The BEE Detailed Procedure for Compliance Mechanism – A Complete Guide to India's GHG Monitoring and Reporting Framework

Introduction: The Rulebook for GHG Compliance

The Bureau of Energy Efficiency (BEE) published the Detailed Procedure for Compliance Mechanism under CCTS in July 2024, establishing the comprehensive Measurement, Reporting, and Verification (MRV) framework that underpins India's Carbon Credit Trading Scheme (CCTS). This document is the operational rulebook for obligated entities—the factories, plants, and industrial units that must comply with legally binding greenhouse gas emission intensity targets.

The Detailed Procedure covers every aspect of the compliance journey: from developing a monitoring plan to calculating emissions, from selecting emission factors to undergoing verification by accredited carbon verification agencies. It translates the broad legislative framework of the Energy Conservation Act, 2001 and the CCTS, 2023 into actionable, enforceable requirements.

For obligated entities across nine energy-intensive sectors—including aluminium, cement, chlor-alkali, fertiliser, iron and steel, petrochemicals, petroleum refining, pulp and paper, and textiles—this document is the definitive guide to compliance. Understanding its provisions is not optional. It is the difference between earning Carbon Credit Certificates (CCCs) and facing penalties.

This guide provides a comprehensive breakdown of the BEE Detailed Procedure for Compliance Mechanism, explaining every requirement, timeline, and obligation that obligated entities must meet.

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The Legislative Foundation: Energy Conservation Act and CCTS

The Energy Conservation Act, 2001

The Energy Conservation Act, 2001 established the Bureau of Energy Efficiency (BEE) and provided the framework for energy efficiency in India. However, it did not originally contain provisions for carbon trading.

The 2022 Amendment

The Energy Conservation (Amendment) Act, 2022 empowered the Government of India to establish a national carbon market and to issue Carbon Credit Certificates (CCCs) to registered entities under different mechanisms.

The Carbon Credit Trading Scheme (CCTS), 2023

The Central Government notified the Carbon Credit Trading Scheme (CCTS) on 28 June 2023 under the powers conferred by clause (w) of section 14 of the Energy Conservation Act, 2001. This legislation delineates the Indian Carbon Market (ICM), establishing a national framework with the aim of reducing, removing, or avoiding greenhouse gas emissions from the Indian economy by pricing GHG emission reductions through the trading of carbon credit certificates.

The Environment (Protection) Act, 1986

The Environment (Protection) Act, 1986 empowers the Government of India to specify standards for emission or discharge of pollutants for obligated entities. This is the legal basis for notifying GHG emission intensity targets.

The Two Mechanisms

The CCTS operates through two distinct mechanisms：

Mechanism	Participants	Purpose
Compliance Mechanism	Obligated Entities (OEs)	Legally binding GHG emission intensity targets
Offset Mechanism	Non-Obligated Entities (Non-OEs)	Voluntary project-based carbon credits

The Detailed Procedure

The Detailed Procedure for Compliance Mechanism was adopted in July 2024 to operationalise the compliance mechanism. It specifies the criteria for issuance of CCCs, validity of CCCs, floor and forbearance prices, requirement format and timeline for submissions, monitoring, reporting, and verification, and any other related and incidental matters.

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Overview of the Compliance Mechanism

What Is the Compliance Mechanism?

Under the CCTS, the Government has introduced a Compliance Mechanism, where obligated entities shall comply with the greenhouse gas emission intensity targets as may be notified by the Central Government.

Key Participants

Participant	Role
Obligated Entities (OEs)	Energy-intensive industries notified under the compliance mechanism
Bureau of Energy Efficiency (BEE)	Administrator—develops targets, manages registration, oversees compliance
Ministry of Power (MoP)	Recommends targets to MoEFCC based on BEE and NSC-ICM recommendations
Ministry of Environment, Forest and Climate Change (MoEFCC)	Notifies GHG emission intensity targets under the Environment Protection Act
National Steering Committee for Indian Carbon Market (NSC-ICM)	Governance and oversight, chaired by Secretary, MoP

The Target-Setting Process

Step	Description
1. Sector Identification	MoP decides sectors and obligated entities based on BEE and NSC-ICM recommendations
2. Trajectory Development	BEE develops a sectoral GHG emission intensity trajectory extending to 2030
3. Target Setting	BEE develops targets in terms of tCO₂e per unit of equivalent product
4. Recommendation	MoP recommends targets to MoEFCC after considering BEE and NSC-ICM recommendations
5. Notification	MoEFCC notifies annual GHG emission intensity targets for each obligated entity

The Compliance Cycle

Step	Description	Timeline
1. Monitoring Plan Submission	Submit monitoring plan to BEE	Within 3 months of trajectory period commencement
2. Annual Monitoring Plan Update	Submit updated plan annually	Within 3 months of compliance year start
3. GHG Emission Report Submission	Submit verified GHG emissions report	Within 4 months of compliance year completion
4. Verification	ACVA verifies emissions data	During verification window
5. CCC Issuance or Surrender	CCCs issued or surrendered based on performance	Following verification

The Working of Compliance Mechanism

The compliance mechanism works on a baseline-and-credit system. Obligated entities are assigned GHG emission intensity targets based on a baseline year. Entities that outperform their targets earn Carbon Credit Certificates (CCCs). Entities that fall short must purchase and surrender CCCs.

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GHG Emission Intensity Trajectory and Targets

Inclusion of Obligated Entities

Under the provisions of CCTS, the Central Government shall, upon the NSC-ICM's recommendation, determine the obligated entities for notification under the compliance mechanism. The sectors for the obligated entities shall be specified by the Central Government as per clause 14(e) of the Energy Conservation Act.

Greenhouse Gases (GHG) Coverage

For the compliance mechanism under CCTS, the greenhouse gases to be covered are carbon dioxide (CO₂) and perfluorocarbon (PFCs) gases from the obligated entities' operations. GHG emissions shall be converted to carbon dioxide equivalent (CO₂e) based on Global Warming Potential (GWP) values from the latest IPCC Assessment Report.

Establishment of GHG Emission Intensity Trajectory

For target setting under the CCTS compliance mechanism, BEE will develop a sectoral GHG emission intensity trajectory in consultation with the technical committee for each sector. This trajectory will determine the sectors' potential reductions to meet NDC targets set by the government.

The emission intensity trajectory for the sectors, extending to 2030, will be subject to regular reviews and updates by BEE.

The trajectory is developed based on:

Factor	Description
NDC Commitments	GHG reduction required to meet India's NDC targets
Technology and Cost	Available technology and associated cost of implementation
Decarbonisation Potential	Potential for energy efficiency, fuel switch, use of non-fossil fuel energy/feedstock, and decarbonisation

Establishment of GHG Emission Intensity Targets

To establish the GHG emission intensity targets, the technical committee for the respective sectors shall evaluate:

1. The obligated entity's GHG emission intensity in the baseline year
2. The targets for GHG emissions intensity in the trajectory period

The evaluation covers:

Emission Type	Description
Direct GHG Emissions	Emissions from energy use and processes
Direct Process Emissions	Emissions from chemical reactions or transformations
Indirect GHG Emissions	Emissions from purchased electricity and heat

Emissions Included in Calculation

Included	Description
Direct Energy Emissions	Solid, liquid, and gaseous fuel combustion
Direct Process Emissions	Chemical reactions and transformations
Indirect Emissions	Purchased electricity and heat
Notional Emissions	Where intermediate products/raw materials are imported (specified in sector MRV guidelines)

Emissions Excluded from Calculation

Excluded	Description
Biomass/Biogenic	GHG emissions from biomass or biogenic sources of energy
Renewable Energy	Energy from renewable sources
Co-processing	Emissions from co-processing of alternate fuels (excluding petcoke, carbon black, PPF, peat, dolochar)
CCUS	GHG emissions captured, transferred, or utilised through CCUS
Colony/Construction	Energy consumed in colonies, temporary construction, and outside transportation
Refrigerant Leakages	GHG emissions from refrigerant leakages in office buildings and processes
Exported Energy	GHG emissions from captive energy production exported outside the boundary

The Gate-to-Gate Boundary

The GHG emission intensity is calculated considering the direct and indirect GHG emissions based on provisions in the Detailed Procedure. The Gate-to-Gate boundary shall be applied such that the products mentioned in the sector tables are fully captured. Once the obligated entity's boundary has been fixed, the same boundary shall be considered for the entire trajectory period.

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The Monitoring and Reporting Process

The Gate-to-Gate Boundary

The Gate-to-Gate boundary outlines the monitoring scope of obligated entities, covering direct and indirect GHG emissions resulting from obligated entities' processes and operations. Once the entity's boundary is fixed, it remains the same for the entire trajectory period. Any change—such as capacity expansion, merger of two plants, or division of operations—must be duly intimated to BEE and subject to approval.

Monitoring Plan Submission Timeline

Requirement	Timeline
Initial Monitoring Plan	Within 3 months of the commencement of the first trajectory period
Subsequent Annual Updates	Within 3 months of the start of each compliance year
Plan Review and Approval	Reviewed and approved by BEE; updated based on BEE observations

What the Monitoring Plan Must Contain

Requirement	Description
Activities and Sources	Description of activities, list of emission sources and source streams
Diagram	Diagram highlighting emission sources, source streams, metering points, sampling points, and data flow
Monitoring Methodology	GHG emission monitoring methodology for source streams
Activity Data and Emission Factors	Monitoring details for activity data and emission factors
Traceable References	Traceable and verifiable references of activity data
Data Flow Procedures	Written procedure for data flow and control activities
Sampling Procedure	Sampling procedure for fuel and other materials
Testing Procedure	Internal and external testing procedure for fuel and other materials
Plan Evaluation	Procedure to regularly evaluate the monitoring plan
Staff Responsibilities	Procedure to assign responsibilities to staff
Measurement Equipment	Description of measurement equipment, range, uncertainty, and location
Analysis Methods	Analysis methods for determination of all relevant factors
Plan Updates	Changes or variations must be updated and made available to ACVA

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The Monitoring Plan: Your Compliance Blueprint

What Is a Monitoring Plan?

A monitoring plan is a comprehensive document outlining the details of an obligated entity's Gate-to-Gate boundary, the monitoring methodology applied, data control, and any other information necessary for the transparent monitoring and calculation of GHG emissions relating to an obligated entity's operations.

Why the Monitoring Plan Matters

The monitoring plan is the foundation of credible GHG reporting. It ensures that:

• All emission sources and source streams are identified
• Monitoring methodologies are consistent and transparent
• Data flow and control activities are documented
• Verification can be conducted efficiently

The BEE Monitoring Plan Template

BEE has developed a comprehensive Monitoring Plan Template to help obligated entities prepare their monitoring plans. The template covers:

Section	Content
Entity Details	General information, contact details, monitoring system overview
Gate-to-Gate Boundary	Included and excluded activities with BEE clause citations
Entity Description	Narrative description of operations, activities, emission sources
Production & Raw Material Monitoring	Production measurement codes, instrument specs, calibration frequency
Direct Emission Monitoring	Methodology, measurement points, emission factor type
Indirect Emission Monitoring	Electricity consumption monitoring, grid emission factors
Carbon Capture & Credit Monitoring	CCUS monitoring methodology, GHG transfer details
Management Control & Data Quality	Roles, responsibilities, data flow procedure, quality control
SOP Register	13 mandatory SOPs with BEE clause references

The Compliance Tracker

The monitoring plan template includes a 30-item compliance tracker that maps every BEE mandatory requirement to the relevant sheet. This tracker helps obligated entities identify gaps before ACVA review.

Version History

The monitoring plan must maintain a version history recording all versions, revisions, and submission history. Each version must have a unique version number and reference date.

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Activity Data Monitoring: The Foundation of GHG Accounting

What Is Activity Data?

Activity data means the quantity of fuels, energy, or materials consumed or produced by a process relevant for GHG emission calculations.

How to Monitor Activity Data

The obligated entity shall monitor the activity data of source streams in one of the following ways:

Method	Description
Continual Measurement	Based on continual measurement at the process which causes emissions
Aggregated Quantities	Based on aggregated quantities delivered or consumed, considering stock changes

The Stock Change Formula

When using aggregated quantities, consumption shall be calculated as:

Total Consumption = (Fuel/Material Received during compliance year - Fuel/Material moved out of the entity) + (Opening Stock - Closing Stock)

Units of Measurement

Material Type	Unit
Solid Fuels	Tonne (t)
Liquid Fuels	Kilolitre (kL)
Gaseous Fuels	Cubic metre (m³)

Stock Estimation Where Direct Measurement Is Not Feasible

Where it is not feasible to determine quantities in stock by direct measurement due to technical or unreasonable cost challenges, the obligated entity may estimate those quantities based on:

1. Data from previous years correlated with output for the compliance year
2. Documented procedures and respective data in audited financial statements

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Emission Factors: Type I vs. Type II

What Is an Emission Factor?

An emission factor is the average emission rate of a greenhouse gas relative to the activity data of a source stream, assuming complete oxidation for combustion and complete conversion for all other chemical reactions.

The Two Types of Emission Factors

Type	Description	Source
Type I (Standard/Default)	Standard emission factors from recognised sources	IPCC guidelines, national inventory submissions, statutory bodies
Type II (Site-Specific)	Determined by the obligated entity through sampling and analysis	Laboratory analysis of fuels and raw materials

When to Use Type I Emission Factors

Type I emission factors shall be used only when Type II emission factors are not available. The factors should be selected based on the type of fuel used and shall be based on the principle of conservativeness.

When to Use Type II Emission Factors

Type II emission factors shall be used by obligated entities for emission calculation from solid fuel, gaseous fuel, and process emissions. Only in the case of unreasonable cost and technical infeasibility shall Type I emission factors be referred.

The Type II Transition Requirement

After April 2027, all obligated entities must calculate Type II emission factors for emission calculation under CCTS. The use of Type I (default) emission factors will not be allowed under CCTS, except for purchased electricity where the latest grid emission factor from CEA applies.

How to Calculate Type II Emission Factors

For solid and gaseous fuels, Type II emission factors shall be calculated using:

1. Site-specific Net Calorific Value (NCV) of fuel (sampled and calculated)
2. Total Carbon (TC%) in the fuel (calculated based on solid fuel analysis or composition analysis for gaseous fuels)

Sources of Type I Emission Factors

Source	Description
Annexure IV	Standard emission factors provided in the Detailed Procedure
IPCC Guidelines	Latest IPCC Guidelines
National Inventory Submissions	Biennial Update Report or National Communication
Statutory Bodies	Emission factors published by statutory bodies or departments of the Central Government
International Organisations	Emission factors published by reputed international organisations

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Sampling Plan and Minimum Frequency of Analysis

What Is a Sampling Plan?

A sampling plan is a written procedure that contains information on the procedure for the preparation of samples, including locations for sample collection, frequencies of collection, quantity, storage, and transport of samples.

Key Requirements for the Sampling Plan

Requirement	Description
Based on Standards	Shall be based on relevant Indian Standard/ISO Standard
Representative Samples	Derived samples must be representative and unbiased
Available to ACVA	Must be made available to the accredited carbon verification agency
'As-Fired' Samples	Arrangements for taking 'as fired' samples from auto-samplers at solid fuel feeding points

Minimum Frequency of Analysis

Material	Frequency
Solid Fuels (coal, lignite, coke, petroleum coke)	Every 20,000 tonnes and at least once every month
Carbonates (limestone, dolomite)	Every 50,000 tonnes and at least once every month
Conversion Factors Materials (raw material, intermediate product, final product)	Every 50,000 tonnes and at least once every quarter
Gaseous Fuels	At least once every week

Why Sampling Frequency Matters

Accurate emission calculations depend on representative sampling. The sampling plan and frequency of analysis directly affect the accuracy of:

• Net Calorific Value (NCV) determination
• Total Carbon (TC%) determination
• Type II emission factor calculation
• Overall GHG emission estimates

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Laboratory Analysis: Internal and External Requirements

Internal Laboratory Analysis

Requirement	Description
Purpose	Determine Net Calorific Value (NCV), Total Carbon (TC%), and oxidation factors
Accreditation	Must be NABL-accredited as per IS/ISO/IEC 17025:2017
Standards	Analyses must follow relevant Indian or International Standards
Non-NABL Labs	If not NABL-accredited, must demonstrate competence, apply applicable standards, employ competent personnel, ensure sampling integrity, implement quality assurance procedures, and have required tools
NABL Timeline	Must obtain NABL certification within three years of inclusion in CCTS

External Laboratory Analysis

Requirement	Description
Purpose	Demonstrate proficiency of internal laboratory
Frequency	Monthly for solid fuel samples
Sample Requirements	Representative portions from the same sample at the last stage of sample preparation
Acceptable Deviation	Less than 300 J/gm or 71.7 kcal/kg for coal (as per IS 1350: Part 2: 2022) and ±2% for materials
Deviation Correction	If deviation exceeds thresholds, the difference is added to the internal lab result (conservative correction)

The Importance of Laboratory Analysis

Laboratory analysis is the foundation of Type II emission factors. Accurate laboratory analysis ensures:

• Accurate NCV determination
• Accurate Total Carbon (TC%) determination
• Credible Type II emission factors
• Reliable GHG emission calculations

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Treatment of Exported Power, Renewable Energy, and Heat

Exported Power

Treatment	Description
Adjustment	Electricity exported through captive power plant, cogeneration plant, or waste heat shall be adjusted and subtracted from overall emissions
Emission Factor	Calculated based on Weighted Average Net Heat Rate (WANHR) of the power generation and fuel used
Fallback	If WANHR/fuel data unavailable, use average grid emission factor published by CEA

Renewable Energy

Treatment	Description
Zero Emissions	Renewable energy through onsite generation, offsite procurement (open access, dedicated PPA, green tariff) shall be considered as zero GHG emissions
Documentation	Must demonstrate through contracts and agreements that energy is renewable and emissions are not double counted
Undertaking	Must provide an undertaking to prevent double accounting
RECs	Purchase of Renewable Energy Certificates (RECs) is NOT considered as a claim towards renewable energy under the compliance mechanism

Purchased Heat

Treatment	Description
Indirect Emissions	Purchased heat (steam, hot water, chilled water) shall be included as indirect emissions
Emission Factor	Use supplier-specific emission factor based on fuel usage and actual efficiency of equipment
Verification	Supplier-specific emission factor must be verified by an accredited carbon verification agency
CHP Allocation	For heat from cogeneration plants, emissions shall be apportioned to heat based on heat content
Chilled Water	Emissions calculated based on type of chilled water generation system (electrical and/or thermal)

Exported Heat

Treatment	Description
Subtraction	Emissions associated with exported heat shall be subtracted from overall GHG emissions
Calculation	Based on fuel used and actual generation efficiency of equipment
CHP Allocation	For heat from cogeneration plants, emissions shall be apportioned to heat

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Transferred Carbon Dioxide (CO₂) and CCUS

Treatment of Captured and Transferred CO₂

Treatment	Description
Subtraction	GHG emissions transferred outside the obligated entity's boundary and utilised through CCUS shall be subtracted from overall direct GHG emissions
Utilisation	Captured CO₂ used to produce precipitated calcium carbonate or other chemicals/materials where CO₂ is chemically bonded
Storage	CO₂ transferred to long-term geological storage as permitted by relevant regulations
Receiving Entity	Transferred GHG emissions shall be adjusted only if the receiving entity demonstrates permanent storage or utilisation
Non-Obligated Entity	If receiving entity is non-obligated, captured/stored emissions cannot be used to generate carbon credit certificates
Monitoring	Must monitor and quantify captured or transferred GHG emissions, including leakages and fugitive emissions

The CCUS Opportunity

Carbon Capture, Utilisation, and Storage (CCUS) is a critical pathway for hard-to-abate sectors. The Detailed Procedure provides a clear framework for accounting for captured and transferred CO₂, ensuring that entities are not penalised for emissions that are permanently stored or utilised.

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Data Control and Reporting of GHG Emissions

Quarterly and Yearly Data Reports

Obligated entities must prepare and maintain quarterly and yearly data reports, supported by established and documented data flow procedures and control procedures.

The Data Control Team

Obligated entities shall appoint a team to implement and maintain the data control and reporting activity, segregating responsibilities among different personnel.

What Data Must Be Recorded

Data Category	Description
GHG Emission Intensity	Performance of the entity and production processes
Internal Fuel Audits	For identification of opportunities and measures to reduce GHG emissions
Production and Energy Data	Production achieved, energy consumed, GHG emissions, and GHG emission intensity
Fuel Analysis Data	Data records for fuel analysis
E2 Form	Annual Energy Consumption and GHG Emissions

Control Activities

Obligated entities shall implement procedures for control activities covering at least:

Control Activity	Description
Quality Assurance	Regular quality assurance of measurement equipment, instruments, and IT systems
Internal Reviews	Internal reviews and validation of data
Corrective Actions	Correction of data based on internal review
Outsourced Quality Assurance	Quality assurance of outsourced activities (e.g., external lab)
Responsibilities	Defined responsibilities for monitoring and reporting
Competence	Competence of personnel involved in monitoring and reporting
Documentation	Recording and documenting relevant information

The Four-Eye Principle

The Detailed Procedure requires the implementation of the four-eye principle—segregation of duties where data collection and validation are performed by different personnel. This ensures data integrity and prevents errors or manipulation.

The E2 Form

The E2 Form (Annual Energy Consumption and GHG Emissions) is a mandatory submission that captures:

Section	Content
Section-A	General Details—registration number, entity name, sector, sub-sector, address, energy manager details
Section-B	Production and Energy Consumption Details—production details, energy consumption, GHG emissions
Section-C	Pro-forma Details—sector-specific proforma

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The GHG Emission Report and Proforma

The GHG Emission Calculation Proforma

BEE has developed a standardised GHG Emission Calculation Proforma, presented as an Excel-based template or an IT-based system. This acts as a standardised monitoring template through which obligated entities shall systematically monitor and report their greenhouse gas emissions.

The GHG Emission Report

The obligated entity within four months of the completion of the compliance year shall submit the GHG emissions report and GHG Emission Proforma, duly verified by the accredited carbon verification agency, to BEE and the State Designated Agency.

What the GHG Emission Report Must Include

Section	Content
Entity Details	Registration number, plant head and energy manager details, contact information
Reporting Year	Clearly indicating the reporting year for which emissions data is presented
Monitoring Plan	Reference to the latest submitted monitoring plan, version number, and effective date
Changes in Operations	Any relevant changes in operations during the reporting period
Production Process	Raw material consumption, production process/sub-process-wise details
Emission Source Information	Comprehensive details for all emission sources and source streams
Total Emissions	Expressed in tonnes of CO₂ equivalent
Non-CO₂ Gases	Emissions of greenhouse gases other than CO₂
Calculation Methodology	Methodology applied for each source
Emission Factors	Type of emission factors applied for each source
Activity Data	Amount of fuel, net calorific value, and other source stream details
Mass Balance	Mass flow and carbon content for each source stream
Sampling Plan	Sampling plan and procedure
Data Control	Data control procedures
Memo Items	Amounts of biomass combusted or employed in processes
GHG Reduction Measures	List of GHG reduction measures implemented

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Verification and Assessment of Performance

What Is Verification?

Verification is an independent assessment of the GHG emission report and GHG emission intensity for the relevant compliance year. The accredited carbon verification agency shall carry out verification with reasonable level of assurance.

Key Verification Activities

Activity	Description
Strategic Analysis	Assess nature, scale, and complexity of verification activity
Risk Analysis	Design, plan, and implement an effective verification
Team Appointment	Appoint a team with required competence and experience
Verification Plan	Develop a plan with objectives, scope, activities, schedule, and sampling plan
Site Visit	At least one site visit during the verification process
Data and Systems Assessment	Assess data systems, IT systems, data flow activities, control activities
Sampling	Apply sampling techniques for data sampling and checking control activities
Analytical Procedures	Perform analytical procedures to assess data accuracy
Data Gap Identification	Identify data gaps and outliers
Primary Data Verification	Verify data against primary and secondary data sources
Methodology Verification	Verify emission monitoring/calculation methodology for each source stream
Document Review	Review data and its source, tracing to primary source data
Interviews	Site visits and interviews with responsible personnel
Fuel Analysis Verification	Verify fuel and material analysis process
Mitigation Measure Verification	Verify GHG emission mitigation measures
Laboratory Verification	Verify technical competence and procedures of internal laboratories
Independent Technical Review	Independent review of verification activity and decision

Materiality Threshold

The accredited carbon verification agency shall apply a materiality threshold of 2% of the total reported emissions in the reporting period. Any error, omission, or discrepancy greater than 2% is considered material and must be corrected.

Verification Outcomes

Outcome	Description
Positive Opinion	GHG emission report is free from material misstatements
Negative Opinion	GHG emission report contains material misstatements
Limited Scope	Obligated entity fails to provide required data or evidence

The Verification Report

The verification report must contain:

Section	Content
Summary	Summary of verification process, results of assessment, and opinion
Verification Details	Details of verification activities carried out
Interaction Record	Record of interaction between ACVA and obligated entity
Findings	Whether GHG emission report is satisfactory and positive opinion can be issued
Limitations	Any limitations on the scope of verification

Form A and Form B

Form	Submitted By	Content
Form A	Obligated Entity	Performance Assessment Document—compliance with GHG emission intensity targets
Form B	Accredited Carbon Verification Agency	Certificate of Verification—verification opinion and findings

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Check Verification Process

What Is Check Verification?

Check Verification is a second-level, independent reassessment for a selected fraction of obligated entities, initiated by BEE. It is carried out by an independent ACVA, not the original verifier.

When Check Verification Is Initiated

BEE may initiate check verification:

Trigger	Description
On Its Own	Within 1 year of GHG emission and verification report submission
On Complaint	Within 6 months of CCC issuance (whichever is later)
Reasons	Errors, inconsistencies, misrepresentation, complaint by any stakeholder

The Check Verification Process

Step	Description
1. Notice	BEE issues notice to obligated entity and original verification agency
2. Response	OE and verifier respond within 10 working days
3. Decision	BEE decides whether to proceed with check verification within 10 working days
4. Appointment	BEE appoints an independent ACVA (not involved in original verification)
5. Assessment	ACVA assesses compliance with procedure, monitoring and reporting process
6. Report	ACVA submits check verification report with due certification in Form C

Outcomes of Check Verification

Outcome	Description
Positive Opinion	All requirements with regard to compliance and CCC issuance have been met
Negative Opinion	Implications on GHG emission standards, CCC issuance, and agency liability quantified

Form C

Form C is the Certificate of Check Verification, submitted by the ACVA conducting the check verification.

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Issuance and Surrender of Carbon Credit Certificates

CCC Issuance Formula

Number of CCCs to be issued = (GEI Target for compliance year - GEI Achieved in compliance year) × Quantity of equivalent product produced in that compliance year

CCC Surrender Formula

Number of CCCs to be surrendered = (GEI Achieved in compliance year - GEI Target in compliance year) × Quantity of equivalent product produced in that compliance year

The Issuance Process

Step	Description	Timeline
1. Form A Submission	Obligated entity submits Form A to BEE	Within 4 months of compliance year completion
2. BEE Assessment	BEE assesses compliance and prepares report	Within 2 months of Form A submission
3. NSC-ICM Recommendation	NSC-ICM recommends CCC issuance	Within 2 weeks of receiving BEE report
4. CCC Issuance	BEE issues CCCs on the ICM registry	Within 2 weeks of NSC-ICM recommendation

The Surrender Process

For obligated entities where there is a requirement to surrender CCCs:

1. The BEE report specifies the exact number of CCCs to be surrendered
2. BEE debits the registry account of the obligated entity
3. The obligated entity surrenders the equivalent number of CCCs for compliance purposes

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Banking of Carbon Credit Certificates

The Banking Provision

On completion of the compliance year, the remaining Carbon Credit Certificates (CCC) from that year may be banked for use in subsequent compliance years.

Use of Banked CCCs

Banked CCCs that were issued to the obligated entity may either be:

Option	Description
Sold	Sold within the Indian Carbon Market
Utilised	Utilised to meet compliance in future compliance years

Why Banking Matters

Banking provides flexibility for obligated entities to manage their compliance obligations across compliance cycles. Entities that outperform their targets in one year can bank surplus credits for use in years when they may fall short.

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Obligations of the Obligated Entities

The Core Obligations

The obligated entity shall:

Obligation	Description
1. Develop Monitoring Plan	Develop and implement the monitoring plan to monitor GHG emissions and emission intensity
2. Adhere to MRV Requirements	Adhere to the monitoring and reporting requirements to accurately monitor and report GHG emissions and emission intensity
3. Undertake Verification	Upon completion of the compliance year, undertake verification activities through accredited carbon verification agencies
4. Comply with Targets	Comply with GHG emission intensity targets by implementing GHG reduction measures
5. Surrender CCCs	If targets are not achieved, surrender the equivalent number of CCCs
6. Take All Measures	Take all measures including implementation of long-term action plan and good practices
7. Furnish Data	Furnish full and complete data and provide necessary documents as required by BEE or ACVAs

The GHG Reduction Action Plan

Requirement	Description
Long-Term Plan	Prepare a long-term action plan (at least five years) for GHG emissions reduction
Submission Timeline	Submit within one year from the commencement of the first compliance year
Annual Update	Submit annual planned activities within three months of the commencement of each compliance year
Minimum Contents	Brief description of GHG reduction measures, estimated cost and savings, implementation plan, details of measures for next five years

Form D: Compliance Assessment Document

The obligated entity shall furnish the status of compliance in the form of Compliance Assessment Document (Form D) within one month from the date of the last trading session of the relevant compliance year.

Conclusion: Know the Rules, Comply with Confidence

The BEE Detailed Procedure for Compliance Mechanism is the definitive rulebook for obligated entities under India's Carbon Credit Trading Scheme. Understanding and complying with its provisions is not optional—it is the foundation of credible GHG reporting, successful verification, and compliance with emission intensity targets.

Key Takeaways

Aspect	What You Need to Know
Procedure Published	July 2024
GHG Coverage	CO₂ and PFCs
Boundary	Gate-to-Gate, fixed for trajectory period
Emission Factors	Type I (default) and Type II (site-specific)
Type II Transition	Mandatory from April 2027
Materiality Threshold	2% of total reported emissions
CCC Formula	(GEI Target - GEI Achieved) × Production
Verification	Reasonable assurance by ACVA
Check Verification	Independent reassessment by BEE

The Choice Is Yours

Option	Outcome
Understand and comply	Navigate the market confidently, avoid penalties, earn CCCs
Ignore or misunderstand	Risk penalties, lost opportunities, reputational damage