Form A Filing Under CCTS – Everything You Need to Know Before the Deadline

Introduction: What Is Form A?

Form A is the primary compliance filing document under India's Carbon Credit Trading Scheme (CCTS). It is a Performance Assessment Document that obligated entities must submit to the Bureau of Energy Efficiency (BEE).

India's Carbon Credit Trading Scheme — the compliance carbon market notified in June 2023 under the Energy Conservation (Amendment) Act, 2022 and administered by the Bureau of Energy Efficiency — reaches its first real deadline on July 31, 2026, when obligated entities must submit Form A verified emissions data for FY2025-26.

This is not a routine filing. It is the first time approximately 490 entities across energy-intensive sectors will submit binding carbon data. Several of the newly covered entities are filing binding carbon data for the first time in their history.

This guide provides a comprehensive, step-by-step breakdown of everything you need to know about Form A filing under the CCTS.

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Who Must File Form A?

Obligated Entities

Form A must be filed by obligated entities — large industrial consumers across energy-intensive sectors with mandatory emissions intensity reduction targets notified by MoEFCC under the Environment Protection Act, 1986.

The Nine Sectors

Sector	Status	Entities
Aluminium	Notified (October 2025)	13
Cement	Notified (October 2025)	186
Chlor-Alkali	Notified (October 2025)	30
Pulp and Paper	Notified (October 2025)	53
Petroleum Refining	Notified (January 2026)	Part of 208
Petrochemicals	Notified (January 2026)	Part of 208
Textiles	Notified (January 2026)	173
Iron and Steel	Draft notified (June 2026)	255
Fertilizer	Pending	TBD

Number of Entities

• Current: Approximately 490 entities
• Future: Approximately 795 obligated entities

How to Check Your Status

1. Visit the Bureau of Energy Efficiency (BEE) website
2. Look for the list of obligated entities under the CCTS
3. Check if your plant or unit is listed
4. If you are unsure, consult a carbon advisory firm like Carboned.in

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Form A Contents and Requirements

What Form A Requires

Component	Description
Emissions Data	Verified GHG emissions data for FY2025-26
GHG Emissions Report	Comprehensive report of GHG emissions
Compliance Assessment	Assessment of compliance with emission intensity targets
Monitoring and Verification Plans	Plans for ongoing monitoring and verification
Performance Assessment	Assessment of performance against targets

The Submission Timeline

Step	Timeline
Form A Submission	July 31, 2026
Verification Submission	Within 2 months of Form A filing
GHG Emissions Report	Within 4 months of completion of compliance year

The Compliance Cycle

The obligated entity within four months of the completion of the compliance year shall submit the GHG emissions report and GHG. This submission is based on the claim made by the obligated entity in Form 'A' and must occur within two months from the final date of submission of the aforementioned Form 'A'.

After each compliance year, the entity must submit a duly verified Performance Assessment Document (Form A) and a Certificate of Verification (Form B).

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The Legal Framework

The Statutory Basis

The CCTS was notified on June 28, 2023, under the powers conferred by clause (w) of section 14 of the Energy Conservation Act 2001 (52 of 2001).

Key Regulations

Regulation	Purpose
Energy Conservation Act, 2001	Foundation for CCTS
Energy Conservation (Amendment) Act, 2022	Inserted Section 14AA for CCTS and CCCs
CCTS, 2023 (S.O. 2825(E))	Established institutional architecture
GHG Emission Intensity Target Rules, 2025	First-ever binding industrial CO₂ emission intensity benchmarks

Institutional Roles

Institution	Role in Form A Filing
Bureau of Energy Efficiency (BEE)	Administrator — receives Form A, monitors compliance
Ministry of Environment, Forest and Climate Change (MoEFCC)	Notifies GHG emission intensity targets
Accredited Carbon Verification (ACV) Agencies	Verify emissions data
Grid Controller of India	Registry — tracks CCC ownership

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Step-by-Step: How to File Form A

Step 1: Gather Your Data

Action: Collect all emission data for 2023-24 and 2025-26.

Requirements:

• Scope 1 emissions (direct emissions from fuel combustion and industrial processes)
• Scope 2 emissions (indirect emissions from electricity and heat consumption)
• Production data (output in appropriate units)
• Supporting documentation

Timeline: 2-4 weeks

Step 2: Calculate Your Emission Intensity

Formula:

Emission Intensity = Total GHG Emissions (tCO₂e) / Total Output (units)

Example: A cement plant produces 1 million tonnes of cement and emits 800,000 tonnes of CO₂e.

Emission Intensity = 800,000 / 1,000,000 = 0.80 tCO₂e per tonne of cement

Timeline: 1-2 weeks

Step 3: Assess Your Compliance Gap

Formula:

Gap = Current Intensity – Target Intensity

• If gap is negative (surplus): You have surplus credits to sell
• If gap is positive (deficit): You need to reduce emissions or buy credits

Timeline: 1 week

Step 4: Engage an Accredited Carbon Verification (ACV) Agency

Data quality, audit trails, and energy management integration are not just reporting tasks. They become cost items and compliance inputs.

Action: Identify and engage an ACV agency empanelled with BEE. Ensure they are accredited in your sectoral scope.

Timeline: 2-4 weeks

Step 5: Prepare Your GHG Emissions Report

Contents:

• Emissions data for the compliance year
• Methodology used for calculation
• Supporting documentation
• Monitoring plan

Timeline: 2-4 weeks

Step 6: Complete Form A

Action: Fill out Form A on the Indian Carbon Market Portal.

Requirements:

• Verified emissions data
• GHG emissions report
• Compliance assessment
• Performance assessment

Timeline: 1-2 weeks

Step 7: Submit Form A

Deadline: July 31, 2026

Action: Submit Form A through the Indian Carbon Market Portal.

Timeline: 1 day

Step 8: Submit Verification

Action: Within 2 months of Form A filing, submit the verification report.

Timeline: Within 2 months of July 31, 2026

Step 9: Submit GHG Emissions Report

Action: Within 4 months of the completion of the compliance year, submit the GHG emissions report.

Timeline: Within 4 months of March 31, 2026

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Verification Requirements

What Is Verification?

Verification is the independent evaluation of the obligated entity's emission data by an Accredited Carbon Verification (ACV) agency.

Why Verification Matters

Verification ensures:

• Data accuracy and integrity
• Compliance with methodology requirements
• Credibility of emission reduction claims
• Eligibility for Carbon Credit Certificates

The Verification Process

Step	Description
1. Data Submission	Obligated entity submits data to ACV agency
2. Document Review	ACV agency reviews documentation
3. Site Visit	ACV agency conducts site visit (if required)
4. Verification Report	ACV agency prepares Verification Report
5. Certificate of Verification	ACV agency issues Certificate of Verification (Form B)

ACV Agency Requirements

An ACV agency shall have a minimum annual turnover of rupees fifty lakh per annum in at least one of the previous three years. An ACV agency shall demonstrate that it has financial resources and stability required for undertaking functions as defined under CCTS.

Timeline

Step	Timeline
Verification Submission	Within 2 months of Form A filing
Verification Completion	Typically 2-4 weeks after data submission

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The Performance Assessment Document

What Is the Performance Assessment Document?

The Performance Assessment Document (Form A) is the primary compliance filing document that assesses the obligated entity's performance against its emission intensity targets.

What It Assesses

Aspect	Description
Emission Intensity	Actual intensity compared to target
Compliance Status	Whether the entity met its target
Surplus/Deficit	Whether the entity has surplus credits or a deficit
Reduction Measures	Measures taken to reduce emissions

Submission Requirements

• Must be submitted by July 31, 2026
• Must be verified by an ACV agency
• Must include supporting documentation

Consequences of Non-Submission

Failure to submit the Performance Assessment Document constitutes non-compliance under the Energy Conservation Act, 2001, and triggers the Environmental Compensation penalty.

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Common Mistakes in Form A Filing

Mistake 1: Incomplete Data

The Problem: Incomplete or inaccurate emission data is the most common reason for Form A rejection.

The Solution: Ensure all data is complete and accurate. Use verified sources.

Mistake 2: Incorrect Calculations

The Problem: Emission intensity calculations may be incorrect.

The Solution: Double-check all calculations. Use professional assistance if needed.

Mistake 3: Missing Documentation

The Problem: Required supporting documentation may be missing.

The Solution: Prepare all documentation in advance. Use checklists.

Mistake 4: Late Filing

The Problem: Filing after the July 31 deadline.

The Solution: File early. Do not wait until the last minute.

Mistake 5: Inadequate Verification

The Problem: Verification may not meet ACV agency requirements.

The Solution: Engage an ACV agency early. Ensure they are accredited in your sector.

Mistake 6: Underestimating Complexity

The Problem: The CCTS involves complex calculations, multiple regulatory bodies, and stringent documentation requirements.

The Solution: Work with a carbon advisory firm like Carboned.in.

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Consequences of Non-Filing

Environmental Compensation

The Central Pollution Control Board (CPCB) is empowered to levy environmental compensation equivalent to twice the average market price of carbon credit certificates for the relevant period.

Environmental Compensation = Shortfall (tonnes CO₂e) × Average Market Price × 2

Payment Timeline

The penalty must be paid within 90 days of the imposition order.

Reputational Damage

The market creates its own leaderboard. Net sellers of credits look like efficiency leaders. Net buyers look like laggards.

Legal Consequences

Non-compliance is a violation of the Energy Conservation Act, 2001. This can lead to:

• Legal proceedings
• Regulatory sanctions
• Potential restrictions on operations

Export Competitiveness

India's steel and aluminium exports to the EU fell 24.4% in FY2025 — steel alone down 35.1% — before CBAM even imposed a financial obligation. Poor compliance will only accelerate this decline.

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The Role of Accredited Carbon Verification Agencies

What Is an ACV Agency?

An Accredited Carbon Verification (ACV) agency is an independent third-party entity that verifies GHG emissions data and compliance with CCTS requirements.

ACV Agency Requirements

Requirement	Details
Minimum Turnover	₹50 lakh per annum in at least one of the previous three years
Financial Stability	Demonstrate financial resources and stability
Accreditation	Accredited by BEE
Expertise	Sector-specific expertise

How to Select an ACV Agency

Factor	What to Look For
Accreditation	Accredited by BEE in your sector
Experience	Experience in your sector
Track Record	Proven track record
Capacity	Ability to handle your verification
Cost	Competitive pricing

The Verification Process

Step	Description
1. Engagement	Engage an ACV agency
2. Data Submission	Submit emissions data
3. Document Review	ACV agency reviews documentation
4. Site Visit	ACV agency conducts site visit
5. Verification Report	ACV agency prepares Verification Report
6. Certificate of Verification	ACV agency issues Form B

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How Carboned.in Can Help

At Carboned.in, we help obligated entities navigate the Form A filing process with clarity and confidence.

Our Form A Filing Services

Service	What We Do
Data Preparation	Help you gather and organise emissions data
Intensity Calculation	Calculate your emission intensity
Gap Analysis	Assess your compliance gap
Documentation	Prepare Form A and supporting documents
Verification Coordination	Connect you with ACV agencies
Form A Submission	Guide you through the submission process

Why Choose Carboned.in?

Reason	Why It Matters
Legal Expertise	Led by Siddharth Gupta, Advocate, Calcutta High Court
Regulatory Knowledge	Deep understanding of CCTS and Form A requirements
ACV Network	Relationships with accredited ACV agencies
End-to-End Support	From data preparation to submission

Your first consultation is completely free. No obligation. Just honest advice.