Carbon Compliance

India CCTS

BEE PAT

Find out whether you're earning credits or buying them.

Your Greenhouse Gas Emission Intensity target is already set. Beat it and the surplus becomes Carbon Credit Certificates you can sell; miss it and you're buying CCCs, or paying a penalty priced to make buying the cheaper option. Most obligated entities don't know which side of the line they're on until the year has closed. Carbon Compliance tells you during it.

It applies whether or not you export a single tonne.

§ 1

Who is obligated

Obligation arrives by notification, not by choice.

Cross BEE's energy-consumption threshold in a notified sector and you are designated automatically. Two notifications are in force. A third, covering the largest tranche of all, is still only a draft — worth knowing before you accept a headline count.

CCTS obligated entities by Gazette notification, showing in-force and draft tranches
NotificationEntitiesSectors
G.S.R. 739(E)8 Oct 2025In force282

Aluminium / Cement / Chlor-alkali / Pulp & paper

G.S.R. 25(E)13 Jan 2026In force208

Secondary aluminium / Petroleum refinery / Petrochemicals / Textile

G.S.R. 517(E)26 Jun 2026Draft — not binding255

Iron & steel

490 entities carry a binding target today. The 255-entity iron & steel tranche is a draft notification with an objection window — counts of "~740 across 9 sectors" add it to the total before it is in force.

Gazette of India

BEE — notifications

checked 2026-08-09

PIB — entity counts

checked 2026-08-09

Primary source

§ 2

Target & penalty

The metric is intensity. The penalty is a multiple.

The target

GEI measures tonnes of CO2-equivalent per unit of output, set at the sub-sector level against a fixed baseline year under the Greenhouse Gases Emission Intensity Target Rules, 2025 — assigned automatically once you cross BEE's energy-consumption threshold in a notified sector.

Missing it

Beat your target and the surplus is issued as Carbon Credit Certificates, sellable to entities that fell short. Miss it and you buy CCCs to cover the gap — or face an environmental compensation penalty set attwice the average traded CCC pricefor that compliance year, enforced by the Central Pollution Control Board under the Energy Conservation Act, 2001.

Rule 6, G.S.R. 739(E)

§ 3

Credit lifecycle

A credit is a record, not a number in a cell.

  1. 01

    Projected

    Modelled ahead of the compliance year from your production plan and historical GEI.

  2. 02

    Submitted

    Filed with the compliance-year data once the year closes.

  3. 03

    Issued

    BEE confirms the surplus against your target and issues Carbon Credit Certificates.

  4. 04

    Held / traded / retired

    Hold as a buffer, sell on the Indian Carbon Market, or retire against a shortfall — tracked as one continuous record.

One continuous record

Not a balance that resets each year — a credit keeps its history from modelled to retired.

§ 4

The filing path

What a CCTS filing actually requires.

Six steps, in this order, from the Bureau's compliance procedure. The one most often missed is the second: the verification is not a review you commission if you want assurance — it is the only route to a filing that exists. What the agency does, and which acts the procedure assigns to you rather than to them, is set out on the verification page.

  1. 01

    Report the year's energy and emissionsForm I

    The annual Carbon Emission Accounting form. Proof that you filed it on time has to accompany the performance assessment later, so it is the first thing a verifier asks for and the easiest thing to be unable to produce.

  2. 02

    Appoint an accredited verification agency§ 5(2)

    You appoint it — the obligation is yours, not BEE's. And you cannot skip it: verification has to be done through an accredited agency, so there is no compliant route that ends with you certifying your own numbers.

  3. 03

    The agency verifies, on site§ 5(4)

    Its team and their roles are communicated to you before it begins, and at least one site visit is required. Anything it finds — a discrepancy, a data gap, a figure it cannot trace — it must document and put to you for explanation with supporting evidence.

  4. 04

    The interaction goes in the report§ 5(8)

    The verification report has to record the exchange between you and the agency, and any change the agency made to its assessment because of what you supplied. That thread is part of the filing, not a private conversation.

  5. 05

    File Form A together with Form B§ 5(1)

    The performance assessment document goes in with the agency's certificate of verification — within three months of the conclusion of the compliance cycle. One without the other is not a filing.

  6. 06

    It can be reopened§ 6

    BEE can start an independent review up to six months after the compliance report or three months after certificates are issued, whichever falls later — and the agency that signed your Form B has ten working days to stand behind it, point by point.

Deadlines run from the cycle's conclusion, not a calendar date

§ 5

On the platform

What a compliance cycle looks like here.

  • One data set, two regulations

    The same production, fuel and electricity data that produces your CBAM figure also produces your CCTS GEI figure.

  • Target tracking through the year

    See your projected position against target before the compliance year closes, not after.

  • Form A assembled, with the gaps named

    Every field of the performance assessment document is sourced from data you already hold — and where something is genuinely missing, it says which field and why it matters, rather than rendering a blank that reads as nil on a form carrying a personal indemnity undertaking.

  • Form B, and the verification behind it

    The appointment, the site visit, the findings thread and the opinion are all recorded, and the certificate is rendered from them. The preconditions the procedure sets are checked before an opinion can be issued, so a certificate cannot be produced for verification work that has not happened.

  • Your verifier is a participant, not a recipient

    The agency you appoint gets its own access, scoped to the cycle it was appointed for — and the acts the procedure assigns to the agency cannot be performed by your own staff. That separation is enforced, not just documented.

  • An evidence pack, not a dashboard screenshot

    Your GEI position with every figure traceable back to the invoice, meter reading or ledger line it came from — backed by the same hash-chained audit trail as your CBAM filing, so your verifier has something to check rather than take on trust.

  • A credit ledger, not a spreadsheet

    Every CCC tracked from projected through retired, so you know your real position before you decide to buy or sell.

Concurrent, not sequential

§ 6

Questions

Questions we actually get asked.

What is a GEI target, exactly?
Greenhouse Gas Emission Intensity — tonnes of CO2-equivalent per unit of output for your sub-sector, set against a baseline year. Beat your assigned intensity and the surplus becomes Carbon Credit Certificates (CCCs); miss it and you have a shortfall to cover.
What happens if we miss our target?
You buy CCCs on the Indian Carbon Market to cover the shortfall, or face an environmental compensation penalty set at twice the average traded CCC price for that compliance year — enforced under the Energy Conservation Act, 2001, as amended in 2022.
Are we actually an obligated entity?
If you're in a notified CCTS sector and cross BEE's energy-consumption threshold, you're automatically designated — it doesn't depend on whether you export anything. Obligations have applied to 490 entities across the notified sectors since the January 2026 tranche.
Can we do the verification ourselves?
No. The compliance procedure requires verification to be done through an accredited carbon verification agency, and Form A has to be filed together with that agency's certificate of verification — so there is no compliant filing that does not involve one. You appoint the agency; the obligation to do so is yours.
Does this replace our EU CBAM filing?
No — they're separate obligations calculated from the same underlying plant data. Carbon Compliance runs both methodologies off one data set so you're not maintaining two spreadsheets. See the CBAM page.

Asked by obligated entities

Next

Are you obligated?

Not sure if you're an obligated entity?

One call. We check your sector and your energy consumption against BEE's threshold and tell you exactly where you stand.

Book a compliance assessment