Author : Saee Rege

Expert Speak Young Voices
Published on Jul 11, 2025

India’s ambitious energy transition risks deepening gender gaps unless ESG frameworks like the BRSR are strengthened to capture the realities of women’s work and leadership.

Embedding Gender in India’s ESG: Strengthening the BRSR

Image Source: Gawrav/ via Getty Images

India’s clean energy transition is among the most ambitious globally, promising millions of jobs and restructured value chains. This moment offers a critical opportunity to embed gender equity into sustainability governance. However, unless Environmental, Social, and Governance (ESG) frameworks, such as India’s Business Responsibility and Sustainability Reporting (BRSR), do not explicitly focus on gender, they risk perpetuating existing structural inequalities.

A common blind spot in ESG is that companies often treat gender superficially or narrowly, missing critical intersections with social divisions, disability, and geography. In India, women, mainly from marginalised communities, face systemic barriers to formal employment and leadership. Furthermore, unpaid care work, predominantly carried out by women, continues to fall outside the scope of ESG reporting despite its immense social and economic contribution.

Unless Environmental, Social, and Governance (ESG) frameworks do not explicitly focus on gender, they risk perpetuating existing structural inequalities.

ESG frameworks, such as BRSR and the European Union’s Corporate Sustainability Reporting Directive (CSRD), offer a foundation for institutionalising accountability for social and environmental justice. However, their potential will remain unrealised without deliberate integration of gender equity into risk assessments, disclosure standards, and corporate governance structures.

Gender Metrics Limitations in the BRSR

Introduced in 2021 by the Securities and Exchange Board of India (SEBI), the BRSR is a more comprehensive extension of the 2015 Business Responsibility Report. It mandates the top 1,000 listed companies to report non-financial disclosures based on the nine principles of the National Guidelines on Responsible Business Conduct (NGRBC). Its 2023 update, BRSR Core, extends these ESG requirements to corporate supply chains and introduces assured metrics, including indicators on workforce diversity, board representation, equal pay, and other prioritised parameters.

Many companies treat gender diversity and pay parity disclosures as mere compliance exercises rather than opportunities to capture the lived realities of women in India's diverse labour sectors.

While these are essential steps, the framework lacks enforcement mechanisms and does not require data disaggregation by caste, disability, or rural-urban divides, which are vital for intersectional analysis. Moreover, the BRSR currently emphasises quantitative disclosures (for example, the number of women employed and their percentage of board representation), with limited qualitative data on workplace culture, inclusion, or the structural reasons behind wage gaps and leadership disparities. Consequently, many companies treat gender diversity and pay parity disclosures as mere compliance exercises rather than opportunities to capture the lived realities of women in India’s diverse labour sectors.

Global Lessons, Local Gaps in ESG Gender Integration

CSRD mandates disclosures on gender pay gaps, board diversity, work-life balance policies, and incidents of sexual harassment, applying a “double materiality lens that recognises how gender inequality both influences and is influenced by business practices. This framework aims to move beyond representation by incorporating workplace culture and structural issues into ESG assessments. Meaningful impact, however, requires more than disclosure. The effectiveness of gender accountability within CSRD remains uneven, particularly among smaller firms that may lack the capacity to comply with its technical demands. Without adequate enforcement and cultural alignment within organisations, companies would continue to treat gender metrics as procedural rather than transformative.

Compared to the CSRD, India’s BRSR includes some requirements for disaggregated data, such as workforce diversity and representation of people with disabilities. However, limitations in data quality and consistency still constrain meaningful gender analysis despite steady improvements in ESG reporting. Additionally, gender-related metrics remain underdeveloped, often treated as formalities rather than indicators of substantive change, given the absence of mandatory reporting on gender pay gaps, board diversity, or workplace safety indicators.

India has the institutional capacity and opportunity to pioneer gender responsive ESG governance for the Global South by building on existing strengths and thoughtfully integrating global best practices with local realities.

This scenario creates space to build on the current momentum. International frameworks offer relevant lessons for deepening gender integration. In Sweden, gender equality is embedded in sustainability policy through tools such as the Gender Equality Index and sustainability-linked bonds that incorporate measurable gender targets. For instance, private equity firm EQT AB issued a bond linked to increasing the proportion of women in senior management, aligning financial accountability with diversity outcomes. Canada’s Gender-Based Analysis Plus (GBA+) model incorporates intersectional gender equity across policy and procurement systems, providing a structured approach to disclosures. In South Africa, Barloworld Ltd. issued a gender-linked bond tied to measurable diversity goals, demonstrating how companies can utilise financial instruments to drive accountability.

Towards a Gender-Accountable BRSR

For India to embed gender equity meaningfully into its ESG framework, future iterations of the BRSR could consider the following:

  • Phase in tiered gender disclosures across recruitment, leadership pipelines, training access, and attrition, tailored by company size and sector, by leveraging India’s existing tiered ESG filing system. A staged approach would ease compliance burdens while signalling clear expectations, mirroring how the EU is rolling out its CSRD.
  • Develop a gender equity score within ESG assessments, integrating weighted indicators such as board representation, pay equity, work conditions, and anti-harassment measures. Similar to Sweden, linking ESG ratings to sustainability-linked finance could incentivise stronger performance.
  • Mandate sector-specific metrics in green industries, particularly in sectors such as solar, wind, and electric vehicles, which attract government incentives, such as India’s Production-Linked Incentive Collaborating with NITI Aayog and the Ministry of Environment, Forests and Climate Change could support a targeted integration modelled on Canada’s GBA+.
  • Enable voluntary intersectional audits of ESG reports that address caste, disability, and rural-urban divides. Companies could fund these initiatives through their existing CSR budgets, drawing on models such as independent social audits, supported, for example, by the Azim Premji Foundation.
  • Link recognition and procurement access to gender performance using mechanisms such as preferential procurement, award schemes, or tax incentives. The UK Government’s Social Value Model provides one approach to aligning public contracts with equality objectives.

A Blueprint for Gender-Inclusive Green Growth

India’s clean energy expansion is more than an environmental objective. It represents a structural shift that will shape the country’s sustainable economic and social future, promoting a just transition. While India’s ESG frameworks, such as BRSR, currently lag behind standards like the EU’s CSRD in terms of depth and intersectionality, India has the institutional capacity and opportunity to pioneer gender responsive ESG governance for the Global South. By building on existing strengths and thoughtfully integrating global best practices with local realities, India can set a new standard for inclusive and accountable sustainability reporting that supports equitable growth across diverse communities.


Saee Rege is a Research Intern at the Observer Research Foundation.

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