What Happens to Obligated Entities Now?

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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.
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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.
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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.
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.
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.
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.
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.
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Confirm with your internal team or your ACVA whether Form A was actually submitted, not only prepared.
Ask your ACVA for a status update directly rather than waiting for BEE to reach out.
A late but verified filing is reported to be a materially better position than a deemed baseline submission.
Whatever your filing status, BEE's review and any check verification will still examine your underlying monitoring and data records.
Budget time and attention for the verification and review stages that follow it, since they determine the actual outcome.
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.
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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.
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The first compliance date for the FY 2025-26 compliance year has been reported as around 31 July 2026 for the Form A submission.
Submitted filings move into ACVA verification and then BEE's review stages, which determine the eventual certificate or surrender outcome.
Form A is the GHG emissions performance report that must be submitted by the compliance date, verified by an accredited agency.
An entity whose verified performance falls short of its target must surrender Carbon Credit Certificates equivalent to the shortfall.
Surrender follows BEE's review of verified performance, once the shortfall between target and achieved intensity is confirmed.
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