India’s carbon market is fully built and has never traded a credit

Last checked 10 September 2026. Monitored since 26 August 2026.

As of 10 September 2026, India’s Carbon Credit Trading Scheme covers 490 obligated entities across seven notified sectors, operates a live national registry, a market portal launched on 21 March 2026, fifteen accredited verification agencies, and trading regulations notified by the electricity regulator on 27 April 2026 — and no compliance carbon credit has been reported traded in it. The scheme’s first compliance deadline is reported to have passed on 31 July 2026.

That sentence is the whole story, and it is not one you will find in the official material, which describes what has been built rather than what has happened.

It is worth being precise about what is not being claimed. Nothing here says the CCTS has failed, and nothing here says trading will not start: coverage this week puts the first exchange trading at around October 2026. The claim is narrower and checkable — that on 10 September 2026 every institutional precondition is in place, the first compliance deadline is behind us, and the market has still not opened.

What exists

The institutional architecture is genuinely complete, and it was assembled quickly by the standards of emissions trading schemes anywhere.

ComponentStatusDate
Obligated entities under notified targets490282 from 8 Oct 2025, 208 from 13 Jan 2026
Sectors with notified targets7Of BEE’s nine-sector scoping list
Indian Carbon Market PortalLiveLaunched 21 Mar 2026
National registryLive
Accredited verification agencies15 (3 final, 12 provisional)Accreditations issued 2 Mar – 24 Jun 2026
Trading regulations (CERC)Notified27 Apr 2026, Gazette No. 292
Methodologies approved or in consultation19
First compliance deadlineReported passed31 Jul 2026
Recognised abroad for carbon-price reliefUK CBAM qualifying schemeAssessed 19 Jun 2026, published 27 Aug 2026

Three of those rows deserve more than a cell.

The trading rules are not missing. The Central Electricity Regulatory Commission notified the (Terms and Conditions for Purchase and Sale of Carbon Credit Certificates) Regulations, 2026 on 27 April 2026 under Gazette No. 292 — the row is on CERC’s own register of regulations in force. This closes the most obvious objection to everything below, which is that there was nothing to trade under. There has been, since April.

A correction, made before publication rather than after. Several secondary sources date these regulations 27 February 2026. CERC’s register gives 27 April. Where they disagree, the regulator’s own register is what this article follows.

Fifteen verifiers is the true number and the misleading one. Read off BEE’s accreditation register: 3 are final accreditations and 12 are provisional, and 11 are accredited for the compliance mechanism — against 490 obligated entities, an average of roughly 45 entities per verifier. The twelve provisional accreditations begin expiring on 1 March 2027, inside the second compliance year.

And the scheme is now recognised abroad, before it has traded. On 27 August 2026 HM Revenue & Customs published the UK’s list of carbon pricing schemes that qualify for carbon price relief under the UK’s Carbon Border Adjustment Mechanism, and the Indian Carbon Credit Trading Scheme (CCTS) is one of sixteen schemes on it, assessed on information available as of 19 June 2026. Indian coverage reached this on 8 September. It is the sharpest form of this article’s point: a foreign tax authority will discount a UK border charge against a carbon price paid under a scheme in which no credit has yet changed hands. HMRC’s page carries the condition that matters for anyone planning around it — if a listed scheme changes after 19 June 2026 such that it no longer fully meets the criteria, it ceases to qualify, and relief depends on an effective carbon price actually having been paid.

Method note on that register, offered because it is the kind of thing that goes wrong: the workbook has two sheets. The first is a stale copy listing two agencies; the live register is the second sheet, listing fifteen. Reading only the first would produce a confident correction wrong by a factor of seven.

Who is actually covered — the 490, by sector

These have only ever been published as one number, or as the two notification batches. Counted row by row from the schedules of the two gazette notifications themselves:

SectorEntitiesShare
Cement18638.0%
Textile17335.3%
Pulp and paper5310.8%
Chlor-alkali306.1%
Petroleum refinery214.3%
Aluminium (13 primary, 3 secondary)163.3%
Petrochemicals112.2%
Total490

Why you can trust the arithmetic: the schedules were counted twice by independent methods — serial ranges under each sub-sector heading, and unique registration numbers by code family. Every sub-sector range sums to its sector total, and the two batches sum to exactly 282 and 208, the figures the government published. The derivation reproduces two numbers it was never given.

And the thing the coverage has missed. Textile is the second-largest sector in the scheme by company count, and it is almost absent from the reporting, which is nearly all cement and aluminium. Cement and textile together are 73% of the scheme. The typical CCTS-obligated entity is a spinning mill — 60 of the 173 textile entities are spinning units — not a large integrated industrial group with an energy-management function already in place. That is a materially different compliance problem from the one being written about.

Targets are set at sub-sector level against an FY 2023–24 baseline and bind for compliance years 2025–26 and 2026–27. Scope is gate-to-gate, covering Scope 1 and Scope 2 with some Scope 3 for imported and exported intermediary products. The gases covered are CO₂ and perfluorocarbons. Obligations apply retroactively from 1 April 2025, and the reduction requirement is back-loaded — roughly 40% falls in 2025–26 and 60% in 2026–27.

What has not happened

ExpectedSource and date of the expectationPosition at 10 Sep 2026
First CCC trading “by mid-2026”ICAP, 30 Mar 2026No trading reported. Mid-2026 has passed; the expectation is now reported as ~October 2026.
First compliance deadline31 Jul 2026 (reported)Passed. Still no market to settle obligations in.
Iron & steel final notificationDraft G.S.R. 517(E), dated 26 Jun 2026, gazetted 2 Jul 2026, 60-day comment windowWindow closed 31 Aug 2026. Ten days on, no final notification — and none on the government’s own notification register.
Fertiliser targetsExpected “by year-end” 2025Still pending, roughly eight months late.
Registered offset projectsRegistry liveZero. No credits issued.

Each of those rows was checked on 10 September 2026 against the government’s own notification register, its press office, and press coverage. The correct reading is “no announcement found,” not “proved not to exist” — a gazette notification can issue quietly. But five separate expectations passing their dates without visible movement is a pattern rather than an accident of reporting.

There is a sixth item that belongs here only as an observation, and is stated as what a page displayed rather than as proof about the world. On the government’s own Indian Carbon Market portal, checked 10 September 2026: the Statistics page read “Coming Soon”, Registered Projects was empty, and Listed Projects held a single entry named Test1308, whose stakeholder consultation window closed on 10 September 2026.

Iron and steel: the largest block in the scheme, counted

Iron and steel is the biggest single piece of India’s carbon market and it is not in it yet. The draft schedule — G.S.R. 517(E), dated 26 June 2026 and gazetted on 2 July — was counted row by row for this article. It covers 255 units with combined baseline emissions of 358.6 MtCO₂e in 2023–24, against 148.7 million tonnes of baseline equivalent product output.

Draft steel schedule, G.S.R. 517(E)
Obligated entities255
Baseline emissions, 2023–24358.6 MtCO₂e
Baseline output148.7 Mt of equivalent major product
Required cut against baseline, at 2026–27 targets20.0 MtCO₂e — 5.59%
Range of required cuts2.15% to 9.35%, median 5.46%
Compliance year 2025–26 targetsEmpty for all 255 entities
States14 — Chhattisgarh 62, Odisha 61, Karnataka 33, West Bengal 25, Jharkhand 20
StatusDraft. Comment window closed 31 Aug 2026; not notified as of 10 Sep 2026

Four things here are worth more than a table cell.

The 2025–26 column is empty for every one of the 255. The schedule prints two target columns and only the 2026–27 one is populated. Steel’s obligations begin in 2026–27, a full compliance year behind the other seven sectors. A reader glancing at the page will assume both columns bind. They do not.

The count is 255, and the numbering will make you say 256. Registration numbers run INSOE0001 to INSOE0256, but INSOE0020 does not exist — serial 19 is INSOE0019OD and serial 20 is INSOE0021GA. Anyone reading the count off the last registration number gets 256. The serials are the authority, they run 1–255 unbroken, and the Hindi and English printings of the schedule contain identical sets of 255 registration numbers.

The obligation is concentrated. The ten largest plants carry 51% of the sector’s baseline emissions and the largest twenty-five carry 73%. Chhattisgarh and Odisha together hold 123 of the 255 plants — just under half. Whatever steel compliance turns out to look like, it will be decided in two states and by about twenty-five sites.

One caution about what to do with this data. Baseline intensities in the schedule span 0.13 to 8.25 tCO₂e per tonne of equivalent product. That spread is product type, not performance — a coated-products line is not comparable with an integrated steel plant, and a league table sorted on raw intensity would misrepresent named companies. The fair comparison is the cut each entity must make against its own baseline.

Where the “740 entities across nine sectors” figure comes from

Two figures circulate constantly in coverage of India’s carbon market — roughly 740 obligated entities and roughly 16% of national emissions — and they are almost always presented as the current state of the scheme. They are not, and it is now possible to show precisely how the wrong number is produced.

The nine is a scoping list, and BEE says so in its own words. The Bureau of Energy Efficiency’s carbon market page reads:

“The nine sectors – Aluminium, Chlor Alkali, Cement, Fertiliser, Iron & Steel, Pulp & Paper, Petrochemicals, Petroleum refinery, and textile are to be considered for gradual transition and more sectors would be included in future.”

To be considered. It is a forward-looking list of candidates. Seven of the nine now carry notified targets. Iron and steel sits in draft. Fertiliser has no schedule at all.

And the 740 is two numbers from different worlds added together:

Entities
In force — seven notified sectors490
Draft — iron and steel, G.S.R. 517(E)255
Sum745

745, reported as “about 740”. The figure is not invented and it is not far off arithmetically; it is simply in-force plus draft, quoted as in-force. Add a sector list that includes one sector still under consultation and one that has never been scheduled, and you get the scheme as it may exist in 2027 described in the present tense.

This is not a historical complaint. On 3 September 2026 a major Indian business title reported that the CCTS “spans about 740 obligated entities across nine sectors”; a widely-shared industry post the previous day said around 740 entities across nine sectors “now hold legally binding” obligations. The in-force figures on the same day were 490 and seven.

The distinction is not pedantry. If you are a compliance officer at a steel plant, the difference between the nine-sector scheme and the seven-sector one is whether you have a legal obligation this year. You do not. You will, probably in 2026–27, and the target against your plant’s name is already published in a draft you could have commented on until 31 August.

Two corrections to the most-cited source

The most widely cited English-language reference on India’s scheme is ICAP’s ETS map. Checked against the notifying ministry’s own press office, it is wrong on two points that propagate into most secondary coverage.

One — the January date. ICAP states the additional sectors were officially notified on 16 January 2026. The notification itself, G.S.R. 25(E), is dated 13 January 2026 on its face; PIB, publishing for MoEFCC on 22 January 2026, gives the same date. This correction is not one source against another — it is the gazette against a summary of the gazette.

Two — the sector count. ICAP’s headline update names three sectors: refinery, petrochemicals and textiles. PIB names four: petroleum refineries, petrochemicals, textiles and secondary aluminium. Most secondary coverage has dropped the fourth.

Neither correction changes the argument. They are recorded because a reference is only worth citing if it is right about details a reader can check, and because the same two errors appear in a great deal of what is written about this scheme.

The point

The gap between a scheme that is fully built and a scheme that is running is the single most useful thing to know about India’s carbon market in September 2026, and it is the thing the official material is least likely to tell you. Dates in this piece are the dates things were published, not the dates they took effect, because in several cases they have not taken effect.

If trading opens in October, this article describes the last weeks of a phase rather than a permanent condition — and that is fine. The record of what was and was not true on 10 September 2026 does not stop being accurate when the position changes. It is the coverage that asserts the nine-sector scheme is already here which will not age well.

None of this is an argument that the CCTS is failing. Schemes take years to start trading, and building the registry, the portal and the verifier pool before opening a market is the right order to do things in. It is an argument against reading the architecture as the outcome.

Sourcing. Primary for: the per-sector entity counts and the totals (counted from the schedules of the two gazette notifications); the entire iron and steel section — the 255 count, the 358.6 MtCO₂e baseline, the 20.0 Mt implied cut, the state split, the empty 2025–26 column and the INSOE0020 gap (all counted from the schedule of G.S.R. 517(E), a draft, dated 26 Jun 2026 and gazetted 2 Jul 2026); the nine-sector scoping list and its “are to be considered” wording (BEE’s own carbon market page, read 10 Sep 2026); the January notification date (G.S.R. 25(E), 13 Jan 2026, on its face, corroborated by PIB/MoEFCC 22 Jan 2026); the target rules (BEE, Greenhouse Gases Emission Intensity Target Rules 2025, 8 Oct 2025); the trading regulations date and gazette number (CERC’s register of regulations in force); the verifier breakdown (BEE ACVA register, live sheet, re-read 10 Sep 2026: 15 agencies, 3 final and 12 provisional, 11 accredited for the compliance mechanism); and the UK CBAM qualifying-scheme listing (HM Revenue & Customs, Carbon Border Adjustment Mechanism: List of current qualifying carbon pricing schemes, published 27 Aug 2026, read 10 Sep 2026). Secondary for: the reduction ranges and the original “mid-2026” trading expectation (ICAP); the 31 July 2026 compliance deadline and the ~October 2026 trading expectation (press coverage, 2–3 Sep 2026, no government announcement located). The negative findings are dated, and labelled by strength: the iron and steel absence is “not present on the government’s own notification register as of 10 September 2026”, which is a register check; the trading and fertiliser absences are the weaker “no announcement located as of 10 September 2026”.

Everything in the iron and steel section describes a draft under consultation. Entities may be added, removed or have targets changed before it is finalised, and this article says so wherever it uses the numbers.

Corrections. If any statement here is wrong, it will be corrected on this page with the date and the reason, and the original text left visible.

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5 tracks · 97 sourced claims · 43 dated gaps · 34 primary sources monitored · last checked 9 Sep 2026 · 10 currently unreadable, reported as unknown rather than unchanged

Counted from the records on every page load, never typed. A dated gap is a question one of the six slots asks that has no answer yet — recorded with the day the watch began, rather than left blank. A source that cannot be read is reported as unknown rather than assumed unchanged.

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Written and maintained by Richard N. Bright, CEO of Carbon Registry India — a non-profit carbon standard and an NCCF initiative.

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