India — BRSR, the Carbon Credit Trading Scheme, CBAM and EUDR

Updated 2026-08-17reviewed ESGOS15 sources

SEBI's BRSR and BRSR Core assurance glide path, the Carbon Credit Trading Scheme's first compliance years, and EU CBAM and EUDR as they reach Indian exporters.

This is editorial market intelligence compiled from public sources on the dates shown. It is not legal, tax or compliance advice, and it does not change any organisation's verification status on ESGOS.

India requires the top 1000 listed companies by market capitalisation to file a Business Responsibility and Sustainability Report (BRSR), with the BRSR Core assessed or assured on a phased glide path. It requires named industrial entities to meet greenhouse gas emission intensity targets under the Carbon Credit Trading Scheme (CCTS). Two EU regulations reach Indian exporters on top of that: the EU Carbon Border Adjustment Mechanism (CBAM) and the EU Deforestation Regulation (EUDR).

What is in force

BRSR. SEBI’s circular of May 10, 2021 made BRSR filing mandatory for the top 1000 listed companies by market capitalisation from the financial year 2022-2023, replacing the earlier Business Responsibility Report; filing was voluntary for the financial year 2021-22.¹ It is organised around the nine principles of the National Guidelines on Responsible Business Conduct; essential indicators are mandatory, leadership indicators voluntary.¹ The July 12, 2023 circular introduced the BRSR Core — a sub-set of the BRSR with KPIs under 9 ESG attributes — and the updated BRSR format for the top 1000 listed entities from FY 2023-2024.²

The circular of March 28, 2025 sets the current glide path for mandatory assessment or assurance of the BRSR Core: FY 2023-24 top 150, FY 2024-25 top 250, FY 2025-26 top 500 and FY 2026-27 top 1000 listed entities by market capitalisation.³ It also added a leadership indicator under Principle 6 on Green Credits generated or procured by the entity and its top ten value chain partners, from FY 2024-25.³ SEBI’s circular of December 20, 2024 directs listed entities to follow the Industry Standards Forum’s standards on BRSR Core reporting for FY 2024-25 and onwards.⁴

CCTS. The Carbon Credit Trading Scheme, 2023 was notified vide S.O. 2825(E) dated 28th June 2023 under clause (w) of section 14 of the Energy Conservation Act, 2001; under its compliance mechanism the Ministry of Environment, Forest and Climate Change notifies emission intensity targets for obligated entities.⁵ The Greenhouse Gases Emission Intensity Target Rules, 2025 (G.S.R. 739(E), 8th October, 2025) set entity-level targets in tCO2e per equivalent product for the named obligated entities in aluminium, cement, chlor-alkali and pulp and paper. The targets run for the compliance years 2025-26 and 2026-27 against a 2023-24 baseline, and the 2025-26 targets are pro rata for September 2025 to March 2026.⁵ The Amendment Rules (G.S.R. 25(E), 13th January, 2026) inserted a Second Schedule for aluminium (second aluminium), petroleum refinery, petrochemical and textile entities, with 2025-26 targets pro rata for January 2026 to March 2026.⁶

CBAM. Regulation (EU) 2023/956 covers cement, electricity, fertilisers, iron and steel, aluminium and hydrogen; the reporting-only transitional period ran from 1 October 2023 to 31 December 2025.⁷ Applications for authorised CBAM declarant status opened on 31 December 2024, and from 1 January 2026 goods may be imported into the customs territory of the Union only by an authorised CBAM declarant, with the annual declaration, certificate and penalty articles applying from that date. The quarterly certificate-holding requirement in Article 22(2) applies from 1 January 2027.⁸ Regulation (EU) 2025/2083, in force from 20 October 2025, introduced a 50-tonne cumulative net-mass de minimis exemption per importer per calendar year across iron and steel, aluminium, fertilisers and cement (not electricity or hydrogen). It set the declaration and surrender deadline at 30 September of the year following importation — first due 30 September 2027 for 2026 imports.⁹

What is coming

BRSR Core assessment or assurance reaches the top 1000 listed entities in FY 2026-27.³ Value chain ESG disclosures apply to the top 250 listed entities on a voluntary basis from FY 2025-26, and their assessment or assurance is voluntary from FY 2026-27.³ The value chain is defined as the top upstream and downstream partners individually comprising 2% or more of purchases and sales by value, and disclosure may be limited to cover 75% of purchases and sales.³

Under the CCTS, a draft notification (G.S.R. 517(E) dated 26th June, 2026) proposes a Third Schedule of targets for the iron and steel sector, to be taken into consideration after sixty days from publication; it is a draft and not in force.¹⁰ The Bureau of Energy Efficiency names nine sectors for gradual transition from PAT to the CCTS compliance mechanism — aluminium, chlor-alkali, cement, fertiliser, iron and steel, pulp and paper, petrochemicals, petroleum refinery and textile.¹¹

Regulation (EU) 2025/2650 replaced Article 38 of the EUDR so that its core articles apply from 30 December 2026, and from 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024. It also created a downstream operator category and a simplified declaration for micro or small primary operators.¹² The regulation applies to cattle, cocoa, coffee, oil palm, rubber, soya and wood and to the products in its Annex I.¹³

Who it binds

BRSR binds the top 1000 listed entities by market capitalisation, with assessment or assurance tiers of 150, 250, 500 and 1000 in successive financial years.³ CCTS targets bind the individual obligated entities (units) named in the Schedules to the 2025 rules.⁵ CBAM places its obligations — authorisation, the annual declaration and certificate surrender — on the EU importer as authorised CBAM declarant; an Indian producer of Annex I goods is the upstream source of the embedded-emissions data behind that declaration.⁷ The EUDR binds EU operators and traders placing relevant products on the Union market; Indian producers and exporters supply the information those operators need.¹²

Verification requirements

For the BRSR Core, the March 28, 2025 circular states that “assessment” refers to third-party assessment as per standards developed by the Industry Standards Forum in consultation with SEBI. The same circular has the listed entity’s board ensure the assessment or assurance provider has the necessary expertise and no conflict of interest — for instance, no non-audit, non-assessment or non-assurance services such as consulting to the entity or its group.³ The July 12, 2023 circular had originally required reasonable assurance;² the option of assessment replaced it.³

Under the CCTS, every obligated entity, within three months of the conclusion of the compliance cycle, submits a performance assessment document in Form A, duly verified, with a Form B certificate of verification from an accredited carbon verification agency, which shall conduct at least one site visit.¹⁴ Entities register with the ICM Registry, and certificates trade over the power exchanges under CERC procedure.¹⁴ An accredited carbon verification agency shall at minimum meet ISO 14065:2020 and is required to have or obtain ISO 14065 accreditation; provisional accreditation is cancelled if that accreditation is not submitted within one year.¹⁵ Under the 2025 rules an obligated entity shall achieve its target, register on the Indian Carbon Market portal, submit the stipulated documents and surrender banked or purchased certificates equal to any shortfall. The Bureau issues certificates equal to the target minus achieved intensity multiplied by equivalent product output.⁵ On failure to comply, the Central Pollution Control Board shall impose environmental compensation equal to twice the average traded certificate price for that compliance year’s trading cycle, payable within 90 days after a hearing.⁵

What an organisation on ESGOS can do

An Indian organisation can find its listing in the directory and claim it from its profile page, or get listed and submit evidence: a BRSR Core assessment or assurance report, a CCTS Form B verification certificate, or an ISO 14065 accreditation record. Producers of CBAM goods can add a compliance profile recording installation-level embedded-emissions data and its verification. The verifiers directory lists accredited verification bodies drawn from national accreditation registers, by standard; verifiers accredited for CBAM are not yet published by the Commission, so the directory does not hold them. The exposure check indicates whether an organisation’s goods fall within CBAM or EUDR scope.

Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 — Business responsibility and sustainability reporting by listed entities, Securities and Exchange Board of India. ↩ ↩²
Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 — BRSR Core: framework for assurance and ESG disclosures for value chain, Securities and Exchange Board of India. ↩ ↩²
Circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42 — Measures to facilitate ease of doing business with respect to framework for assurance or assessment, ESG disclosures for value chain, and introduction of voluntary disclosure on green credits, Securities and Exchange Board of India. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸
Circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2024/177 — Industry Standards on Reporting of BRSR Core, Securities and Exchange Board of India. ↩
G.S.R. 739(E) — Greenhouse Gases Emission Intensity Target Rules, Ministry of Environment, Forest and Climate Change. ↩ ↩² ↩³ ↩⁴ ↩⁵
G.S.R. 25(E) — Greenhouse Gases Emission Intensity Target (Amendment) Rules, Ministry of Environment, Forest and Climate Change. ↩
Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, Official Journal of the European Union. ↩ ↩²
Regulation (EU) 2023/956 — consolidated text 02023R0956-20251020, EUR-Lex. ↩
Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956, Official Journal of the European Union. ↩
G.S.R. 517(E) — Draft notification, Greenhouse Gases Emission Intensity Target (Amendment) Rules, iron and steel sector, Ministry of Environment, Forest and Climate Change. ↩
Carbon Credit Trading Scheme programme page, Bureau of Energy Efficiency. ↩
Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115, Official Journal of the European Union. ↩ ↩²
Regulation (EU) 2023/1115 on certain commodities and products associated with deforestation and forest degradation, Official Journal of the European Union. ↩
Detailed Procedure for Compliance Mechanism under CCTS, Bureau of Energy Efficiency. ↩ ↩²
Accreditation Procedure and Eligibility Criteria for Accredited Carbon Verification Agency, Bureau of Energy Efficiency. ↩

Regimes referenced

From the ESGOS regimes table — facts as recorded there, not a summary of this article.

SEBI Business Responsibility and Sustainability Reportdisclosurejurisdiction INeffective 2022-04-01Mandatory for the top 1000 listed companies by market capitalisation from FY 2022-23, voluntary for FY 2021-22. BRSR Core assurance follows a separate glide path set by later circulars.threshold — scope: top 1000 listedSource
Carbon Credit Trading Scheme (CCTS) compliance cyclecarbon compliancejurisdiction INeffective 2025-04-01Targets are set in tCO2e per equivalent output or product (Rule 2(1)(c)) against a 2023-24 baseline, for compliance years 2025-26 and 2026-27, as the Schedule's column headers state. The Rules commence on publication in the Official Gazette (Rule 1(2)), which was 8 October 2025; the date shown here is the start of the first compliance year. Four further sectors — petroleum refineries, petrochemicals, textiles and secondary aluminium, 208 more obligated entities, bringing the total to 490 — were added by a notification issued on 13 January 2026, announced by MoEFCC at https://www.pib.gov.in/PressReleasePage.aspx?PRID=2217239 and not contained in the Rules cited here. A draft notification of 26 June 2026 proposes a Third Schedule for iron and steel and had not been finalised as at 20 August 2026.threshold — obligated: entities named individually, each with a registration number, in the Schedule to the Greenhouse Gases Emission Intensity Target Rules, 2025 — Table 1 aluminium, Table 2 cement (plants and grinding units carry separate code series), Table 3 chlor-alkali, Table 4 pulp and paperSource
EU CBAM definitive phase (exports to the EU)tradejurisdiction EUeffective 2026-01-01The first CBAM declaration and certificate surrender are due by 30 September 2027 for goods imported in 2026.threshold — certificate_price: average of EU ETS auction closing prices (Art. 21(1)); for 2026, the quarterly average for the quarter of importation (Art. 21(1a)) · de_minimis: 50 t cumulative net mass per importer per year (Art. 2a), excluding electricity and hydrogen · verification: actual embedded emissions verified by an accredited verifier (Art. 8(1))Source
EU Deforestation Regulation (exports to the EU)tradejurisdiction EUeffective 2026-12-30Regulation (EU) 2025/2650 sets 30 December 2026 for operators and traders generally (Art. 38(2)). By Art. 38(3) the later date of 30 June 2027 applies only to operators that are natural persons or micro or small undertakings within the meaning of Art. 3(1) or Art. 3(2), first subparagraph, of Directive 2013/34/EU and that were established as such by 31 December 2024, and it does not apply at all to products covered by the Annex to Regulation (EU) No 995/2010. Separately, Art. 4a gives "micro or small primary operators" as defined in Art. 2(15a) a one-time simplified declaration in place of the full due diligence statement; that is a different population from the one Art. 38(3) defers. Deforestation-free means produced on land not subject to deforestation after 31 December 2020 (Art. 2(13)). The Regulation sets no volume or value de minimis.Source

Organisations on ESGOS

Directory listings matching this article's category and market, in the directory's own order. A tier badge means the organisation has claimed its own listing and had submitted evidence verified. Most listings here carry verifications from public registers and no badge — read the record, not the badge.

Manufacturing in India

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Agritech in India

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CO2 management in India

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ESG & carbon strategy in India