Form A Filing Under CCTS – Step-by-Step Compliance Guide for Obligated Entities

Introduction: The Deadline Is Here

The clock is ticking. For approximately 490 obligated entities across India's most emission-intensive industries, the first major compliance deadline under the Carbon Credit Trading Scheme (CCTS) is July 31, 2026.

By this date, every obligated entity must submit its Performance Assessment Document—commonly known as Form A—to the Bureau of Energy Efficiency (BEE). This is the document that reports your facility's greenhouse gas (GHG) emissions for the 2025-26 compliance year, using fiscal year 2023-24 as the baseline.

This is not a bureaucratic formality. Form A is the foundational compliance filing under the CCTS. Its accuracy determines whether you earn Carbon Credit Certificates (CCCs), must purchase them, or face financial penalties.

This guide provides a step-by-step walkthrough of the Form A filing process. It is designed for compliance officers, sustainability managers, and anyone responsible for meeting India's new carbon compliance obligations.

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What Is Form A and Why Does It Matter?

Form A is the Performance Assessment Document that obligated entities must submit to the Bureau of Energy Efficiency (BEE). It is the primary compliance filing document under the CCTS.

What Form A Requires

Component	Description
Verified emissions data	Actual GHG emissions for the compliance year (2025-26)
Production data	Total output in appropriate units
Emission intensity calculation	tCO₂e per tonne of equivalent product
Comparison with target	Performance against your notified GEI target
Reduction measures	Documentation of any in-house reductions achieved
Credit procurement	Documentation of any CCCs procured

Why It Matters

Form A serves as the basis for:

• Compliance assessment: BEE uses it to determine if you met your target
• CCC issuance: If you outperformed, you receive CCCs
• Penalty calculation: If you fell short, it determines your shortfall
• Market participation: It connects your physical emissions to the carbon market

The filing deadline is July 31, 2026.

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Who Must File Form A?

The Obligated Entities

Form A must be filed by all obligated entities covered under the compliance mechanism of the CCTS.

The Covered Sectors

Sector	Status	Entities
Aluminium	Notified	~13
Cement	Notified	~186
Chlor-Alkali	Notified	~30
Pulp and Paper	Notified	~53
Petroleum Refining	Notified	Part of 208
Petrochemicals	Notified	Part of 208
Textiles	Notified	~173
Total	~490 entities

What If You're Not Sure?

If you are unsure whether your facility has been notified, that is the first thing to confirm—because every deadline that follows depends on it.

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The Legal Framework and Deadlines

The Legal Basis

Instrument	What It Does
Energy Conservation Act, 2001 (as amended)	Provides statutory basis for the CCTS
Carbon Credit Trading Scheme, 2023	Established the institutional architecture
GHG Emission Intensity Target Rules, 2025	Made GEI reduction targets legally binding
CERC CCC Regulations, 2026	Operational framework for CCC trading

The Key Dates

Date	Event
April 1, 2025	Compliance obligations come into force
July 31, 2026	Form A filing deadline
September 30, 2026	GHG emissions report and verification submission
October 2026	First CCC trading expected

The Compliance Cycle

Step	Description	Timeline
1. Monitoring	Track emissions and production data	Throughout compliance year
2. Form A Filing	Submit Performance Assessment Document	July 31, 2026
3. Verification	Submit GHG emissions report and verification	Within 2 months of Form A
4. Assessment	BEE assesses compliance	Following verification
5. Credit Trading	Trade CCCs on Power Exchanges	Starting October 2026

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Step 1: Gather Your 2023-24 Baseline Data

Why the Baseline Matters

The baseline year is fiscal year 2023-24. Your emission intensity target is expressed relative to this baseline. Accuracy here is critical.

What Data to Gather

Data Type	Description
Production data	Total output in appropriate units (tonnes, MT, etc.)
Fuel consumption	All fuels used (coal, natural gas, diesel, etc.)
Electricity consumption	Grid electricity imported and consumed
Captive power generation	Any on-site power generation
Process emissions	Emissions from industrial processes (e.g., calcination in cement)
Waste handling	Any emissions from waste treatment

Data Sources

Source	What It Provides
Production records	Output data
Fuel purchase invoices	Fuel quantity and type
Energy bills	Electricity consumption
Process logs	Process-related data
Emission factor databases	Standard emission factors (e.g., from CEA)

The Data Quality Check

• Is the data complete for the entire fiscal year?
• Is it consistent with previous years?
• Is there a clear audit trail?
• Can the data be verified by an ACV agency?

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Step 2: Calculate Your Emission Intensity

The Formula

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

Calculating Total GHG Emissions

Emission Source	How to Calculate
Scope 1 (Direct)	Fuel consumption × Emission Factor
Scope 2 (Indirect)	Electricity consumption × Grid Emission Factor
Process emissions	Activity data × Process Emission Factor

Example Calculation

A cement plant produces 1,000,000 tonnes of cement and emits 800,000 tonnes of CO₂e in 2023-24.

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

Key Considerations

Factor	Why It Matters
Grid Emission Factor	Use the latest factor from CEA's CO₂ Baseline Database
Units	Ensure consistency with your target's units
Boundary	Include all emissions sources within your facility boundary

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Step 3: Understand Your Notified Target

Where to Find Your Target

Your target was notified at the sub-sector level by the Ministry of Environment, Forest and Climate Change (MoEFCC).

The Target Range

Targets vary by sector and sub-sector. For example:

Sector	Target Reduction Range
Cement	2-5% (varies by sub-sector)
Aluminium	2-5%
Iron and Steel	2.1-9.3% (draft notification)
Textiles	3-7%

What Your Target Means

Your target is expressed as a specific emission intensity value (tCO₂e per unit of output) that you must achieve in the compliance year.

The Back-Loaded Structure

The targets are back-loaded: about 40% of the required reduction must be achieved in 2025–26 and the remaining 60% in 2026–27.

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Step 4: Assess Your Compliance Gap

The Gap Formula

Compliance Gap = Baseline Intensity – Target Intensity

Scenario Analysis

Scenario	Outcome
Current intensity ≤ Target	No gap; you may be eligible for CCCs
Current intensity > Target	Gap exists; you need to reduce emissions or procure CCCs

Example Calculation

Variable	Value
Baseline intensity (2023-24)	0.85 tCO₂e/t
Target intensity (2025-26)	0.80 tCO₂e/t
Current intensity (2025-26)	0.82 tCO₂e/t
Gap	0.02 tCO₂e/t

If your production is 1,000,000 tonnes, your shortfall is 20,000 tCO₂e.

What This Means

Gap Size	Action Required
Surplus	You earn CCCs
Zero	No action required
Deficit	You must procure CCCs or reduce emissions

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Step 5: Document Your Reduction Measures

What to Document

If you have implemented measures to reduce emissions, document:

Item	Description
Energy efficiency improvements	Motor upgrades, waste heat recovery, etc.
Fuel switching	Moving from coal to natural gas or biomass
Process optimization	Changes to production processes
Renewable energy	On-site solar, wind, or biomass
CCS/CCUS	Carbon capture and storage

Documentation Requirements

Document	Purpose
Implementation records	When and how measures were implemented
Performance data	Energy savings, emission reductions
Verification	Evidence that reductions are real

Why This Matters

Documenting your reduction measures:

• Demonstrates compliance
• Supports your CCC claim (if you outperformed)
• Provides evidence for verification

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Step 6: Engage an Accredited Carbon Verification (ACV) Agency

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
Accreditation	Must be accredited by BEE
Expertise	Sector-specific expertise in GHG emissions
Independence	Must be independent and impartial

The ACV Verification Process

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

When to Engage

Engage an ACV agency early—well before the July 31 deadline. Verification takes time.

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Step 7: Complete the Form A Document

What Form A Contains

Section	Content
Entity Information	Name, location, sector, contact details
Production Data	Total output for the compliance year
Emissions Data	Scope 1, Scope 2, and process emissions
Emission Intensity	Calculated intensity for the compliance year
Target Comparison	Performance against notified target
Gap Assessment	Surplus or deficit calculation
Reduction Measures	Description of any in-house reductions
Credit Procurement	Details of any CCCs procured
Verification	ACV agency verification statement

Where to Get the Form

Form A templates are available on:

• The Indian Carbon Market Portal (www.indiancarbonmarket.gov.in)
• The BEE website

Tips for Completing Form A

Tip	Why It Matters
Use accurate data	Accuracy is essential for compliance
Double-check calculations	Errors can lead to penalties
Get verification early	Verification takes time
Keep supporting documents	Maintain an audit trail

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Step 8: Submit Through the Indian Carbon Market Portal

The Portal

The Indian Carbon Market Portal (www.indiancarbonmarket.gov.in) was launched on March 21, 2026. It is the central platform for:

• Entity registration
• CCC issuance
• Compliance submissions (including Form A)
• Validation and verification

How to Submit

Step	Action
1	Log in to the ICM Portal
2	Navigate to the compliance submission section
3	Upload the completed Form A
4	Upload supporting documents
5	Submit the form
6	Receive confirmation of submission

What If You're Not Registered?

If you haven't registered on the ICM Portal, do it now. Registration is mandatory for all obligated entities.

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Step 9: Submit Your GHG Emissions Report and Verification

The Requirement

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

The GHG Emissions Report

The GHG Emissions Report is a comprehensive document that reports your facility's GHG emissions for the compliance year.

What It Includes

Component	Description
Scope 1 Emissions	Direct emissions from fuel combustion and industrial processes
Scope 2 Emissions	Indirect emissions from electricity and heat consumption
Production Data	Total output in appropriate units
Emission Intensity	Calculated emission intensity
Monitoring Plan	How emissions were monitored
Verification Statement	Independent verification of data

The Verification 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

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Step 10: Prepare for Post-Submission Assessment

What Happens After Submission

Step	Description
1. BEE Review	BEE reviews your Form A and supporting documents
2. Compliance Assessment	BEE assesses whether you met your target
3. CCC Issuance	If you outperformed, CCCs are issued
4. Penalty Assessment	If you fell short, penalties may apply

What to Expect

BEE may:

• Request additional information
• Conduct its own verification
• Issue a compliance order

Keep Records

Maintain all supporting documents for at least 4 years in case of audit.

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Common Mistakes to Avoid

Mistake 1: Incomplete Data

Problem: Missing or incomplete emissions data.

Solution: Gather all required data well in advance. Use the checklist provided in this guide.

Mistake 2: Incorrect Calculations

Problem: Errors in emission intensity calculation.

Solution: Double-check all calculations. Use standard emission factors.

Mistake 3: Missing the Deadline

Problem: Filing after July 31, 2026.

Solution: Start early. File well before the deadline.

Mistake 4: Inadequate Verification

Problem: Verification not completed on time.

Solution: Engage an ACV agency early. Give them enough time.

Mistake 5: Ignoring the Gap

Problem: Not assessing your compliance gap until it's too late.

Solution: Calculate your gap early. Procure CCCs if needed.

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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 Services

Service	What We Do
Baseline Calculation	Calculate your 2023-24 emission intensity
Target Interpretation	Understand your notified target
Gap Analysis	Assess your compliance position
Form A Preparation	Assist with documentation and submission
Verification Support	Coordinate with ACV agencies
Portal Registration	Guide you through ICM Portal registration
Credit Procurement	Help you buy CCCs at the best price

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 BEE requirements
Practical Experience	Real-world experience with Form A filing
End-to-End Support	From baseline to compliance

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

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Conclusion

The July 31 deadline is real. Missing it means financial penalties. Filing accurate, verified data on time is the first step to successful CCTS compliance.

Key Takeaways

Aspect	What You Need to Know
Deadline	July 31, 2026
Who Must File	~490 obligated entities
Baseline Year	2023-24
Compliance Year	2025-26
Key Document	Form A (Performance Assessment Document)
Verification	Required by an ACV agency
Penalty	2× average market price of CCCs

The Choice Is Yours

Option	Outcome
Act now	File on time, avoid penalties, earn CCCs if eligible
Wait and see	Miss deadline, face penalties, higher costs

How Carboned.in Can Help

At Carboned.in, we help obligated entities file Form A with confidence.

• Baseline Calculation: Know your starting point
• Gap Analysis: Assess your position
• Form A Preparation: Ensure accuracy
• Verification Support: Coordinate with ACV agencies
• Credit Procurement: Buy CCCs if needed

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