What 20 Years of Environmental Auditing in Indian Industry Teaches You That No ESG Framework Ever Will

By Dr. Rajani Chamala Chairman & MD - ESG and Sustainability, Sustera Global

I have spent a significant portion of my career inside Indian industrial facilities. Cement plants, steel mills, chemical manufacturing sites, power generation assets, textile processing units. Auditing environmental performance, reviewing regulatory compliance, assessing how organisations manage the intersection of their operations and the natural systems around them.

What I find when I walk into a plant and what frameworks like GRI, BRSR, or TCFD are designed to capture are not always the same thing. Sometimes the gap is technical. More often, it is structural. And understanding that gap - not as a failure of the frameworks, but as a fundamental limitation of what standardised disclosure was ever designed to do - is the starting point for understanding why ESG strategy in Indian industry so frequently stalls between intent and reality.

What Frameworks Are Designed to Do

ESG disclosure frameworks are built for a specific purpose: comparability. Their designers want a company in Chennai to produce a report that a pension fund manager in Amsterdam can evaluate alongside a company in Frankfurt. To achieve that comparability, frameworks standardise the questions, the boundaries, the measurement methodologies, and the reporting structure. This is a legitimate and important objective. Capital allocation at scale requires comparable information.

But comparability comes at a cost. Standardisation requires that the question asked of every company is a question every company can answer in the same way. That means the framework must abstract away from the specifics of any given operational context. It must ask about energy intensity at a general level, not about the specific inefficiencies of a particular rotary kiln operating at 60 per cent capacity in a facility that was built in 1987 with the kind of operational knowledge that has been accumulated in the memory of a workforce, not in any documented system.

The frameworks, by design, cannot see that level of detail. They were never intended to.

"The difference between intake and consumption requires tracking within the facility, across processes, including losses that many facilities have neither measured nor mapped."

What You Find When You Are Actually There

When I conduct an environmental audit of an Indian industrial facility, I am not reviewing what the facility has reported. I am reviewing what the facility actually does - the gap between those two things is where the most important information lives.

A few patterns that appear consistently, across sectors and geographies:

Energy reporting diverges from energy reality at the process level. Most facilities track total energy consumption at the utility metre level - because that is what billing requires. When you trace energy flows through individual processes, the story is different. High-energy processes with deteriorating equipment, operating sequences that result in significant idle-running losses, steam and heat systems that leak at rates that have become operationally normalised. None of this appears in an energy intensity figure. But it is where the real efficiency opportunity is, and it is where the real emissions exposure lives.

Water is the disclosure area with the widest gap between reported and actual. Water consumption figures in ESG reports almost always represent metered intake. They rarely represent actual consumption - because the difference between intake and consumption requires tracking within the facility, across processes, including losses that many facilities have neither measured nor mapped. A facility that reports 500,000 kilolitres of water consumption may have very limited understanding of where that water actually goes within its boundary.

Waste data is the least reliable ESG figure in Indian industrial operations.  Not because companies are being deliberately misleading, but because waste streams in complex industrial facilities are generated across dozens of points, handled by multiple contractors and intermediaries, and tracked with uneven rigour depending on the regulatory classification of the waste type. The e-waste and hazardous waste records are usually well-maintained because regulatory requirements are strict. The non-hazardous solid waste and process by-product data is frequently estimated, aggregated, and less precisely traceable than the corresponding figures in an ESG report would suggest.

The Framework Cannot See This and It Is Not Supposed To

None of what I have described is a deficiency in the ESG frameworks. GRI G4 was not designed to find inefficiencies in a specific facility's steam distribution system. BRSR was not designed to audit the precision of an individual facility's water balance. They are designed to produce a comparable, structured disclosure at the entity level.

Data Beyond Disclosure

This distinction - between framework compliance and operational understanding - is the difference between ESG that changes what a company does and ESG that changes what a company reports.

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The problem arises when companies - and their advisors - treat a framework-compliant disclosure as equivalent to having addressed the underlying operational reality. When the BRSR report shows that energy intensity improved by 4 per cent, the board is satisfied. But if the energy intensity figure is built on consumption data that was never mapped at the process level, the 4 per cent improvement may reflect a genuine efficiency gain, a change in production mix, a measurement artefact, or some combination of all three. Without operational-level data, it is impossible to know which.

What This Means for ESG Strategy

The implications are practical, not philosophical.

Organisations that treat ESG frameworks as operational guides will build reporting systems. Organisations that treat ESG frameworks as disclosure tools and build operational measurement systems alongside them will build something more durable: a genuine understanding of their environmental performance that survives the inevitable tightening of assurance requirements and the equally inevitable deepening of investor and regulatory scrutiny.

The frameworks are necessary. They are the language in which ESG performance is communicated to markets and regulators. But they are not sufficient as a guide to where the actual work is, what the actual risks are, and where the real improvement opportunities exist.

That knowledge lives at the operational level. It requires time inside the facilities, not just time with the data. And for most Indian industrial organisations, it has not yet been developed systematically.

That is the work that matters. And it is, by definition, the work that no framework can do for you.