CCTS compliance calendar: build backwards from the verified filing

First establish which pathway applies

The Indian Carbon Market separates a compliance mechanism for obligated entities from an offset mechanism for eligible projects outside that obligation. This note concerns the compliance mechanism. Start with the entity’s notified status, applicable target and compliance year; an offset project should not adopt this filing calendar by analogy.

Source: BEE: Indian Carbon Market ↗

The filing window in the procedure

BEE’s Detailed Procedure, version 1.0, requires the verified GHG emissions report and calculation pro forma within four months of the compliance year’s end. Section 6 also places the performance assessment in Form A, supported by the accredited verifier’s Form B and specified records, within that window. Submission is to BEE and the State Designated Agency.

For a compliance year ending 31 March, four months points to 31 July. This is a calendar illustration, not confirmation of a particular entity’s live deadline. Check current notifications, portal instructions and any applicable extensions before filing.

Source: BEE Detailed Procedure, sections 5(22) and 6(1), printed pages 25–27 (PDF) ↗

During the year: keep the record usable

Our suggested preparation rhythm starts well before year-end. Give each data stream a named owner and agree a routine review date. Keep explanations with unusual entries while the operating team still remembers the event. A plant shutdown, an equipment change or a changed meter reading is harder to reconstruct months later.

Use a shared issue register with three fields: the question, the person resolving it and the evidence of closure. This is more useful than accumulating several spreadsheets with slightly different numbers. Retain the earlier version when a figure changes so the reviewer can follow what happened.

Before year-end: plan the review backwards

Ask the appropriately accredited verification agency about its scope and availability early. Our recommendation is to work backwards from the confirmed submission date, allowing time for its review, site work where needed, questions, corrections and the entity’s own sign-off. Do not treat the last day of the filing window as the day to begin verification.

Prepare a document index so the team knows where each input, calculation and supporting record sits. Agree who will answer technical questions and who can approve a correction. Where an external laboratory or another supplier holds information, request it before the internal review is due.

After submission: keep ownership of follow-up

Save the acknowledgement and an exact copy of the submitted package. Record subsequent questions and the version of each response. Internally, assign responsibility for checking the registry and official communications so that submission does not become the end of the workflow.

The procedure treats certificate issuance and surrender as separate steps. It does not justify promising a universal October cash receipt. Build a project plan around confirmed regulatory events, rather than budgeting income from a presumed trading date.

Source: BEE Detailed Procedure, section 8, printed page 36 (PDF) ↗

What BitCon can help with

Our advisory work can help organise the baseline, documentation and monitoring-readiness tasks. Independent verification belongs to the appropriately accredited agency. Agree these responsibilities separately, and use the current official procedure and entity-specific notices as the authority for compliance dates.