India has no single law telling every company to publish a carbon footprint. It has three pressure points that already push much of the listed and industrial economy into measuring greenhouse gases: a securities regulator that mandates sustainability reporting for the largest listed entities, a domestic carbon market with emission intensity targets notified plant by plant, and European customers asking their Indian suppliers for emissions data.

Carbon accounting in India therefore starts with exposure rather than method: which regime applies, in which financial year, at what level of verification. This article sets out the framework in force as of 3 September 2026, with the circular and gazette reference behind each obligation.

The BRSR: who reports and what it covers

The Business Responsibility and Sustainability Report, or BRSR, is the format introduced by the Securities and Exchange Board of India, SEBI, through circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated 10 May 2021, alongside the amendment of regulation 34(2)(f) of the SEBI Listing Obligations and Disclosure Requirements Regulations, 2015, notified on 5 May 2021 as SEBI/LAD-NRO/GN/2021/22.

  • Who is covered. Filing became mandatory from financial year 2022-2023 for the top 1 000 listed companies by market capitalisation, replacing the Business Responsibility Report. It was voluntary for 2021-22 and does not reach unlisted companies.
  • What is reported. Performance against the nine principles of the National Guidelines on Responsible Business Conduct, split between essential indicators, which are mandatory, and leadership indicators, which are voluntary.
  • How it connects. Entities already reporting under GRI, SASB, TCFD or Integrated Reporting may cross reference those disclosures to the BRSR.

BRSR Core: assessment or assurance and the glide path

BRSR Core is a subset of the BRSR, introduced by SEBI circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023, with the LODR amendment notified as SEBI/LAD-NRO/GN/2023/131 on 14 June 2023. It gathers key performance indicators under nine ESG attributes, adds indicators chosen for the Indian context such as job creation in small towns, and expresses intensity ratios on revenue adjusted for purchasing power parity.

The planning point is the glide path, by market capitalisation band:

  • financial year 2023-24: top 150 listed entities;
  • financial year 2024-25: top 250 listed entities;
  • financial year 2025-26: top 500 listed entities;
  • financial year 2026-27: top 1 000 listed entities.

The 2023 circular required reasonable assurance. That changed on 28 March 2025 with circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, after a board decision of 18 December 2024 and gazette amendment CG-MH-E-28032025-262027. Entities now undertake assessment or assurance, where assessment means a third party assessment under standards developed by the Industry Standards Forum in consultation with SEBI. The glide path was unchanged. At the time of writing, on 3 September 2026, no later SEBI circular amending this regime had been identified.

Two governance rules survive from 2023: the board must satisfy itself that the provider has the necessary expertise, and there must be no conflict of interest, which rules out a provider also selling consulting services to the group.

Value chain disclosures after March 2025

The 2023 text had made value chain ESG disclosures applicable to the top 250 listed entities on a comply or explain basis from 2024-25, with limited assurance from 2025-26. The March 2025 circular deferred and softened it:

  • value chain partners are now those individually accounting for 2 % or more of purchases or sales by value, with an option to limit disclosure to 75 % of each;
  • the disclosures apply to the top 250 listed entities on a voluntary basis from 2025-26;
  • their assessment or assurance applies on a voluntary basis from 2026-27;
  • in the first year, previous year figures are voluntary, and an entity that discloses must state the percentage of sales and purchases covered.

The same circular added a leadership indicator on green credits generated or procured, from financial year 2024-25.

The signal holds even though the requirement is voluntary: a listed customer will still ask, because its own reporting depends on your numbers. Our guide on tier 2 and tier 3 supplier emissions describes how those requests cascade.

The Carbon Credit Trading Scheme

India's domestic carbon market rests on the Energy Conservation (Amendment) Act, 2022, Act No. 19 of 2022, which received presidential assent on 19 December 2022. It inserted clause (w) in section 14 of the Energy Conservation Act, 2001, letting the Central Government specify a carbon credit trading scheme, and section 14AA on issuing carbon credit certificates.

The Carbon Credit Trading Scheme, 2023 was notified as S.O. 2825(E) dated 28 June 2023 under clause (w) of section 14 of the Energy Conservation Act, 2001. The Bureau of Energy Efficiency administers the market and issues the certificates. The emission intensity targets are notified by the Ministry of Environment, Forest and Climate Change, on a recommendation of the Ministry of Power based on the advice of the Bureau of Energy Efficiency and of the National Steering Committee for the Indian carbon market.

The compliance mechanism runs on emission intensity targets, in tonnes of CO2 equivalent per unit of equivalent product, notified plant by plant:

  • G.S.R. 739(E) of 8 October 2025, the Greenhouse Gases Emission Intensity Target Rules, 2025, covering aluminium, cement, chlor-alkali, and pulp and paper;
  • G.S.R. 25(E) of 13 January 2026, adding secondary aluminium, petroleum refinery, petrochemicals and textiles;
  • G.S.R. 517(E) of 26 June 2026, a draft notification for iron and steel, open to objections for sixty days from publication. At the time of writing, on 3 September 2026, no final notification for that sector had been identified on the Bureau of Energy Efficiency site, so the sector is still at draft stage.

Both notified sets cover the same two compliance years, 2025-26 and 2026-27. An entity beating its target receives certificates equal to the gap between target and achieved intensity multiplied by equivalent product output. An entity missing it buys and surrenders the equivalent number.

The sanction sits in the rules: the Central Pollution Control Board issues an environmental compensation order equal to twice the average price at which carbon credit certificates traded during that compliance year's trading cycle, the average being set by the Bureau of Energy Efficiency, payable within 90 days and only after a reasonable opportunity of being heard.

PAT, the scheme the carbon market was built on

Perform, Achieve and Trade, or PAT, is the energy efficiency mechanism run by the Bureau of Energy Efficiency under the Energy Conservation Act, 2001. It sets energy consumption reduction targets for designated consumers in energy intensive industries and issues tradable energy savings certificates, or ESCerts, to those who overachieve. The 2022 amendment kept them and let any other person buy an energy saving or a carbon credit certificate voluntarily.

For an industrial site the point is continuity: a designated consumer already runs metering, normalisation and third party verification. The carbon market reuses that discipline and changes the unit of account from energy to greenhouse gases.

India's national commitment

India's updated Nationally Determined Contribution was approved by the Union Cabinet on 3 August 2022. Per the Government of India press release, it commits the country to cut the emissions intensity of its GDP by 45 % by 2030 from 2005 levels, and to reach about 50 % cumulative electric power installed capacity from non fossil sources by 2030, on the path to net zero by 2070. Whether a further Indian NDC has been submitted since that update could not be checked on an accessible official source: data unavailable at the time of writing.

The word intensity matters. The national target is per unit of GDP and the carbon market mirrors that logic per tonne of product, so a company tracking only absolute emissions cannot show compliance without recomputing against production volumes.

The Indian supplier of an EU customer: CSRD

For many exporters the first real carbon request comes not from SEBI but from a European customer. Directive (EU) 2026/470 of 24 February 2026 narrowed the European sustainability reporting regime, with three consequences.

  • Your European customers. Reporting now targets undertakings exceeding 450 million euros in net turnover and an average of more than 1 000 employees over the financial year, consolidated where applicable. Member States must transpose by 19 March 2027, the new scope applying to financial years starting on or after 1 January 2027. Fewer customers are in scope, and those that remain have the longest supply chains.
  • Your group, if it operates in the Union. The third country regime still applies, with turnover generated in the Union raised to 450 million euros in each of the last two consecutive financial years, and 200 million euros for the EU subsidiary or branch.
  • Your right to limit the request. The directive creates the protected undertaking: a value chain company not exceeding an average of 1 000 employees over the previous financial year, at its balance sheet date. It has the right to refuse information going beyond what the voluntary standards referred to in article 29ca specify, a reporting undertaking may not contractually require more from it, and any contractual clause to the contrary is not binding.

CBAM: steel, aluminium, cement, fertilisers

The EU Carbon Border Adjustment Mechanism, CBAM, has applied in its definitive regime since 1 January 2026. According to the European Commission it covers imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.

The obligations sit with the EU importer, not the Indian producer, so the effect here is commercial. To keep selling, an Indian exporter of steel, aluminium, cement or fertilisers must supply the actual embedded emissions of its goods, detailed enough for the importer's CBAM declaration. Without verified data the importer falls back on default values, generally less favourable than a well run plant's real figures. Documenting embedded emissions therefore lowers a European customer's compliance cost, an argument that can be quantified in a negotiation. Our article on CBAM in 2026 covers the timeline and the certificate mechanism.

Where to start, in practice

  • Establish the legal perimeter. Are you in the top 1 000 listed entities, and in which BRSR Core band? Is a plant of yours named in a schedule to the emission intensity target rules? Do you export CBAM goods into the Union?
  • Fix the organisational boundary before calculating. Indian groups often run many legal entities under one brand, and consolidation rules must be settled first, otherwise the same tonne is counted twice. See our guide on carbon accounting for multi entity groups.
  • Build the emission factor layer. Scope 2 depends on the Indian grid mix, and several industrial processes have no equivalent in European databases, so expect company specific and India specific factors with documented sources. Our explainer on what an emission factor is shows why the version of a factor matters.
  • Produce intensity, not just totals, in tonnes of CO2 equivalent per unit of equivalent product: that is the unit used by the compliance mechanism and by BRSR Core.
  • Keep the evidence. Assessment, assurance and market verification all come down to whether a third party can retrace a number to an invoice, a meter reading or a supplier declaration.

How Kabaun fits, and what it does not cover

Kabaun is a carbon management platform built on the GHG Protocol. For an Indian group the relevant capabilities are the engine covering scopes 1, 2 and 3 with the fifteen standardised scope 3 categories, custom emission factors validated by an administrator and fully traced, multi entity consolidation, uncertainty analysis, a tamper evident audit trail, documentary evidence attached to each data point, and automated supplier data requests.

Two limits are worth stating up front. Kabaun ships regulatory outputs for the frameworks in its scope, including CSRD and ESRS E1, the French BEGES, the EU Taxonomy, ISO 14064-1 and ISO 14067, but no ready made BRSR or BRSR Core template: those KPIs have to be mapped from the calculated inventory. Its regulatory watch module covers France, the European Union and a defined set of international frameworks, and India is not on that list.

If your priority is a defensible GHG Protocol inventory that a third party can audit, the fit is direct. A one click BRSR filing is not.

Talk to our team about carbon accounting for your Indian operations: [kabaun.com/en/contact](https://www.kabaun.com/en/contact)

FAQ

What is the difference between BRSR and BRSR Core?

The BRSR is the full format covering the nine principles of the National Guidelines on Responsible Business Conduct. BRSR Core is a subset of indicators under nine ESG attributes that must undergo third party assessment or assurance, from the top 150 entities in 2023-24 to the top 1 000 in 2026-27.

Is BRSR Core assurance still mandatory in 2026?

Verification remains mandatory, but since SEBI's circular of 28 March 2025 an entity may choose between assurance and assessment, the latter being a third party assessment under standards developed by the Industry Standards Forum in consultation with SEBI. The glide path was not modified.

Do Indian suppliers have to answer their listed customers' ESG questionnaires?

There is no direct legal obligation on the supplier. Value chain ESG disclosures apply to the top 250 listed entities on a voluntary basis from 2025-26, covering partners individually representing 2 % or more of purchases or sales. In practice the customer asks anyway.

What happens if a plant misses its target under the Carbon Credit Trading Scheme?

It buys and surrenders carbon credit certificates equal to the shortfall. Failing that, the Central Pollution Control Board imposes environmental compensation equal to twice the average certificate price over that compliance year's trading cycle, payable within 90 days.

Does CBAM apply directly to an Indian exporter?

No. CBAM obligations fall on the EU importer or its indirect customs representative. The effect on an Indian producer of steel, aluminium, cement or fertilisers is commercial: without verified embedded emissions data, the importer uses default values, usually less favourable than the plant's real figures.

Official sources

  • SEBI, circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 of 10 May 2021 on Business Responsibility and Sustainability Reporting, primary source, securities regulator: https://www.sebi.gov.in/legal/circulars/may-2021/business-responsibility-and-sustainability-reporting-by-listed-entities_50096.html
  • SEBI, circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 of 12 July 2023 on BRSR Core, primary source: https://www.sebi.gov.in/legal/circulars/jul-2023/brsr-core-framework-for-assurance-and-esg-disclosures-for-value-chain_73854.html
  • SEBI, circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42 of 28 March 2025 on assessment or assurance and value chain disclosures, primary source: https://www.sebi.gov.in/legal/circulars/mar-2025/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_93102.html
  • Energy Conservation (Amendment) Act, 2022, Act No. 19 of 2022, gazette text hosted by the Bureau of Energy Efficiency, Ministry of Power: https://beeindia.gov.in/WriteReadData/L45218/1772711141.pdf
  • Ministry of Environment, Forest and Climate Change, Greenhouse Gases Emission Intensity Target Rules, 2025, G.S.R. 739(E) of 8 October 2025, gazette notification hosted by the Bureau of Energy Efficiency: https://beeindia.gov.in/WriteReadData/RTF1984/RTF-PDF-f0db112734284168_1776057153.pdf
  • Ministry of Environment, Forest and Climate Change, Greenhouse Gases Emission Intensity Target (Amendment) Rules, G.S.R. 25(E) of 13 January 2026: https://beeindia.gov.in/WriteReadData/RTF1984/RTF-PDF-de57eb4cfcc5ab0c_1776057184.pdf
  • Ministry of Environment, Forest and Climate Change, draft amendment rules for the iron and steel sector, G.S.R. 517(E) of 26 June 2026: https://beeindia.gov.in/WriteReadData/RTF1984/RTF-PDF-bbce4f833a613eae_1783081829.pdf
  • Press Information Bureau, Government of India, Cabinet approves India's updated Nationally Determined Contribution, release ID 1847812, 3 August 2022: https://pib.gov.in/PressReleasePage.aspx?PRID=1847812
  • European Commission, Taxation and Customs Union, Carbon Border Adjustment Mechanism, institutional source on the definitive regime and covered sectors: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en
  • Directive (EU) 2026/470 of 24 February 2026, European Union official journal reference: http://data.europa.eu/eli/dir/2026/470/oj