The CCTS Compliance Cycle – A Complete Timeline for Obligated Entities

Introduction: The Compliance Calendar

India's Carbon Credit Trading Scheme (CCTS) is now operational. Compliance obligations are in force for approximately 490 entities across seven energy-intensive sectors, expanding to 740 entities across nine sectors.

The compliance cycle under CCTS is a structured, year-long process with specific deadlines that obligated entities must meet. Missing a deadline can result in penalties, reputational damage, and lost opportunities for earning Carbon Credit Certificates (CCCs).

This guide provides a complete timeline of the CCTS compliance cycle, detailing every phase, every deadline, and every responsibility.

---

The Legislative Framework: Understanding Your Obligations

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.

The Energy Conservation (Amendment) Act, 2022

The 2022 amendment empowered the Government of India to establish a national carbon market and to issue Carbon Credit Certificates (CCCs) to registered entities.

The Carbon Credit Trading Scheme (CCTS), 2023

The CCTS was notified in 2023 to establish the legal framework for a national carbon market. The scheme has the objective of reducing, removing, or avoiding greenhouse gas emissions from the Indian economy by pricing such emissions through the trading of CCCs.

The BEE Detailed Procedure for Compliance Mechanism

The Detailed Procedure for Compliance Mechanism was published in July 2024 and specifies the requirement format and timeline for submissions, monitoring, reporting, and verification.

---

The Compliance Cycle: An Overview

The CCTS compliance cycle consists of five phases:

Phase	Description	Timeline
Phase 1	Pre-Compliance Preparation	Before compliance year
Phase 2	Monitoring and Reporting	During compliance year
Phase 3	Verification and Assessment	After compliance year
Phase 4	CCC Issuance and Trading	After verification
Phase 5	Post-Compliance and Banking	After trading

The Compliance Cycle Timeline Diagram

┌─────────────────────────────────────────────────────────────────────────────┐
│                        CCTS COMPLIANCE CYCLE                                │
├─────────────────────────────────────────────────────────────────────────────┤
│                                                                             │
│  PHASE 1: PRE-COMPLIANCE PREPARATION (Before Compliance Year)               │
│  ├── Confirm Obligated Status                                               │
│  ├── Register on ICM Portal                                                 │
│  ├── Develop Monitoring Plan                                                │
│  └── Prepare GHG Reduction Action Plan                                      │
│                                                                             │
│  PHASE 2: MONITORING AND REPORTING (During Compliance Year)                 │
│  ├── Monitor GHG Emissions                                                  │
│  ├── Maintain Quarterly Data Records                                        │
│  ├── Update Monitoring Plan (Annual)                                        │
│  └── Implement Reduction Measures                                           │
│                                                                             │
│  PHASE 3: VERIFICATION AND ASSESSMENT (After Compliance Year)               │
│  ├── Submit Form A (31st July)                                              │
│  ├── Submit Form B (31st July)                                              │
│  ├── BEE Assessment (30th September)                                        │
│  └── Check Verification (if initiated)                                      │
│                                                                             │
│  PHASE 4: CCC ISSUANCE AND TRADING (After Verification)                     │
│  ├── NSC-ICM Recommendation (15th October)                                  │
│  ├── CCC Issuance (30th October)                                            │
│  └── Trading Session (31st January)                                         │
│                                                                             │
│  PHASE 5: POST-COMPLIANCE AND BANKING (After Trading)                       │
│  ├── Submit Form D (28th February)                                          │
│  └── Banking of CCCs                                                        │
│                                                                             │
└─────────────────────────────────────────────────────────────────────────────┘

---

Phase 1: Pre-Compliance Preparation

Before the Compliance Year Begins

Activity	Description	Timeline
Confirm Obligated Status	Confirm your facility is on the notified list of obligated entities	Before compliance year
Register on ICM Portal	Register on the Indian Carbon Market Portal	Before compliance year
Open Registry Account	Open account with Grid Controller of India	Before compliance year
Develop Monitoring Plan	Develop GHG monitoring plan	Within 3 months of trajectory period start
Prepare GHG Reduction Action Plan	Prepare long-term action plan (at least five years)	Within 1 year of first compliance year

Register on the ICM Portal

The Indian Carbon Market Portal (www.indiancarbonmarket.gov.in) serves as the central digital backbone of the Indian Carbon Market. For a notified obligated entity, registration is not optional. Until you complete carbon credit registration on the ICM portal, you cannot submit compliance documents or manage your CCCs.

Develop the Monitoring Plan

The monitoring plan must be submitted to BEE within three months of the commencement of the first trajectory period. The plan must contain:

• A description of activities, emission sources, and source streams
• A diagram highlighting emission sources, metering points, and data flow
• GHG emission monitoring methodology
• Monitoring details for activity data and emission factors
• Data flow and control procedures
• Sampling procedures
• Internal and external testing procedures
• Staff responsibilities
• Measurement equipment details

Prepare the GHG Reduction Action Plan

The obligated entity shall submit the action plan within one year from the commencement of the first compliance year. The action plan must include:

• Brief description of identified GHG reduction measures
• Estimated cost and resultant savings
• Implementation plan
• Details of GHG reduction measures identified for the next five years

---

Phase 2: Monitoring and Reporting

During the Compliance Year

Activity	Description	Frequency
Monitor GHG Emissions	Monitor emissions based on the monitoring plan	Continuous
Maintain Quarterly Data Records	Maintain quarterly data reports	Quarterly
Monitor Activity Data	Monitor fuel consumption, production, electricity	Continuous
Conduct Fuel Analysis	Conduct internal and external lab analysis	Monthly
Calibrate Equipment	Calibrate measurement equipment	As per schedule
Update Monitoring Plan	Submit annual update to monitoring plan	Within 3 months of compliance year start
Implement Reduction Measures	Implement GHG reduction measures	Ongoing

Quarterly Data Records

The obligated entity shall prepare and maintain quarterly data reports covering:

• Fuel consumption logs for all source streams
• Electricity purchased/generated/exported
• Heat purchased/exported
• Production records
• Lab analysis reports
• Opening/closing stock of fuels and raw materials

Annual Monitoring Plan Update

The subsequent monitoring plans are required to be submitted on an annual basis and within three months of the start of the compliance year.

Fuel Analysis Requirements

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	Every 50,000 tonnes and at least once every quarter
Gaseous Fuels	At least once every week

---

Phase 3: Verification and Assessment

After the Compliance Year

Activity	Description	Deadline
Submit Form A	Performance Assessment Document	31st July
Submit Form B	Certificate of Verification	31st July
Submit GHG Emission Report	Verified GHG emissions report	31st July
Submit GHG Emission Proforma	Filled and verified proforma	31st July
BEE Assessment	BEE assesses compliance	30th September
Check Verification	Independent reassessment (if initiated)	Variable

Form A – Performance Assessment Document

The obligated entity shall submit the performance assessment document in Form 'A' covering the performance for the relevant compliance year, specifying the compliance with GHG emission intensity targets, duly verified together with the certificate of verification in Form 'B'.

Form A must include:

• Registration number
• Sector and sub-sector
• Achieved GHG Emission Intensity (SGE)
• Production (baseline)
• Number of Carbon Credit Certificates (Issued/Surrendered)
• Carbon Emission Reduction measures implemented

Form B – Certificate of Verification

The accredited carbon verification agency shall submit the certificate of verification in Form 'B' with the date and signature by an authorised person.

Form B certifies that:

• Verification of data collection has been carried out diligently and truthfully
• Verification of carbon emission reduction measures has been carried out diligently and truthfully
• Verification of compliance with GHG emission norms has been carried out diligently and truthfully
• Verification of GHG emissions report has been carried out diligently and truthfully

Supporting Documents Required

Document	Description
Registration Number	Copy of unique registration number
E2 Form	Proof of timely submission of Annual Energy Consumption and GHG Emissions
Monitoring Plan	Latest version with version number and effective date
Sampling Procedures	Written sampling procedures
Data Flow Documentation	Documented data flow and control procedures
Fuel Analysis Records	Fuel and material analysis records
GHG Emission Proforma	Excel-based or IT-based calculation template

BEE Assessment

BEE shall assess compliance and prepare a report within two months from the final date of submission of Form A. This report specifies the exact number of CCCs to be issued or surrendered.

Check Verification

BEE may on its own, or on receipt of a complaint regarding any error or inconsistency or misrepresentation, initiate action for check verification. The check verification process involves:

1. Notice to obligated entity and ACVA
2. Response within 10 working days
3. BEE decision within 10 working days
4. Appointment of independent ACVA
5. Assessment and report

---

Phase 4: CCC Issuance and Trading

After Verification

Activity	Description	Deadline
NSC-ICM Recommendation	NSC-ICM recommends CCC issuance	15th October
CCC Issuance	BEE issues CCCs on the ICM registry	30th October
Trading Session	CCCs traded on Power Exchanges	31st January (Next Year)

NSC-ICM Recommendation

The National Steering Committee for Indian Carbon Market shall recommend the Bureau to issue carbon credit certificates within two weeks from the date of receiving the report from BEE.

CCC Issuance

BEE shall issue the carbon credit certificates to the concerned obligated entity within two weeks from the date of receipt of such recommendation from the NSC-ICM on the ICM registry.

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

Trading Session

The CCCs shall be traded over the power exchanges as per the procedure defined by CERC under the Terms and Conditions for trading of CCC under the ICM. Trading shall occur within three months after CCC issuance.

---

Phase 5: Post-Compliance and Banking

After Trading

Activity	Description	Deadline
Submit Form D	Compliance Assessment Document	28th February (Next Year)
Banking of CCCs	Bank surplus CCCs for future use	After compliance year

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.

Banking of CCCs

On completion of the compliance year, the remaining Carbon Credit Certificates (CCC) from that year may be banked for use in subsequent compliance years. Banked CCCs may either be sold within the Indian Carbon Market or utilised to meet compliance in future compliance years.

---

Key Deadlines You Cannot Miss

Summary of All Deadlines

Deadline	Event	Responsible Party	Description
Within 3 months of trajectory start	Monitoring Plan Submission	Obligated Entity	Submit initial monitoring plan to BEE
Within 3 months of compliance year start	Annual Monitoring Plan Update	Obligated Entity	Submit updated monitoring plan
Within 1 year of first compliance year	GHG Reduction Action Plan	Obligated Entity	Submit long-term action plan
31st July	Form A Submission	Obligated Entity	Submit Performance Assessment Document
31st July	Form B Submission	ACVA	Submit Certificate of Verification
31st July	GHG Emission Report	Obligated Entity	Submit verified GHG emissions report
31st July	GHG Emission Proforma	Obligated Entity	Submit filled and verified proforma
30th September	BEE Assessment	BEE	BEE assesses compliance
15th October	NSC-ICM Recommendation	NSC-ICM	Recommend CCC issuance
30th October	CCC Issuance	BEE	Issue CCCs on ICM registry
31st January (Next Year)	Trading Session	CERC/GCIL/IEX/PXIL	CCCs traded on Power Exchanges
28th February (Next Year)	Form D Submission	Obligated Entity	Submit Compliance Assessment Document

Critical Path Timeline

┌─────────────┬────────────────────────────────────────────────────────────────┐
│   Phase     │                        Timeline                               │
├─────────────┼────────────────────────────────────────────────────────────────┤
│  Pre-       │  Trajectory Start → 3 months: Monitoring Plan                  │
│  Compliance │  → 1 year: GHG Reduction Action Plan                          │
├─────────────┼────────────────────────────────────────────────────────────────┤
│  Monitoring │  Compliance Year (April - March)                              │
│  & Reporting│  → Quarterly data records                                     │
│             │  → Monthly fuel analysis                                      │
├─────────────┼────────────────────────────────────────────────────────────────┤
│  Verification│  Compliance Year End → 31st July: Form A & Form B             │
│  & Assessment│  → 30th September: BEE Assessment                            │
├─────────────┼────────────────────────────────────────────────────────────────┤
│  CCC        │  30th September → 15th October: NSC-ICM Recommendation         │
│  Issuance   │  → 30th October: CCC Issuance                                │
│  & Trading  │  → 31st January: Trading Session                             │
├─────────────┼────────────────────────────────────────────────────────────────┤
│  Post-      │  31st January → 28th February: Form D Submission              │
│  Compliance │  → Banking of CCCs                                            │
└─────────────┴────────────────────────────────────────────────────────────────┘

---

The Obligated Entity's Responsibilities

Core Responsibilities

Responsibility	Description	Timeline
Develop Monitoring Plan	Develop and submit monitoring plan to BEE	Within 3 months of trajectory start
Update Monitoring Plan	Submit annual update to monitoring plan	Within 3 months of compliance year start
Monitor GHG Emissions	Monitor emissions based on the monitoring plan	Throughout compliance year
Maintain Data Records	Maintain quarterly and yearly data records	Ongoing
Conduct Fuel Analysis	Conduct internal and external lab analysis	Monthly
Implement Reduction Measures	Implement GHG reduction measures	Ongoing
Submit Form A	Submit Performance Assessment Document	31st July
Submit GHG Emission Report	Submit verified GHG emissions report	31st July
Submit GHG Emission Proforma	Submit filled and verified proforma	31st July
Submit Form D	Submit Compliance Assessment Document	28th February (Next Year)

Additional Responsibilities

Responsibility	Description
Register on ICM Portal	Register on the Indian Carbon Market Portal
Open Registry Account	Open account with Grid Controller of India
Prepare GHG Reduction Action Plan	Prepare long-term action plan (at least five years)
Appoint ACVA	Appoint accredited carbon verification agency
Address Verification Findings	Address any material outstanding issues or non-conformities
Surrender CCCs	Surrender CCCs if targets are not achieved

---

The ACVA's Responsibilities

Core Responsibilities

Responsibility	Description	Timeline
Pre-Contractual Review	Assess whether verification falls within scope of accreditation	Before verification
Strategic Analysis	Assess nature, scale, and complexity of verification	Start of verification
Risk Assessment	Design, plan, and implement effective verification	Start of verification
Develop Verification Plan	Develop verification plan with objectives, scope, activities	Before verification
Conduct Site Visit	At least one site visit during verification	During verification
Verify Data and Systems	Assess data systems, IT systems, data flow activities	During verification
Verify Emission Sources	Verify emission sources and source streams coverage	During verification
Verify Calculations	Verify emission monitoring/calculation methodology	During verification
Verify Fuel Analysis	Verify fuel and material analysis process	During verification
Verify Mitigation Measures	Verify GHG emission mitigation measures	During verification
Independent Review	Make independent technical review of verification	After verification
Submit Form B	Submit Certificate of Verification	31st July
Submit Verification Report	Submit detailed verification report	31st July

Check Verification Responsibilities

Responsibility	Description
Conduct Check Verification	Conduct independent reassessment when appointed by BEE
Submit Form C	Submit Certificate of Check Verification
Submit Check Verification Report	Submit detailed check verification report

---

BEE's Responsibilities

Core Responsibilities

Responsibility	Description	Timeline
Develop Targets	Develop sectoral GHG emission intensity trajectory	Before trajectory period
Review Monitoring Plans	Review and approve monitoring plans	Within 3 months of submission
BEE Assessment	Assess compliance and prepare report	Within 2 months of Form A submission
Submit to NSC-ICM	Submit report to NSC-ICM for CCC issuance	Within 2 months of Form A submission
Issue CCCs	Issue CCCs on the ICM registry	Within 2 weeks of NSC-ICM recommendation
Initiate Check Verification	Initiate check verification if errors or inconsistencies found	Within 1 year of submission

Additional Responsibilities

Responsibility	Description
Develop Proforma	Develop GHG Emission Calculation Proforma
Publish MRV Guidelines	Develop and publish sector-specific MRV guidelines
Accredit ACVAs	Accredit carbon verification agencies
Monitor Compliance	Monitor compliance with the procedure

---

Common Compliance Mistakes and How to Avoid Them

Mistake 1: Missing the Monitoring Plan Deadline

Problem: Monitoring plan not submitted within 3 months of trajectory period commencement.

Solution: Start developing the monitoring plan early. Use the BEE monitoring plan template.

Mistake 2: Incomplete Monitoring Plan

Problem: Monitoring plan does not contain all required elements.

Solution: Use the compliance tracker to ensure all requirements are addressed.

Mistake 3: Missing Form A Deadline

Problem: Form A not submitted by 31st July.

Solution: Start preparing Form A well before the deadline. Engage an ACVA early.

Mistake 4: Missing Form B Deadline

Problem: Form B not submitted by 31st July.

Solution: Ensure the ACVA completes verification in time for the 31st July deadline.

Mistake 5: Incomplete Verification

Problem: Verification does not cover all required activities.

Solution: Ensure the ACVA conducts a thorough verification including site visit, data verification, and independent review.

Mistake 6: Data Quality Issues

Problem: Data is inaccurate, incomplete, or not traceable.

Solution: Implement robust data flow and control procedures. Maintain clear audit trails.

Mistake 7: Missing GHG Reduction Action Plan

Problem: GHG reduction action plan not submitted within 1 year of first compliance year.

Solution: Prepare the action plan early. Update annually.

Mistake 8: Going It Alone

Problem: Trying to navigate the compliance cycle without professional guidance.

Solution: Engage a carbon advisory firm like Carboned.in.

Conclusion: Stay on Track

The CCTS compliance cycle is a structured, year-long process with specific deadlines that obligated entities must meet. Missing a deadline can result in penalties, reputational damage, and lost opportunities for earning CCCs.

Key Takeaways

Aspect	What You Need to Know
Phase 1	Pre-Compliance: Monitoring Plan, GHG Reduction Action Plan
Phase 2	Monitoring and Reporting: Quarterly data, fuel analysis
Phase 3	Verification and Assessment: Form A, Form B, BEE Assessment
Phase 4	CCC Issuance and Trading: NSC-ICM Recommendation, CCC Issuance, Trading
Phase 5	Post-Compliance: Form D, Banking of CCCs

The Choice Is Yours

Option	Outcome
Stay on track	Meet compliance, earn CCCs, avoid penalties
Miss deadlines	Face penalties, reputational damage, lost opportunities