Raterlens

Shows a listed company why each ESG rater scored it the way it did

Enterprises

TL;DR Raterlens is software for the sustainability and investor-relations teams of mid-sized listed companies. It gathers every ESG score the company has received, traces each one back to the disclosures the rater used and builds a correction pack per rater. The company pays an annual subscription, and Raterlens never issues a rating of its own.

The problem

ESG ratings disagree with each other far more than credit ratings do. A study of six large raters found pairwise correlations between 0.38 and 0.71, and put most of the gap down to how each rater measures the same thing, not what it chooses to weigh[1]. So a company can look like a leader to one rater and a laggard to the next.

In India this now hits more firms. The top 1,000 listed companies file a Business Responsibility and Sustainability Report, and SEBI's 2023 plan brings the top 500 under assured BRSR Core metrics from FY 2025-26[2]. Since a 2025 SEBI circular, stock exchanges show ESG ratings on company pages[3], which means a weak score sits right in front of every investor and it's often built from public data the company never got to check.

The idea

What it does, in regulatory terms: a data reconciliation tool for the rated company only. Raterlens does not produce an ESG rating, score or ranking of any security, so it should stay outside SEBI's certification rules for ESG rating providers[4]. It gives no investment advice. Get securities counsel to confirm that boundary before launch, especially for any feature that predicts a score.

The company uploads its BRSR, annual report and policies. Raterlens pulls in the published scores and methodology documents from every SEBI-registered rater that covers it, then maps each scored theme to the exact BRSR field or document behind it. What comes out is a gap list - data the rater missed, figures it read wrong, policies that exist but were never published and disclosures that just aren't there. For each rater, it drafts a short evidence pack the company can send through that rater's feedback channel.

The original version of this idea was AI that rates companies in real time. Under SEBI's rules that would make the startup a rating provider, with certification and a single pay model to deal with[4]. Helping the rated company read its ratings needs neither.

Who pays

The user is the sustainability head or company secretary, but the budget usually sits with the CFO or investor-relations head. Aim at companies roughly between the 150th and 1,000th largest by market cap, which are inside BRSR, rated by several raters and don't have an in-house ESG analyst team. I couldn't find a public price for ESG-rating advisory in India, so an annual subscription per company is my assumption. Consultancies and assurance firms that do BRSR work could resell it.

Why now

SEBI brought ESG rating providers under certification from July 2023, with published methodologies and E, S and G weights[2]. The April 2025 ERP circular added withdrawal rules and display on exchange pages[3]. BRSR Core assurance reaches the top 500 in FY 2025-26 under the 2023 glide path[2]. Every step gives companies more reason to care and gives a tool more published methodology to map against.

Market signal

Nobody publishes a figure for an ESG-rating reconciliation market in India. The narrowest base you can count is the 1,000 listed companies that must file BRSR, of which the top 500 come under BRSR Core assurance from FY 2025-26[2]. As an adjacent number, one global rater alone rates more than 17,000 issuers worldwide[5], which tells you how many companies sit under rater coverage they never asked for.

Who's already doing this

One Indian rater says it's a SEBI-registered Category 1 ESG rating provider and sells a subscription product built on public data[6]. It's a rater though, not the company's advocate. A sustainability-software firm offers a check of a company's BRSR filing for material inconsistencies[7], which is close but looks at the report, not what raters did with it. A big global rater runs an issuer resources channel for companies it covers[5]. I found no Indian tool that reconciles all of a company's ESG scores in one place.

How hard is it?

Difficulty Moderate (38/100)
Starting capital ₹45–85 L
Time to launch 5–8 months

The software is document parsing plus a mapping layer, nothing exotic. The hard part is analyst work, because each rater's methodology keeps changing and someone has to keep the theme-to-BRSR map current for every rater and sector. Raters also publish full rationales only to subscribers[3], so some reconciliations will be partial.

Licences and approvals

Raterlens should need no licence of its own, but only if it stays clear of issuing ratings. That line is the whole regulatory story.

  • SEBI ESG rating provider certification applies to anyone issuing ESG ratings. Never publish a score, rank or predicted rating, and get counsel to confirm this in writing before launch[4][2].
  • SEBI's April 2025 ERP circular splits public scores from subscriber-only rationales. Check each rater's terms before storing their documents[3].
  • SEBI investment adviser registration is needed for securities advice. Keep the rated company as the client and give no buy, sell or hold view[8].
  • DPDP Act compliance for user accounts and employee-level inputs[9].
  • Company registration with the MCA and GST on subscriptions.

Building this outside India? The categories above usually have a local equivalent, so check with your own regulator.

How AI can power this business

  • Methodology mapping. Read each rater's published methodology and map its themes to BRSR fields, so analysts update the map when a rater changes it instead of rebuilding it.
  • Gap finding. Compare what a rater used against the company's own reports and flag data it missed or read wrong.
  • Draft correction packs. Write the first version of each evidence pack, with page references, for the sustainability team to review.
  • Change alerts. Flag when a rater updates a score or methodology that affects the client.

AI must never produce a score or predict one. That would turn Raterlens into an unregistered rater, so keep every output tied to a document.

Want to work out the AI layer for Raterlens? Talk to Yash →

Biggest risks

Here's what can go south -

  • Regulatory drift. If any output looks like a score or a forecast of one then SEBI could treat Raterlens as an unregistered rater.
  • Rater access. Detailed rationales sit behind subscriber paywalls, which limits how far the tool can trace a score.
  • Small buyer pool. A thousand companies, many already with consultants, makes for a short list and slow enterprise sales.

Our take

I think it's a fair bet for a founder who has done BRSR or ESG assurance work and can sell to CFOs. If you want to build a rating brand then this is not it, because that is a different, licensed business. Prove two things first - that five listed companies will pay to reconcile their own scores, and that at least two raters accept the correction packs.

Questions founders ask

Plan for roughly ₹45–85 L, mostly on document parsing and the analysts who keep each rater's map current.

Do I need SEBI approval to build ESG rating software in India?

Not if the tool only helps a company understand its own ratings. Issuing any score would need SEBI certification as an ESG rating provider, so confirm the boundary with counsel.

Can I build an ESG rating reconciliation tool in another country?

Yes, ratings disagree everywhere. Check local rules on ESG rating providers, since the EU and others are bringing raters under regulation too.

Download the kit

The free Raterlens validation kit has the line-by-line capital breakdown, the effort scoring, the SEBI rating-provider and data-protection checklist, a 14-day validation sprint with pass/fail targets, a 90-day launch plan, 10 interview questions for listed companies, and 5 assumptions to test. Download the kit →

Talk to Yash

Thinking about building Raterlens or something close to it? The make-or-break bit is keeping the product on the right side of SEBI's line between explaining a rating and issuing one, and that's exactly the kind of thing I help founders with. If you need a hand, you know where to find me. Talk to Yash →

Sources

  1. Berg, Kölbel & Rigobon, "Aggregate Confusion: The Divergence of ESG Ratings", Review of Finance 26(6), 2022. https://academic.oup.com/rof/article/26/6/1315/6590670
  2. India Briefing, "India's updated sustainability reporting format and rules for ESG ratings providers", 2023-07-25. https://www.india-briefing.com/news/india-brsr-core-esg-rating-provider-regulation-29062.html
  3. SCC Online Blog, "Navigating SEBI's 2025 ESG circular", 2025-09-22. https://www.scconline.com/blog/post/2025/09/22/navigating-sebis-2025-esg-circular-an-independent-directors-lens-on-sustainability-transparency-and-regulatory-coherence/
  4. SEBI, "Credit Rating Agencies Regulations 1999 (last amended 15 January 2026)", accessed 2026-10-18. https://www.sebi.gov.in/legal/regulations/jan-2026/securities-and-exchange-board-of-india-credit-rating-agencies-regulations-1999-last-amended-on-january-15-2026-_99126.html
  5. MSCI, "ESG Ratings", accessed 2026-10-18. https://www.msci.com/data-and-analytics/sustainability-solutions/esg-ratings
  6. ESGRisk.ai, official site, accessed 2026-10-18. https://www.esgrisk.ai/
  7. Sprih, official site, accessed 2026-10-18. https://www.sprih.com/
  8. SEBI, "Investment Advisers Regulations 2013 (last amended 25 November 2025)", accessed 2026-10-18. https://www.sebi.gov.in/legal/regulations/nov-2025/securities-and-exchange-board-of-india-investment-advisers-regulations-2013-and-securities-last-amended-on-november-25-2025-_98246.html
  9. PRS Legislative Research, "Digital Personal Data Protection Bill 2023", 2023-08. https://prsindia.org/billtrack/digital-personal-data-protection-bill-2023

For illustration only. Names are fictional and ideas hypothetical; sourced facts are real but may be out of date. Nothing here is legal, financial or professional advice, and Yash Khatri is not personally liable for any use of it. Read the full disclaimer.

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