BRSR Core Safety Data: Getting LTIFR and Incident Records Ready for Assurance

For FY 2026-27, BRSR Core reaches the top 1,000 listed companies in India. For about 500 of them, this is the first year their BRSR Core figures must be assessed or assured by a third party, and the safety numbers are part of it. An LTIFR that once went straight from a spreadsheet into the annual report now has to hold up when someone checks how it was built.

This article covers what BRSR Core asks for on safety, who is covered and when, what an assessor will look at, and a checklist for the rest of the financial year.

What BRSR Core asks for on safety

BRSR Core is a subset of the Business Responsibility and Sustainability Report (BRSR): a set of key indicators under nine ESG attributes that the largest listed companies must have assessed or assured by a third party. Safety sits under attribute 5, “Enhancing Employee Wellbeing and Safety”, which has two parts.

• Spending on wellbeing: the cost of measures for the wellbeing of employees and workers, as a percentage of total revenue. SEBI’s format lists the evidence it has in mind, such as insurance policies and premiums paid, the infant care policy, and invoices for the facilities provided.
• Safety-related incidents for employees and workers, “including contract-workforce e.g. workers in the company’s construction sites”. Three figures are reported.

Figure	How SEBI’s format says it is built or checked
Number of permanent disabilities	“To check on the basis of claims”
Lost Time Injury Frequency Rate (LTIFR), per one million person-hours worked	Total lost-time injuries and total working hours, with LTIFR = (lost-time injuries × 10,00,000) ÷ total working hours
Number of fatalities	“To check on the basis of claims as reported to the Factory Inspector”

These figures come from the safety-incident table you already complete under Principle 3, Essential Indicator 11 of the BRSR. BRSR Core is where a third party checks them.

The phrase that catches companies out is “including contract-workforce”. On many sites, contractors carry out some of the highest-risk work, and their hours and injuries are often held by the contractor rather than by you.

Who is covered, and when

SEBI’s circular of 28 March 2025 sets the glide path. Listed companies “shall mandatorily undertake assessment or assurance of the BRSR Core”, ranked by market capitalisation:

Financial year	Companies covered
2023-24	Top 150 listed companies
2024-25	Top 250 listed companies
2025-26	Top 500 listed companies
2026-27	Top 1,000 listed companies

The same circular made two changes worth knowing about.

• Assessment or assurance. Companies can now choose either. “Assessment” means a third-party assessment carried out under standards developed by the Industry Standards Forum (ISF) in consultation with SEBI.
• Independence. The board must make sure the provider has the necessary expertise, and that there is no conflict of interest: the provider and its associates may not sell products to the company or its group, or provide them with other services, including consulting. Your BRSR names the provider and the type of assessment or assurance obtained.

ESG disclosures for the value chain follow a separate, voluntary track: disclosure is voluntary for the top 250 from FY 2025-26, and its assessment or assurance is voluntary from FY 2026-27. For the wider picture of SEBI’s ESG rules, see SEBI – ESG Disclosures, Rating & Investing.

What an assessor will look at

Assessment and assurance both test where a figure came from, not only whether the arithmetic adds up. For the safety figures, expect questions in four areas.

The hours behind LTIFR

LTIFR has two inputs, and the denominator gets less attention than it deserves. Working hours should come from attendance or payroll records, and they must cover the same people as the injuries. A rate built on injuries for everyone but hours for employees only will look worse than it is. One built the other way round will look better. Neither will survive a check.

What counts as a lost-time injury

Sites often differ on when a case becomes lost time, and on how restricted work or a transfer to lighter duties is treated. SEBI describes the approach in its format as “only a base methodology”, and says any changes or industry-specific adjustments must be disclosed. So pick one definition, apply it at every site, and be ready to show which one you used.

Whether the records match the reports

Permanent disabilities are checked against claims, and fatalities against claims as reported to the Factory Inspector. If an injury was reclassified after it was reported, or a contractor fatality was handled only by the contractor, expect questions.

The reporting route itself has changed. The Occupational Safety, Health and Working Conditions Code, 2020 came into force on 21 November 2025, bringing the Factories Act, 1948 and other safety laws into one code, and it replaces the traditional inspector with an Inspector-cum-Facilitator. How and when accidents must be reported now depends on the central or state rules that apply to each site, so confirm the current requirement for every location before you reconcile.

A trail for every change

Assessors look for evidence that the figures weren’t adjusted to fit. When a case is reclassified, they will want to see when it changed, who changed it, why, and what it was before.

Where the numbers usually break

• A spreadsheet per site. Each site keeps its own log, with its own columns and definitions, and the corporate team stitches them together at year end.
• Missing contractor hours. Contractor injuries are logged, but their hours are estimated from headcount, or left out.
• Late entries. Minor injuries reach the log weeks later, after the monthly figure has gone out.
• Silent reclassification. A lost-time case is downgraded after a doctor’s note, with no record of the original classification or the reason.
• Two versions of the truth. The figure in the BRSR doesn’t match what went to the authorities, the insurer or the board.
• No link to action. The incident is recorded, but the investigation and corrective actions live in email, so nobody can show they were closed.

A checklist for the rest of FY 2026-27

The financial year ends on 31 March 2027, and the figures cover the whole year. The work now is to keep the remaining months clean and repair the months already gone.

1. Agree definitions. Write down what counts as a lost-time injury, a permanent disability and a working hour, and apply them at every site and for every contractor.
2. Collect hours monthly. Take employee hours from attendance or payroll, and contractor hours from the contractors, every month rather than at year end.
3. Keep one record per incident. Report each incident once, from the site, with its classification, investigation and corrective actions on the same record.
4. Reconcile every month. Compare your incident figures with statutory reports and insurance claims, and resolve differences while people still remember the case.
5. Log every change. Record each reclassification with the date, the person and the reason, and keep the original visible.
6. Do a dry run. Before March, take last year’s figures through the checks an assessor would make, and fix what breaks.
7. Appoint the provider early. Check the expertise and independence conditions above, and agree the scope and method before year end.

How Rampart helps

Rampart runs EHS and ESG on one platform, so the figures in your BRSR come from the same records your sites work from.

• Incidents, from site to CAPA. Teams report incidents from site, run root cause analysis and raise corrective actions on the same record.
• An audit trail that can’t be altered. Every report, edit, approval and attachment is time-stamped with the role that made it, so you can show an assessor who did what, and when.
• ESG data from every site. Collect ESG data across sites and business units once, and report it for BRSR alongside GRI, CDP and other frameworks.

See EHS & HSSE and ESG & Sustainability for more, or book a demo below.

Sources

• SEBI circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, 28 March 2025
• Format of BRSR Core (Annexure I), SEBI, July 2023
• Ministry of Labour and Employment: the four labour codes come into force, November 2025

This article summarises these documents as of October 2026. It is general information, not legal advice: check the current circulars, and your provider’s method, for your company’s position.