India: How India's Leading Listed Companies Fare On Disclosure Standards

Last Updated: 12 September 2017
Article by Amrit Singh Deo

Executive Summary

2017 builds on positive disclosure-related regulatory requirements – the New Companies Act 2013 and amended Clause 49 SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 – pushing for higher voluntary disclosure standards, including those around board evaluation. The capital market regulator SEBI has posed an apt question - 'who is evaluating the evaluators?' (in this case, the corporate board) and is the evaluation a robust process? Superior disclosure practices are a proxy for superior management quality and better corporate governance; and we can now add board governance to that list too. This is a positive development for India, a capital markets jurisdiction where charismatic promoters have traditionally held sway over the boards of their companies.

The India Disclosure Index 2017 report, the third edition of its series, reveals a strong embrace of Voluntary Disclosure by Indian companies, coming on the back of previous year's progress on Mandatory Disclosure (even though 22% of Top 100 companies, by market capitalisation, continue to fall short on this measure). The 6.8/ 10 Composite Disclosure Score and 5/ 8 Voluntary Disclosure Score for India's Top 100 companies are good but this significance is evident when reviews movements on individual parameters.

The research methodology for the 2017 report was finalised with the help of an expert research jury (see below). Subsequently, FTI Consulting reviewed publicly available information disclosed by 200 leading listed Indian companies (by market capitalisation) to create a weighted, Composite Disclosure scoring system - with seven parameters for Mandatory Disclosure and eight for Voluntary Disclosure. A re-weighting of parameters marks a significant change in research methodology from previous years, making direct comparisons with previous year's Composite and Voluntary Disclosure scores misleading. The number of companies that provide information on specific individual parameters has risen steadily (specifically for Earnings Transcripts, Margin Improvement Narratives, Risk Metrics and Whistle-Blower Mechanism):

  • 78% of Top 100 companies provided Earning Transcripts (this was 73% in 2016 and 49% in 2015). Amongst the Next 100 companies (by market capitalisation), this was 53% in 2017 (as compared to 49% in 2016)
  • 73% of Top 100 companies provided Margin Improvement Narratives (this was 54% in 2016).
  • 50% of Top 100 companies provided adequate Risk Metrics (this was 32% in 2016).
  • 71% of Top 100 companies provided convenient Whistle-Blowing Mechanisms (this was 68% in 2016)

Three companies – Axis Bank, Infosys and State Bank of India – scored 10/ 10 on the weighted Composite Disclosure score. 22 Indian companies in the Top 200 list scored higher than 9/ 10 and may be considered 'Disclosure Champions'. Two years back, such champions came from one or two sectors. This year, they come from four knowledge economy and three 'old economy' sectors. Each of these companies are setting an example on corporate disclosure for other companies in their respective sectors.

Six companies engaged third-parties for evaluating performance of their boards - an optimistic number given the fairly recent guidance from SEBI on the matter. This number can be expected to grow in following years.

Higher Voluntary Disclosure scores indicate Corporate India is taking a progressive view of disclosure, beyond a legalistic definition. However, one must bear in mind that 'disclosure standard' itself is a moving target and this report covers leading Indian companies only. Boards could articulate 'disclosure policies' anticipating new risks, regulatory developments and global best practices and better prepare their companies to attract 'transparency premiums' from investors.

Research Jury for India Disclosure Index 2017

The research methodology for India Disclosure Index 2017 has been modified from previous year's methodology after consultations with a specially constituted three-member research jury comprising of eminent professionals from the regulatory, legal and institutional investment fraternity.

The three-member research jury that finalised the methodology for India Disclosure Index 2017 comprised of:

  • Dr. V. R. Narasimhan, Chief Regulatory Officer, National Stock Exchange (NSE)
  • Sandeep Parekh, Founder Partner, Finsec Law Advisors
  • Vikram Desai, Director, Canada Pension Plan Investment Board (CPPIB) India

The jury made pertinent observations about how corporate disclosure behaviour and regulatory focus had moved beyond mandatory disclosure to voluntary disclosure standards; and recommended an appropriate re-weighting of parameters. The jury also favoured a more ambitious interpretation of the definition of 'board evaluation' favouring 'evaluation by a third-party' as a preferred international benchmark. These meaningful interventions ensure that India Disclosure Index  2017 is sufficiently dynamic and updated to the current environment. FTI Consulting expresses thanks to the jury for their time and support for this non-commercial, public-research initiative.

India Disclosure Index 2017 Report Findings

Composite Disclosure Scores

Overall as a group, the Top 1001 listed Indian companies (by market capitalisation) have an average Composite Disclosure score of 6.8/ 10.

  • Almost 26% have Composite Disclosure scores of eight or more – and three companies stand out for achieving the maximum score of 10 / 10. They are Axis Bank, Infosys and State Bank of India.
  • 14% of the Top 100 listed Indian companies have low Composite Disclosure Scores – scoring five or less.

The Next 1002 listed Indian companies have an average Composite Disclosure score of 6.2/ 10, with no company achieving the maximum score of 10/ 10. Furthermore, 23% of the Next 100 listed Indian companies have an average Corporate Disclosure score of five or less.

22 companies across both groups of companies, Top 100 and Next 100, have a Composite Disclosure score higher than 9/ 10. These companies are from a wide range of industries and can be viewed as sector champions for corporate disclosure standards. Classified by industry, they are:



Financials (6)

Axis Bank, State Bank of India, IndusInd Bank, YES Bank, Federal Bank, Union Bank

IT/Technology/Telecom (4)

Infosys, Bharti Airtel, Bharti Infra, Mindtree

Pharma/ Life Sciences (3)

Lupin, Piramal, BioCon

Manufacturing (3)

Mahindra & Mahindra, Apollo Tyres, Supreme Industries

Metals & Mining (3)

Tata Steel, UPL, Vedanta

Consumer Products/ Services (2)

Hindustan Unilever, Dish TV

Power/ Energy (1)

JSW Energy

Mandatory Disclosure Scores

Overall as a group, the Top 100 listed Indian companies have an average Mandatory Disclosure score of 1.8 /2.

  • 78% of the Top 100 companies score a full 2/ 2 for Mandatory Disclosure (up from 71% in 2016 and 41% in 2015), with the remaining 22% falling short on either one or some of the mandatory disclosure parameters.
  • 78% of Top 100 companies provide information on 'analyst engagement information AND earning call transcripts'. This is marginally up from 73% in 2016 and significantly up from 49% two years back (2015).

The Mandatory Disclosure score for the Next 100 listed Indian companies is also 1.8 /2, with the weakest performance on 'Analyst Engagement Information AND earning call transcripts'. 53% of these companies disclose this information on their corporate websites (up from 49% in 2016).

Voluntary Disclosure Scores

Overall as a group, the Top 100 listed Indian companies score an average of 5/ 8 for Voluntary Disclosure, when reviewed against eight voluntary disclosure parameters (see methodology).

  • Only three of the Top 100 listed Indian companies have a full 8/8 score for Voluntary Disclosure. These were Axis Bank, Infosys and State Bank of India.
  • 24% of the Top 100 listed Indian companies have Voluntary Disclosure scores of 4/ 8 or less. Two companies have Voluntary Disclosure scores below 1/ 8, and there is a company with a zero Voluntary Disclosure score.
  • 50% of companies provided adequate information on risk metrics, significantly up from 32% in 2016.
  • 71% of the Top 100 constituents provided convenient whistleblowing mechanisms to report fraud or unethical activity through a convenient channel (email/phone), up from 63% in 2016.
  • Insufficient information about adoption of Indian Accounting Standards (IndAS) and its impact on financials; and 'board evaluation without the involvement of external third-parties' were the two most significant reasons for low Voluntary Disclosure scores.
  • Six companies use external third-parties for evaluation of the board. They are Axis Bank, Dr. Reddy's Lab, Infosys, Kotak Mahindra Bank, ONGC and State Bank of India.
  • 47% of Top 100 Indian companies provide information on adoption of IndAS and its impact on financials in their Annual Reports.
  • Voluntary Disclosure on Risk Metrics and Margin Improvement Narrative saw the biggest jump from 2016 numbers. 73% of companies provide Margin Improvement Narrative in 2017, up from the 54% figure in 2016 The average Voluntary Disclosure score for the Next 100 companies was 4.6/ 8, with the weakest performance on 'Board Evaluation by Third Party' (done by only one Next 100 company) followed by 'Risk Management Metrics'.
  • 66% of Next 100 listed Indian companies provided debt related information, an improvement from 40% in 2016.
  • 66% provided adequate strategy-related information, up from 49% in 2016.

Two Qualitative Observations: Disclosure Best Practices

While reviewing disclosure information of all 200 companies, the FTI Consulting research team came across two specific noteworthy examples – for the spirit of transparency (in the first instance) and a broad view of risk (in the second):

  • The first instance was one of the Top 100 companies, specifying the number of whistle-blowing instances in the last 12 months, the exact nature of complaints and steps taken to address them.
  • The second was explicit mention of the impact of international regulations, specifically 'The Modern Slavery Act 2015' in this case, on Indian operations.

Both instances are commendable examples of voluntary disclosure in their true spirit, and an indication of how new standards could evolve in the next 18-24 months. Risks arising from international regulations (around anti-bribery, corruption and human rights) will impact Indian companies with overseas operations as well as those that are part of global supply chains. This is an important point for board-level discussions.

Download >> How India's Leading Listed Companies Fare On Disclosure Standards

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

*** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.