CCTS Offset Mechanism: India approved the methodologies and never finished the rules

BEE has approved four offset methodologies that cannot be used as written. Two of them depend on programme-of-activities aggregation; two of them depend on a non-permanence risk assessment tool. Both instruments went out for public comment in June 2026, both windows closed in July, and as of today neither has produced an amended instrument. The methodologies are on the register. The rules they run on are not.

Six closed consultation windows, not four

Coverage of the CCTS Offset Mechanism has counted the project-level consultations — the draft Project Design Documents. There are four of those. There are also two rule-making consultations, and those are the ones that matter, because they amend the governing procedure rather than one applicant’s paperwork.

Window 3 closed 69 days ago. Window 4 closed 64 days ago.

Why those two are the consequential ones

• The PoA procedure is what lets distributed and smallholder activities register as one programme instead of one project at a time. Without it, aggregation has no route, and an activity whose unit economics only work in aggregate has no route either.
• The Non-Permanence Risk Assessment Tool is what makes reversible removals — forestry above all — bankable, by defining how reversal risk is buffered. Without it there is no approved way to quantify the risk a buyer is being asked to carry.

Four approved methodologies depend on them

From BEE’s Methodologies and Tools page, last updated 7 July 2026 — five days before the second window even closed:

• BM AG04.001 — methane recovery from livestock and manure management at households and small farms. Aggregation-dependent.
• BM AG04.002 — improved management practices in rice cultivation. Aggregation-dependent.
• BM FR05.001 — afforestation and reforestation of degraded mangrove habitats. Reversal risk.
• BM FR05.002 — afforestation and reforestation of lands except wetlands. Reversal risk.

A household biogas methodology with no aggregation procedure is a methodology for a project nobody can afford to register alone. A mangrove restoration methodology with no non-permanence tool is a methodology whose central risk has no approved treatment.

The absence, checked rather than assumed

“The consultation closed and nothing happened” is only worth publishing if the outputs genuinely are not there. Two checks, both run again on 15 September 2026:

1. The Detailed Procedure for the Offset Mechanism — the document both consultations propose to amend. A HEAD request returns 200 with a Last-Modified of Mon, 13 Apr 2026 04:51:36 GMT and a length of 39,881,882 bytes. That is three months before either window closed, and byte-identical to the reading taken earlier the same day. The file has not been touched.
2. The Methodologies and Tools page, last updated 7 July 2026. Full text searched: “non-permanence” returns nothing; “ecosystem-based” returns nothing. The approved tool list runs BM-T-001 to 006, 008, 010, 011, 013, 014 and 015, plus forestry tools BM-T-AR-0002 to 0005. Sixteen tools, and no non-permanence tool at any number.

What this means if you are preparing an offset project

• If your activity is aggregation-dependent, the procedure you would register under does not exist in final form. A PDD written against the current Detailed Procedure is written against a document that is under active amendment.
• If your activity involves reversible removals, there is no approved buffer or risk-assessment method to price against.
• Four PDDs have completed public comment. None of the four appears on the portal’s Listed Projects register, which still holds exactly one entry, a test record called “Test1308”. Registered Projects holds nothing at all.

What would change this reading

Any one of the following, and we are checking for each on a standing basis: the Detailed Procedure’s Last-Modified date moves; a non-permanence tool appears in the tool list; the PoA procedure is published in final form; or a real project replaces Test1308 on Listed Projects. We will date the change when it happens.

Sources

All primary, all on beeindia.gov.in and indiancarbonmarket.gov.in, all read on 15 September 2026: the Carbon Market document index; the Methodologies and Tools page, last updated 7 July 2026; the two consultation notices, last updated 10 June 2026 and 23 June 2026, with comment deadlines of 8 July and 13 July 2026 stated in their own text; a HEAD request against the Detailed Procedure PDF; and the ICM portal’s Listed Projects and Registered Projects registers.