable or untested.

05

Article Section

Conclusion

Part 05

The research shows India's BRSR mandate has succeeded where it was specific, pushing Scope 1 and Scope 2 disclosure to 86.8%, but has left Scope 3 depth largely unaddressed, with only 19 companies reporting at the category level that regulators, assurers and buyers increasingly expect.

With assurance requirements extending to the top 1,000 entities in FY2026-27 and CBAM declarations due from 2027, the next several reporting cycles will show whether disclosure depth catches up with disclosure breadth.

06

Article Section

Frequently Asked Questions

Part 06

What share of Indian listed companies disclose Scope 3 emissions?

525 of 1,247 BRSR filers, or 42.1%, disclose a Scope 3 figure, roughly half the 86.8% rate for Scope 1 and Scope 2.

How many Indian companies disclose Scope 3 by GHG Protocol category?

Nineteen companies, or 1.5% of the index, with Adani Energy Solutions the only one disclosing all fifteen categories.

What share of BRSR filers have confirmed reasonable assurance?

24.2%, or 302 companies, while assurance status could not be determined for a further 70.6% from the filings reviewed.

Which sector has the weakest Scope 3 disclosure?

Textiles and apparel, disclosing Scope 3 at 15.4% compared with 54.2% in steel and metals.

Why does category-level Scope 3 disclosure matter for exporters?

CBAM requires product-level embedded emissions data from EU importers, and only 19 Indian companies currently disclose Scope 3 at a granularity close to that standard.

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