New Delhi – India’s compliance carbon market reaches its first real test this year. Roughly 490 obligated entities across seven energy-intensive sectors have been operating under binding targets since April 2025, and 2026 is when the paperwork turns into a price.
The Carbon Credit Trading Scheme is administered by the Bureau of Energy Efficiency. Nine sectors have been notified in total: aluminium, cement, chlor-alkali, fertiliser, iron and steel, pulp and paper, petrochemicals, petroleum refinery and textile. Any facility crossing the prescribed energy consumption threshold inside a notified sector becomes an obligated entity automatically. There is no application and no opt-in.
Intensity, not absolute emissions
The design choice that matters most is easy to miss. The scheme does not cap total emissions. It sets a greenhouse gas emission intensity target, measured in tonnes of carbon dioxide equivalent per unit of product.
The practical consequence is that a company can grow output, raise its absolute emissions, and still earn credits, provided its emissions per tonne of cement or steel fall faster than the target. For an economy still building out heavy industry that is a deliberate accommodation. For anyone reading the scheme as a decarbonisation cap, it is a misreading.
Three dates that decide the year
- April 2026. Obligated entities file action plans with the Bureau of Energy Efficiency, setting out how they intend to hit their intensity targets.
- July 2026. Monitoring, reporting and verification deadline. Verified emissions data for FY 2025-26 is due, covering fuel consumption, production volumes, electricity purchased and calculated emission intensity.
- October 2026. Trading in carbon credit certificates opens on the designated exchange. Entities in surplus can sell. Entities in deficit must buy and surrender, or pay a statutory penalty.
The measurement problem
July is the pinch point. Verified data at facility level is a different discipline from the estimates most Indian manufacturers have historically reported. Fuel and production figures have to reconcile, meters have to be calibrated, and a third party has to be willing to sign.
Companies that treated the first compliance year as a reporting exercise rather than a metering exercise will discover the gap in July, with three months before trading opens and no time to fix the underlying systems.
Why listed companies face this twice
For a listed obligated entity, the same emissions data now has two masters. The Bureau of Energy Efficiency wants it for carbon market compliance. SEBI wants it, assured, as part of BRSR Core. The two regimes ask overlapping questions on different timetables and to different definitions.
Firms building one emissions data pipeline that can answer both will spend considerably less than those running two.
Source: Bureau of Energy Efficiency notifications under the Carbon Credit Trading Scheme, and International Carbon Action Partnership reporting on the scheme’s compliance phase.

