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India's Carbon Market is Ready. The Window To Build is Now.

November 3, 2026
5 mins

India’s CBAM-exposed exports to the EU in steel, aluminium, cement, and fertilisers amount to $8.2 billion annually. The Carbon Border Adjustment Mechanism (CBAM) is a climate policy tool created by the European Union (EU) to put a fair price on the carbon emitted during the production of certain imported goods.

 As of January 1, 2026, every tonne of those goods arriving in Europe carries a carbon cost indexed to the EU’s carbon price. If India has no credible domestic carbon price, that cost flows to European treasuries. If it does, it stays here. The Carbon Credit Trading Scheme (“CCTS”), notified in June 2023, is India’s answer.

Not many in the startup ecosystem paid attention. The announcement was dense with industrial vocabulary such as chlor-alkali baselines, GHG emission intensity trajectories, gate-to-gate Scope 1 and 2 reporting, and it read like a compliance burden meant for cement plants and petroleum refineries.

What India did was institutionalise carbon as a financial commodity, create a mandatory demand pool of 740 industrial buyers, and open a voluntary market to any entity in the country that can demonstrate a verified emission reduction. The infrastructure to serve all of that barely exists.
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Why India Chose a Different Design

The EU Emissions Trading System is a cap-and-trade system: a fixed ceiling on total emissions, with companies trading allowances within it. When the 2008 financial crisis hit, output fell faster than expected and unused allowances swelled to over 2.1 billion by 2013, more than a full year of covered emissions. Prices collapsed to €2.75 per tonne. The market sent no meaningful signal for close to a decade. EU carbon prices averaged €65 per tonne in 2024, reached after fifteen years of iteration.

Apply a hard cap to an economy growing at 6-7% annually and you are asking industry to choose between growth and compliance. 

India chose differently. Under the CCTS, each covered facility receives a target expressed as CO₂ per unit of output: tonnes of carbon per tonne of steel, per tonne of cement, not a fixed emissions budget. Beat it and you earn Carbon Credit Certificates ("CCC"). Miss it and you buy them or pay environmental compensation at twice the average CCC price. China launched its Emissions Trading System (“ETS”) in 2021 on the same intensity-based design, covering only the power sector, at a price around $11 per tonne in 2025.
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India Built on Thirteen Years of Groundwork

India did not arrive at this market without context. It is the second-highest Clean Development Mechanism ("CDM") project country globally. The Perform, Achieve and Trade scheme ran for 13 years before CCTS, embedding compliance culture into over 1,000 industrial entities across 13 sectors. The administrative infrastructure to run a carbon market already existed when CCTS was notified.

India went further than its peers on three dimensions:

  1. Broader sector coverage from day one: CCTS covers nine sectors from launch: aluminium, cement, chlor-alkali, pulp and paper, petroleum refining, petrochemicals, textiles, iron and steel, fertilisers; where China covered only power for its first four years. The EU ETS launched in 2005 with power and heavy industry but took nearly two decades to reach comparable industrial breadth.
  1. A price collar built in from the start: CCTS launches with a price collar built in from day one. The Central Electricity Regulatory Commission (“CERC”) sets a floor and ceiling price within which Carbon Credit Certificates trade on India's power exchanges. The EU ETS had to engineer the Market Stability Reserve retrospectively in 2019, fourteen years after launch, because price collapse had stripped the market of its investment signal. India has built price stability into the architecture from day one.
  1. A two-track market open to the entire economy from launch: The EU ETS and China's ETS both launched as compliance-only systems where participation was mandatory for large emitters and closed to everyone else. CCTS launches simultaneously with a compliance mechanism for 740 obligated entities and an open voluntary offset mechanism through which any entity in India can participate.
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The External Pressure That Compressed the Timeline

India’s CBAM-exposed exports amount to $8.2 billion annually, representing 27% of India’s global exports in these categories. The consequences are already concrete: unwrought aluminium exports to the EU fell 41.7% year on year in the period surrounding CBAM’s entry into enforcement. Carbon priced at home counts against what the EU importer owes at the border. Without CCTS, that revenue flows to European treasuries.

India signed a Joint Crediting Mechanism MOU with Japan on August 7, 2025, making India Japan’s 31st bilateral carbon partner. Negotiations with Singapore, Sweden, and South Korea are active. India has published 13 eligible activity types under Article 6.2 of the Paris Agreement. If India’s Article 6 linkages mature, it stops being just a domestic compliance market and becomes an origination hub for internationally transferred mitigation outcomes.

CBAM is the defensive case for CCTS. Article 6 is the strategic one.
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CCTS Is the Layer That Ties India's Industrial Missions Together

The National Green Hydrogen Mission targets 5 MMT of production annually by 2030 with a ₹19,744 crore outlay. Green hydrogen production is one of eight approved methodologies under the CCTS voluntary offset mechanism. CCTS creates the domestic demand signal that makes green hydrogen viable before it can compete on cost alone.

India introduced the world’s first Green Steel Taxonomy in December 2024. As of March 2026, 89 steel units have earned certification covering 12.34 million tonnes of production. CCTS intensity targets are what give those certifications financial consequence, not just reputational value.

Budget 2026-27 allocated ₹20,000 crore over five years for Carbon Capture, Utilisation and Storage. Where production efficiency alone cannot reach zero, CCTS creates the financial pressure that makes CCUS investment rational, and the voluntary offset mechanism turns those reductions into a revenue stream once verified.

These missions look unrelated on paper. CCTS is the price signal that makes each of them work.
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Where the Opportunity Actually Sits

  1. The Compliance Stack

The Indian Carbon Market Portal (www.indiancarbonmarket.gov.in), launched at Prakriti 2026 in March, handles entity registration, GHG monitoring, verification tracking, CCC issuance, and trading, managed by the Grid Controller of India. It connects to the Indian Energy Exchange (“IEX”) and Power Exchange India Limited (“PXIL”), where CCCs will trade within the CERC-set price collar. Credit issuance is expected soon.

The mandate is live. The operational infrastructure is not. Every obligated entity needs audit-grade GHG data covering Scope 1, Scope 2, and partial Scope 3, independently verified by an accredited body. REC Power Development and Consultancy Limited (“RECPDCL”) issued an Expression of Interest in May 2026 to empanel verification agencies. The CCTS-grade institutional capacity for Monitoring, Reporting and Verification (“MRV”), compliance tracking, and credit portfolio management at industrial scale does not yet exist domestically.

  1. The Voluntary Market

The voluntary offset mechanism is open to any entity in India that can reduce, remove, or avoid emissions. The buyer base is built in: 740 obligated industrial entities on the other side of the same exchange, many of whom will need credits to meet their targets.

The eight approved methodologies include renewable energy, green hydrogen, industrial energy efficiency, landfill methane recovery, and mangrove afforestation. India has over 140 million farming households, is the world’s second largest rice producer where Alternate Wetting and Drying paddy cultivation is an approved methodology and has over 71 million hectares of forest base. The voluntary origination potential inside India’s existing economic base is larger than almost anywhere else on the planet.

The gap is not project supply. It is the infrastructure layer between project activity and tradeable credit:

  • Aggregation platforms that bundle micro-reductions into institutional-grade credit pools, handling registration, MRV workflows, and verification for participants who generate the activity but cannot run the compliance cycle themselves. Varaha has demonstrated this model in regenerative agriculture. The methodological surface is now far broader.
  • Carbon-backed project finance that advances capital against future CCC issuance, the same model that unlocked distributed solar in India for developers with strong fundamentals but no upfront capital. A verified credit pipeline is a real receivable. The financing structures to monetise it do not yet exist.
  • Digital MRV tools that automate data collection and output BEE-compliant verification reports, without which voluntary projects in agriculture, forestry, and waste cannot reach institutional-grade credibility.

None of this exists at any meaningful scale. 
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What the Market Still Needs to Get Right

A market this new will have problems worth naming.

  • Price signal too weak: India’s projected floor sits around $8 to $10 per tonne, well below the €50 per tonne at which the EU ETS began driving real industrial investment. If the first price collar is set conservatively, the market functions as a compliance exercise rather than an innovation driver. The upcoming price collar announcement will say more about India’s ambition than any policy document has.
  • Credit surplus: The price collar sets a floor but does not prevent surplus from accumulating. If targets are lenient or output grows faster than efficiency improves, the price pins to the floor, technically stable but signalling nothing. IEEFA recommended a supply-side stability mechanism in November 2025. How the government responds as the market matures will be telling.
  • Voluntary market credibility: Nine of the 47 largest projects producing questioned credits globally in 2024 were Indian, legacy projects under international standards, not CCTS. The underlying risk is the same: rigour in methodology design and rigour in project-level verification are two different things. There is no retrofitting credibility after the first round of problems.


Where This Goes Next

Forty-one emissions trading systems now cover 63% of world GDP and generated a record $80 billion in revenues in 2025. Carbon is no longer a compliance cost. It is becoming an asset class. India just built the infrastructure to participate on its own terms.

For founders, the timing is precise. The 740 obligated entities need compliance infrastructure they do not have. The 140 million farming households have carbon to sell and no mechanism to sell it. Project developers have verified pipelines with no financing against them. Every one of those gaps is a business. The demand is not being created it is being mandated.

No other emerging market has attempted this at scale. The compliance mechanism is live. The voluntary market is open. The Article 6 architecture is being linked internationally. The infrastructure layer that makes all of it work does not yet exist. That is not a problem. That is the opportunity!
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