Mastering the GHG Monitoring Plan – A Practical Guide for Obligated Entities Under India's CCTS

Introduction: The Foundation of Credible GHG Reporting

On 21 March 2026, the Indian Carbon Market Portal was launched, marking the formal beginning of India's carbon trading ecosystem. But before any carbon credit can be traded, before any verification can occur, before any compliance can be demonstrated, there must be a monitoring plan.

The monitoring plan is the foundation of credible greenhouse gas (GHG) reporting under India's Carbon Credit Trading Scheme (CCTS). It is the document that tells the Bureau of Energy Efficiency (BEE) and the accredited carbon verification agency (ACVA) exactly how an obligated entity will measure, monitor, and report its emissions.

As one industry expert noted, "The most significant development under India's Carbon Credit Trading Scheme (CCTS) is not the trading mechanism but the launch of the GHG Monitoring Plan Template by the Bureau of Energy Efficiency (BEE)."

The BEE has published a comprehensive monitoring plan template to help obligated entities develop their monitoring plans. This template covers every aspect of GHG monitoring: from entity details and gate-to-gate boundary definition to direct and indirect emission monitoring, data control procedures, and standard operating procedures.

This guide provides a practical, step-by-step walkthrough of the monitoring plan template, explaining what each section requires and how to complete it correctly.

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What Is a GHG Monitoring Plan?

Definition

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

What the Monitoring Plan Covers

Section	Content
Entity Information	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 Regulatory Requirement

Section 5.3 of the Detailed Procedure for Compliance Mechanism states: "The obligated entity shall monitor greenhouse gas emissions based on the monitoring plan and shall submit the monitoring plan to the Bureau within three months from the commencement of the first trajectory period."

The 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

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Why the Monitoring Plan Matters

The Foundation of GHG Reporting

The monitoring plan is the foundation upon which all GHG reporting is built. Without a credible monitoring plan, GHG emissions cannot be accurately measured, reported, or verified.

What the Monitoring Plan Enables

Enablement	Description
Accurate Measurement	Ensures all emission sources and source streams are identified and measured correctly
Consistent Reporting	Provides a standardised framework for reporting emissions year after year
Credible Verification	Enables ACVAs to verify emissions data with confidence
Compliance Demonstration	Demonstrates to BEE that the entity is meeting its compliance obligations
CCC Eligibility	Entities cannot earn CCCs without a credible monitoring plan

The Consequences of a Poor Monitoring Plan

Consequence	Description
Verification Issues	ACVAs may identify material misstatements
Compliance Failures	Incorrect emissions calculations may lead to non-compliance
Penalties	Environmental Compensation penalties may apply
Reputational Damage	Inaccurate reporting damages credibility
Lost Opportunities	Entities may miss out on CCC revenue

The BEE's Perspective

BEE has developed a standardised monitoring plan template to ensure consistency across obligated entities. The template helps obligated entities meet all the requirements of Section 5.6 of the Detailed Procedure, which specifies 13 distinct requirements for the monitoring plan.

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The BEE Monitoring Plan Template: An Overview

The Template Structure

The BEE monitoring plan template consists of multiple sheets, each covering a specific aspect of GHG monitoring:

Sheet	Purpose
Navigation	Central navigation to all sheets
Guidelines_Instruction	Instructions on how to use the template
Compliance_Tracker	30-item checklist mapping every BEE requirement
Version_History	Tracking of all monitoring plan versions
Definition	34 defined terms with plain-language explanations
Acronyms	84 acronyms with full forms and context notes
A_Entity_Details	General entity information and CCTS-mandated disclosures
B1_GTG_Boundary	Gate-to-Gate boundary definition
B2_Entity_Description	Narrative description and activity/emission source lists
C_PR_Monitoring	Production and raw material monitoring
D_Direct_emission_Monitoring	Direct emission monitoring
E_Indirect_emission_monitoring	Indirect emission monitoring
F_Cabon_Capture	Carbon capture and credit monitoring
G_Addition_information	Additional information
H_Management-Control	Management control and data quality
I_SOP_Register	Standard operating procedure register
J_Plant_Review_Checklist	Plant internal review checklist
K_BEE_Review_Checklist	BEE/ACVA review checklist
Activity_List	Master list of activities
List_of_master	Dropdown source lists

The Colour Coding System

The template uses a colour coding system to guide users:

Colour	Meaning
Yellow ■	Fillable input cells
Grey italic	Read-only guidance
Dropdown cells	Predefined input lists
Formula cells	Automatically computed

The Status Tracking System

The template includes a status tracking system to monitor completion:

Status	Meaning
✅ Complete	Addressed in the monitoring plan
⚠ Partial	Partially addressed, needs data
❌ Missing	Not yet drafted or missing

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Part A: Entity Information and Gate-to-Gate Boundary

A_Entity_Details: General Information

The Entity Details sheet captures general information about the obligated entity, including:

Section	Content
About the Entity	Name, sector, sub-sector, registration ID
Address/Location	Complete address, city, district, state, pin code
Contact Details	Plant head and energy manager details
CCTS-Specific Disclosures	Trajectory period, baseline year, ACVA details, emission calculation methodology, NABL status, renewable energy claim type, target GEI, achieved GEI, CCC status
Monitoring System Overview	ISO 50001 status, four-eye principle, ERP approval workflow, monitoring frequency, systems used

B1_GTG_Boundary: Gate-to-Gate Boundary Definition

The Gate-to-Gate Boundary sheet is one of the most critical sections of the monitoring plan. It defines what is inside and outside the entity's monitoring boundary.

Section 1: Activities/Emission Sources Included in the Boundary

Ref	Standard Activity	Your Plant Activity Name	Applies?	Emission Category	BEE Clause
INC-01	Combustion of fossil fuels in boilers		Yes/No	Direct Emission — Combustion	Sec 4.4(2)(ii)
INC-02	Combustion in process heaters, furnaces, calciners, rotary kilns		Yes/No	Direct Emission — Combustion	Sec 4.4(2)(ii)
INC-03	Process emissions from calcination of limestone/dolomite/magnesite		Yes/No	Direct Emission — Process	Sec 4.4(2)(iv)
INC-04	Primary aluminium smelting — anode carbon oxidation		Yes/No	Direct Emission — Combustion	Sec 4.4(2)(iv)
INC-05	PFC emissions from anode effects (aluminium only)		Yes/No	Direct Emission — PFC	Sec 4.2; Sec 5(7)(ix)
INC-06	Captive power plant — internally consumed portion		Yes/No	Direct Emission — Combustion	Sec 4.4(2)(ii)
INC-07	Emergency diesel generators		Yes/No	Direct Emission — Combustion	Sec 4.4(2)(ii)
INC-08	Anode baking plant		Yes/No	Direct Emission — Combustion + Process	Sec 4.4(2)(ii)-(iv)
INC-09	Flue gas scrubbing units consuming carbonate reagents		Yes/No	Direct Emission — Process	Sec 5(6)(i)
INC-10	Sponge iron/DRI production		Yes/No	Direct Emission — Combustion + Process	Sec 4.4(2)
INC-11	BFG, COG, BOF gas combustion		Yes/No	Direct Emission — Combustion	Sec 4.4(2)(iii)
INC-12	VSF/Viscose Staple Fibre production		Yes/No	Direct Emission — Combustion	Sec 4.4(2)(ii)
INC-13	Chlor-alkali electrolysis		Yes/No	Indirect Emission - Electricity	Sec 5(7)(vi)
INC-14	Purchased electricity from national grid		Yes/No	Indirect Emission — Grid	Sec 5(7)(vi)
INC-15	Purchased electricity via open access		Yes/No	Indirect Emission — Grid	Sec 5(7)(vi)
INC-16	Dedicated RE Power Purchase Agreement		Yes/No	Indirect Emission — RE/PPA	Sec 5(7) Cl.17
INC-17	Imported steam or heat		Yes/No	Indirect Emission — Heat	Sec 5(7)(viii)
INC-18	Notional emissions for imported intermediate products		Yes/No	Direct Emission — Notional	Sec 4.4(2)(vi)

Section 2: Activities Excluded from the Boundary

Ref	Standard Exclusion	Applies?	Reason	BEE Clause
EXC-01	Biomass/biogenic fuel combustion	Yes/No		Sec 4.4(3)(i)
EXC-02	Onsite renewable energy generation	Yes/No		Sec 4.4(3)(ii)
EXC-03	Co-processing of approved Alternate Fuels	Yes/No		Sec 4.4(3)(iii)
EXC-04	CO₂ captured via CCUS	Yes/No		Sec 4.4(3)(iv)
EXC-05	Energy consumption in employee colony	Yes/No		Sec 4.4(3)(v)
EXC-06	Temporary/major capital construction	Yes/No		Sec 4.4(3)(v)
EXC-07	Outside transportation	Yes/No		Sec 4.4(3)(v)
EXC-08	Refrigerant leakages in office buildings	Yes/No		Sec 4.4(3)(vi)
EXC-09	Electricity exported outside the plant boundary	Yes/No		Sec 4.4(3)(vii)
EXC-10	Renewable Energy Certificate purchases	Yes/No		Sec 5(7) Cl.17
EXC-11	All Scope 3 upstream and downstream emissions	Yes/No		Sec 5(1); Sec 1(16)

B2_Entity_Description: Entity Description

The Entity Description sheet provides a narrative description of the entity and its activities.

Entity and Activities Description

Provide a brief overview of the obligated entity, including:

• Main products and capacity
• Key process units (e.g., kiln, boiler, BF, spinning machines)
• Energy systems (CPP, boiler, renewable energy)
• Major emission-generating processes

List of Activities

Ref	Activity	Installed Capacity	Unit	Technology	By-Product
A1	Combustion of Fossil Fuel	70	MW	Boiler/Turbine
A2	Production of Cement Clinker	500	TPH	Kiln	No
A3	Production of Cement	300	TPH	Cement Mill	No
A4	Captive Renewable Energy Plant	10	MW	Solar	No
A5	Renewable Energy Procurement	30	MW	Wind	No

List of Emission Sources

Ref	Emission Source	Activity Reference
ES1	Coal Fired Boiler (CPP - Fuel Combustion)	A1
ES2	Crusher (Electricity)	A2
ES3	Raw mill (Electricity)	A2
ES4	Cement Clinker kiln - 1	A2
ES5	Cement Clinker kiln - 2	A2

List of Source Streams

Ref	Source Stream Name	Ref Emission Source	Ref Activity
SS1	Indian Coal in Boiler	ES1	A1
SS2	Imported Coal consumption in Kiln	ES4	A2
SS3	Pet Coke in Kiln	ES4	A2
SS4	Biomass as Alternate fuel in Kiln	ES4	A2
SS5	HSHS used for DG Set	ES9	A1

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Part B: Monitoring Details – Production, Direct Emissions, and Indirect Emissions

C_PR_Monitoring: Production and Raw Material Monitoring

Production Measurement

Ref	Production Measurement	Ref Emission Source	Ref Activity	Type of Instrument	Location	Range	Uncertainty	Calibration Frequency
PM1	Clinker from Kiln 1	ES4	A2	Weigh Bridge	cooler	1000-50000 kg	0.5	Bi Annual
PM2	Clinker from Kiln 2	ES5	A2	Weigh Bridge	Ball Mill	1000-50000 kg	0.5	Annual
PM3	Cement from Mill 1	ES6	A3	Weigh Bridge	Ball Mill	1000-50000 kg	0.5	Annual

Raw Material Measurement

Ref	Raw Material	Ref Emission Source	Ref Activity	Type of Instrument	Location	Range	Uncertainty	Calibration Frequency
RM1	Limestone consumption	ES4	A2	Weigh Bridge	cooler	1000-50000 kg	0.5	Bi Annual
RM2	Fly Ash consumption	ES5	A2	Weigh Bridge	Ball Mill	1000-50000 kg	0.5	Annual
RM3	Gypsum Consumption	ES6	A3	Weigh Bridge	Ball Mill	1000-50000 kg	0.5	Annual

Electricity Generation Monitoring

Ref	Source of Electricity	Ref Emission Source	Ref Activity	Type of Meter	Accuracy Class	Calibration Frequency
EG1	Steam Turbine	ES1	A1	Smart Energy Meter	0.01	Bi Annual
EG2	Solar	-	A6	Smart Energy Meter	0.01	Bi Annual

D_Direct_emission_Monitoring: Direct Emission Monitoring

Source Stream Measurement

Ref	Source Stream	Ref Emission Source	Ref Activity	Type of Instrument	Location	Range	Uncertainty	Calibration Frequency
SS1	Indian Coal Consumption	ES1	A1	Rotary Meter	Belt -1 Tower 2	2000-30000 kg	0.6	Annual
SS2	Petr coke consumption	ES6	A2	Rotary Meter	RM -342	500-10000 kg	0.8	Annual

Activity Data Measurement Methodology

Ref	Source Stream	NCV	Calorific Value Method	Emission Factor	Oxidation Factor
AM1	Default	ADB	Type I	Default	NA

Laboratories and Methods

Lab Ref	Laboratory Details	Parameter	Method of Analysis	NABL Accredited
L1	Internal Lab - 1	Calorific Value	IS 1350 (Part 2): 2022	No
L2	Internal Lab - 1	C - Content	IS 1350 (Part 4/Sec 1): 1974	No

E_Indirect_emission_monitoring: Indirect Emission Monitoring

Electricity Monitoring

Provide a detailed description of the methodology used to measure electricity consumption within the plant, including:

• How electricity consumption is divided by section
• Feeder details for each section
• Calculations used to balance electricity consumption

Master Energy Meter Details

Ref	Energy Meter ID	Type	Accuracy Class	Calibration Frequency
ME1	Meter I	HT Meter	0.2S	Annual

Electricity Measurement Points

Ref	Feeder Details	Metering Type	Type of Meter	Accuracy Class	Calibration Frequency
EL1	UAT Feeder	Import	Smart Digital meter	0.1	Annual

Steam and Chilled Water Monitoring

Provide detailed descriptions of the methodology used to monitor steam and chilled water consumption within the plant, including:

• How thermal energy is measured, recorded, and bifurcated
• Metering locations and specifications
• Calibration frequencies

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Part C: Governance and Compliance – Management Control and SOPs

H_Management-Control: Management Control

Responsibilities for Monitoring and Reporting

Job Title/Post	Responsibilities
Energy Manager	Overall responsibility for CCTS compliance
Production Data Custodian	Production data collection and validation
Fuel Store/Utility Manager	Fuel consumption monitoring
Laboratory In-Charge	Fuel and material analysis
IT/Data Management Representative	Data systems and reporting

Data Flow and Control Procedures

Provide a detailed description of the procedures used to manage data flow activities, including:

• Data collection and processing
• Data validation and aggregation
• Data transfer and storage
• Quality assurance and control

CCTS Data Quality & Four-Eye Principle Compliance

Control Activity	Description	Responsible Post	Frequency
Data Collection & Primary Measurement	Capture activity data from meters, invoices, lab reports	Energy Manager	Monthly
Internal Review (4-Eye Principle)	Second reviewer checks all entries	Senior Energy Manager	Annual
Emission Factor Update Review	Review Type I/II emission factors annually	Energy Manager	Annual
Sampling Plan Compliance Check	Verify solid fuel auto-sampler records	QA Manager	Quarterly
NABL Lab Accreditation Verification	Confirm lab accreditation is current	QA Manager	Annual

I_SOP_Register: Standard Operating Procedure Register

13 Mandatory SOPs

S.No	SOP Title	BEE Clause Ref	Status
1	Data Flow & Control Procedure	Section 5(6)(vi)	☐ Draft / ☐ Approved
2	Fuel & Material Sampling Plan	Section 5(13)	☐ Draft / ☐ Approved
3	Solid Fuel NCV Determination Procedure	Section 5(9)(i)(a)	☐ Draft / ☐ Approved
4	Gaseous Fuel NCV & Composition Analysis	Section 5(9)(i)(b)	☐ Draft / ☐ Approved
5	Measurement Equipment Calibration Procedure	Section 5(11)	☐ Draft / ☐ Approved
6	Emission Factor Selection & Update Procedure	Section 5(10)	☐ Draft / ☐ Approved
7	Stock Change Estimation Procedure	Section 5(8)(iv)	☐ Draft / ☐ Approved
8	GHG Emission Report Preparation Procedure	Section 5(6)(vi)	☐ Draft / ☐ Approved
9	Monitoring Plan Review & Update Procedure	Section 5(4) & 5(6)(ix)	☐ Draft / ☐ Approved
10	Renewable Energy Claim Documentation	Section 5(7)(vi)	☐ Draft / ☐ Approved
11	PFC Emission Monitoring Procedure	Section 5(7)(ix)	☐ Draft / ☐ Approved
12	Personnel Competency & Training Procedure	Section 5(6)(x)	☐ Draft / ☐ Approved
13	Boundary Change Notification Procedure	Section 5(1)	☐ Draft / ☐ Approved

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Part D: Review and Compliance Checklists

J_Plant_Review_Checklist: Plant Internal Review Checklist

The Plant Internal Review Checklist is to be completed by the Energy Manager/Sustainability Team BEFORE submission to BEE. All items must be confirmed before the plan is submitted.

#	Checklist Item	Status	Verified By	Date Checked
A1	Entity registration ID on ICM portal is confirmed
A2	Sector and sub-sector notified by MoP are correctly stated
A3	Trajectory period and baseline year are correctly stated
A4	Gate-to-gate boundary narrative is written and complete
A5	All included activities reviewed
A6	All excluded activities reviewed
A7	Source stream boundary diagram is prepared
B1	All Emission Sources (ES codes) are listed
B2	All Source Streams (SS codes) are listed
C1	Methodology description written for each source stream
C2	Measurement points documented
C3	Emission factor type selected and documented
D1	Electricity consumption methodology written
D2	CEA grid emission factor stated
F1	Monitoring plan approval workflow documented
F2	Roles and responsibilities table complete
G1	Monitoring plan version number correctly filled

K_BEE_Review_Checklist: BEE/ACVA Review Checklist

The BEE Review Checklist is for use by BEE reviewers and ACVAs to assess the completeness and compliance of the submitted Monitoring Plan.

#	Checklist Item	Finding	BEE Clause	Priority
1.1	Plan submitted within 3 months of trajectory period commencement		Sec 5(3)-(4)	M
1.2	Plan signed and approved by Plant Head		Sec 5(5)	H
2.1	Entity registration ID confirmed		Sec 5(6)(i)	H
2.2	Sector and sub-sector correctly classified		Sec 4.1	H
2.3	Gate-to-gate boundary narrative is written and unambiguous		Sec 5(1); 5(6)(i)	H
3.1	All emission sources listed and uniquely coded		Sec 5(6)(i)	H
3.2	All source streams listed and linked to ES codes		Sec 5(6)(i)	H
4.1	Methodology description provided for each source stream		Sec 5(7)(ii)-(iii)	H
4.2	Measurement points documented		Sec 5(6)(xi)	H
5.1	Electricity monitoring methodology described		Sec 5(7)(vi)	H

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Step-by-Step: How to Complete the Monitoring Plan Template

Step 1: Start with the Front Matter

Action	Description
Version History	Record all versions, revisions, and submission history
Compliance Tracker	Track compliance with all BEE CCTS requirements

Step 2: Fill Part A – Entity Information

Action	Description
Entity Details	Fill general information and basic details of the obligated entity
Gate-to-Gate Boundary	Define the emission boundary, including included and excluded activities
Entity Description	Describe plant operations, activities, emission sources, and source streams

Step 3: Fill Monitoring Sections (C → F)

Action	Description
Production Monitoring	Monitor production data
Direct Emission Monitoring	Monitor direct emissions
Indirect Emission Monitoring	Monitor indirect emissions
Carbon Capture Monitoring	Monitor carbon capture (if applicable)

Step 4: Fill Additional Information (G)

Action	Description
Additional Information	Provide any additional explanations or supporting details

Step 5: Complete Governance & SOPs (H, I)

Action	Description
Management Control	Describe data flow, roles, responsibilities, and quality control procedures
SOP Register	List all 13 mandatory SOPs

Step 6: Perform Internal Review (J)

Action	Description
Internal Review	Complete the Plant Internal Review Checklist before submission

Step 7: Submit to BEE

Action	Description
Submission	Submit the completed monitoring plan to BEE within the required timeline

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Common Pitfalls and How to Avoid Them

Pitfall 1: Vague Gate-to-Gate Boundary

The Problem: A vague boundary is one of the most common causes of problems later in the compliance cycle.

The Solution: Define clearly what is inside and outside the facility boundary before you start the registration process. Use the B1_GTG_Boundary sheet to document all included and excluded activities.

Pitfall 2: Incomplete Documentation

The Problem: Required documents are missing or incorrect.

The Solution: Use the compliance tracker to ensure all requirements are addressed. Use the document checklist before starting registration.

Pitfall 3: Missing SOPs

The Problem: Not all 13 mandatory SOPs are documented.

The Solution: Use the I_SOP_Register sheet to track the status of all 13 mandatory SOPs. Ensure each SOP is drafted and approved.

Pitfall 4: Inadequate Data Control Procedures

The Problem: Data flow and control procedures are not documented.

The Solution: Document all data flow activities, including data collection, processing, validation, and reporting. Implement the four-eye principle.

Pitfall 5: Incorrect Emission Factor Selection

The Problem: Type I emission factors are used when Type II factors are available.

The Solution: Ensure Type II emission factors are used for solid fuel, gaseous fuel, and process emissions. Use Type I only when Type II is unavailable.

Pitfall 6: Insufficient Sampling Frequency

The Problem: Sampling frequency does not meet the minimum requirements.

The Solution: Ensure solid fuel samples are collected at every 20,000 tonnes and at least once every month. Gaseous fuel samples must be collected at least once every week.

Pitfall 7: Going It Alone

The Problem: Trying to complete the monitoring plan without professional guidance.

The Solution: Engage a carbon advisory firm like Carboned.in to help you navigate the complex requirements.

Conclusion: The Plan Is the Foundation

The GHG monitoring plan is the foundation of credible GHG reporting under India's Carbon Credit Trading Scheme. Without a credible monitoring plan, emissions cannot be accurately measured, reported, or verified.

Key Takeaways

Aspect	What You Need to Know
Initial Submission	Within 3 months of trajectory period commencement
Annual Updates	Within 3 months of each compliance year start
Template	BEE monitoring plan template with 20+ sheets
Mandatory SOPs	13 SOPs covering all aspects of GHG monitoring
Key Requirement	Gate-to-Gate boundary definition
Emission Factors	Type II preferred; Type I only when unavailable
Sampling Frequency	Solid fuel: 20,000 tonnes/month; Gas: weekly

The Choice Is Yours

Option	Outcome
Complete the monitoring plan correctly	Credible reporting, smooth verification, CCC eligibility
Ignore the monitoring plan requirements	Verification issues, compliance failures, penalties