CCTS India 2025-26: which 490 companies must comply and what to do

India's Carbon Credit Trading Scheme crossed from theory into practice in 2025-26. With the first verified GHG emission intensity reports due to BEE by July 31, 2026, obligated companies in nine sectors need to move quickly. For consultants who have been preparing BRSR filings for manufacturing clients, CCTS is both a natural extension of that work and a distinct new compliance obligation with its own verification requirements and commercial consequences.

What CCTS is and where it comes from

The Carbon Credit Trading Scheme (CCTS) is India's national carbon market framework, notified by the Ministry of Environment, Forest and Climate Change (MoEFCC) under the Energy Conservation (Amendment) Act 2022. The Bureau of Energy Efficiency (BEE) is the implementing agency. BEE sets sector-specific GHG emission intensity (GEI) targets for each obligated sector through what are called GEI Target Orders. Obligated entities that achieve their GEI target earn Carbon Credit Certificates (CCCs), which can be traded on the Indian Carbon Market (ICM). Those that miss the target must purchase sufficient CCCs to cover the shortfall.

Which nine sectors are obligated

BEE notified the nine obligated sectors in two tranches. The first four sectors were notified in October 2025: aluminium, cement, chlor-alkali, and pulp and paper. The remaining five sectors followed in January 2026: petroleum refining, petrochemicals, textiles, iron and steel, and fertilisers. Approximately 490 entities across these nine sectors are obligated in the first compliance year. The exact list of obligated entities is maintained by BEE and can change as BEE updates its assessments.

What obligated companies must do this year

For FY 2025-26 (the first compliance year), obligated entities must: measure their actual GHG emission intensity for the full financial year (April 2025 to March 2026); have that GEI measurement independently verified by a BEE-accredited third-party verification agency following ISO 14064-3 or equivalent; and submit the verified GHG emission intensity report to BEE by July 31, 2026.

The CCTS-BRSR overlap: avoiding double work

The GHG data required for CCTS is substantially the same as the data required for BRSRP6-E1 (GHG emissions, Scope 1 and Scope 2). Both require monthly fuel consumption by type, monthly electricity units purchased, production volume (as the intensity denominator), and cited emission factors with version references. The key difference is that CCTS requires GHG intensity expressed at the entity or plant level (tCO2e per unit of production for the specific product), while BRSR P6-E1 can be at the company level. For a single-product manufacturer, these are the same calculation. For a diversified manufacturer, some allocation methodology is required.

The practical advice: build a single data collection workflow that captures monthly energy and production data in enough detail to satisfy both requirements. If your client uses Saaksh Collect for BRSR data collection, the fuel and electricity inputs that feed the BRSR GHG calculator are the same inputs needed for the CCTS GEI report.

When CCC trading starts and what it means commercially

CCC trading on the Indian Carbon Market (ICM) is expected to begin in October 2026 (delayed from the originally planned April 2025 start). Obligated entities that beat their BEE GEI target in FY 2025-26 will receive CCCs that can be sold on the ICM from October 2026. Those that miss the target must buy sufficient CCCs to cover the shortfall before the compliance deadline. The price of CCCs will be set by the market, but early estimates from government consultations suggest an indicative range of ₹200 to ₹400 per CCC (each CCC represents one tonne of CO2 equivalent).

The EU CBAM connection

There are ongoing discussions between India and the EU about whether BEE-verified CCTS data could be recognised under the EU's Carbon Border Adjustment Mechanism (CBAM). If recognised, Indian exporters in the nine CCTS sectors who export to the EU could use their BEE-verified GHG intensity data to satisfy the CBAM embedded-emissions reporting requirement, potentially reducing their EU importers' CBAM certificate obligations. These discussions are ongoing and no formal agreement has been reached. However, the data trail being built for CCTS verification (monthly fuel data, sub-meter readings, verified GEI report) is exactly the data trail that EU importers would need for CBAM in any case.

Key takeaways

• Nine sectors (approximately 490 entities) are obligated under CCTS from FY 2025-26: aluminium, cement, chlor-alkali, pulp and paper, petroleum refining, petrochemicals, textiles, iron and steel, fertilisers.
• Obligated entities must submit a BEE-verified GHG emission intensity report by July 31, 2026.
• Verification must be done by a BEE-accredited verification agency following ISO 14064-3 or equivalent.
• The underlying data for CCTS is substantially the same as BRSR P6-E1. Build one workflow to satisfy both.
• CCC trading is expected to begin October 2026. Companies that beat their GEI target earn tradeable CCCs.