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All IndustriesSeptember 20264-5 min

The 31 July CCTS Deadline Has Passed

What Happens to Obligated Entities Now?

The 31 July CCTS Deadline Has Passed

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4 min

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6

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01

Article Section

Introduction

Part 01

For many obligated entities, a reported filing date has now passed, and the question shifts from whether they were ready to what happens to them next. Sustainability managers, auditors and consultants are all asking the same question from their leadership teams.

This is the first time India's carbon market has gone through this date, so there is no earlier cycle to check the process against. Every step that follows is being watched closely, since it sets the template for future compliance years.

This guide explains what the first CCTS compliance date marked, what happens next for entities that filed, and what is reported to happen to entities that did not.

02

Article Section

What the First Compliance Date Marked?

Part 02

The date in question is the reported deadline for submitting Form A, the GHG emissions performance report, to BEE and the State Designated Agency, backed by ACVA verification, for the FY 2025-26 compliance year.

It is not the final step in the process. It is the submission point that triggers verification and review, not the point at which Carbon Credit Certificates are issued.

The date matters because it sets the starting position for the rest of the cycle. A late or incomplete filing changes what happens next for that entity, even before verification begins, since the review process treats an unverified filing differently from a verified one from the outset.

03

Article Section

What Happens After the Date?

Part 03

For entities that filed on time

A submitted Form A enters ACVA verification, followed by BEE's review stages. The entity's position from here depends on what that review finds, not on the fact of having filed.

For entities where verification is still in progress

ACVA verification is reported to typically take several weeks, so a filing made close to the date may still be under review for some time afterward.

For entities that missed the date

One secondary source reports that BEE deems an entity without a verified filing to have submitted at its baseline GEI, a position that can be worse than its actual performance would show.

What determines the final outcome?

Verified performance against target decides certificate issuance or surrender, not the filing date by itself. An entity that files late but is still verified sits in a different position than one that never files.

What is not yet public?

Certificate trading had not started as of the most recent dated sources available. Issuance and surrender determinations are reported to follow the completion of review, not the passing of the filing date.

04

Article Section

What Obligated Entities Should Do Now?

Part 04

Check your own filing status

Confirm with your internal team or your ACVA whether Form A was actually submitted, not only prepared.

If filed, track verification progress

Ask your ACVA for a status update directly rather than waiting for BEE to reach out.

If not filed, get a verified position urgently

A late but verified filing is reported to be a materially better position than a deemed baseline submission.

Keep documentation current regardless

Whatever your filing status, BEE's review and any check verification will still examine your underlying monitoring and data records.

Do not treat the date as the finish line

Budget time and attention for the verification and review stages that follow it, since they determine the actual outcome.

Loop in your leadership team early

If your filing or verification status is unclear, flag it to leadership now rather than after BEE's review concludes, since the response options narrow the later this is raised.

05

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Conclusion

Part 05

The date was a submission point, not an outcome. What happens to any entity now depends on whether it filed, and on what verification and BEE's review find.

Confirm your entity's actual filing and verification status this week, rather than assuming the date passing was itself the compliance event.

06

Article Section

Frequently Asked Questions

Part 06

What was the CCTS deadline in 2026?

The first compliance date for the FY 2025-26 compliance year has been reported as around 31 July 2026 for the Form A submission.

What happens after the CCTS deadline?

Submitted filings move into ACVA verification and then BEE's review stages, which determine the eventual certificate or surrender outcome.

Is the deadline called Form A?

Form A is the GHG emissions performance report that must be submitted by the compliance date, verified by an accredited agency.

What if an entity misses its target?

An entity whose verified performance falls short of its target must surrender Carbon Credit Certificates equivalent to the shortfall.

When must CCCs be surrendered?

Surrender follows BEE's review of verified performance, once the shortfall between target and achieved intensity is confirmed.

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