CCTS in BRSR: what obligated companies disclose

8 October 2026 5 min read Grow Billion Trees team

SEBI's BRSR format has no question that names CCTS or Carbon Credit Certificates. Obligated companies use existing Principle 6 items: the PAT question, Scope 1 and 2 emissions, and GHG-reduction projects. BRSR Core's Scope 1 formula subtracts only carbon capture, so certificates bought and trees planted do not lower reported emissions.

Why this question matters now

Final CCTS targets now apply to 490 obligated entities, according to PIB. Many of them are listed companies that file a Business Responsibility and Sustainability Report (BRSR).

BRSR Core must be assessed or assured for the top 500 listed entities in 2025-26 and the top 1,000 in 2026-27. That glide path is in SEBI's circular of 28 March 2025.

So CCTS numbers and BRSR numbers will both be checked by third parties. They need to tell the same story.

Where CCTS shows up in Principle 6

We read the BRSR format attached to SEBI's circular of 12 July 2023, with the March 2025 changes. No item mentions CCTS, so the mapping below is our suggestion, not a SEBI rule.

BRSR item	What it asks	What a CCTS entity can put there
P6 Essential Q2	Sites that are designated consumers under PAT, and whether PAT targets were met	CCTS status of each unit, since PAT units are moving into CCTS
P6 Essential Q7	Scope 1 and Scope 2 emissions and intensity	Gross emissions, without netting certificates
P6 Essential Q8	Projects related to reducing GHG emissions	Efficiency, fuel-switch and process projects that lower intensity
P6 Leadership Q2	Scope 3 emissions and intensity	Value-chain emissions, kept separate from CCTS scope
P6 Leadership Q4	Initiatives to reduce emissions, effluent or waste	Outcomes of decarbonisation initiatives
P6 Leadership Q8	Green Credits generated or procured	Green Credit Programme credits only, not CCCs

ICAP notes that CCTS builds on PAT and that PAT entities are being transitioned using the same thresholds. That makes Q2 the natural home for a CCTS status note.

Why certificates do not reduce reported emissions

The BRSR Core format builds Scope 1 from fuel use times emission factor, minus carbon capture, plus process and fugitive emissions. There is no line for credits bought or trees planted.

So a unit that buys CCCs to cover a shortfall still reports its full Scope 1 and 2. A unit that earns CCCs reports the lower emissions that earned them, not the certificates.

The same logic applies to plantation. Trees never reduce a plant's GHG emission intensity under CCTS, and they do not reduce BRSR Scope 1 either.

Two intensities, two boundaries

CCTS targets are tonnes of CO2e per tonne of product, on a gate-to-gate basis per unit. ICAP says they cover Scope 1 and 2, plus some Scope 3 for imported and exported intermediate products.

BRSR Core asks for intensity per rupee of revenue adjusted for purchasing power parity. It also allows intensity per unit of physical output, at entity level.

The numbers will differ, and that is fine. Add a short reconciliation: which units are under CCTS, their verified emissions, and how they roll into the BRSR total.

How to describe certificates earned or bought

BRSR has no table for CCCs, so a short narrative note works best. Keep it factual and separate from the emissions table.

Units covered: list each obligated unit, its sector and its notified target years.
Performance: state whether each unit met, beat or missed its target for the year.
Certificates: say whether CCCs were issued, bought or surrendered, once those events occur.
Verification: name the type of check, such as verification by a BEE-accredited agency.
Offsets bought: report voluntary offset CCCs or other credits separately from Scope 1 and 2.

Avoid wording that suggests credits or trees cut the plant's emissions. That protects both the CCTS filing and the BRSR assurance.

Where plantation belongs

Plantation is real work with its own disclosures. It belongs alongside CCTS data, never inside it.

Green credits: SEBI added Leadership Q8 on credits generated or procured, applicable from FY 2024-25.
Sensitive areas: Essential Q11 asks about operations in or near wetlands, forests and coastal zones.
Biodiversity: Leadership Q3 covers impact and remediation in those areas.
Initiatives: green belts and restoration can be described under Leadership Q4.

Our guide to BRSR Principle 6 and plantation goes into these items. For the difference between instruments, read green credits vs carbon credits vs CSR vs BRSR.

How Grow Billion Trees helps

We run green belts, mine reclamation, mangrove restoration and CSR plantation with geo-tagged records on GreenTrack. We provide BRSR-ready plantation reports for the right Principle 6 items, kept apart from CCTS data. See ESG and BRSR reporting, our Carbon Market (CCTS) page, or plan a programme.

Further reading: CCTS sectors and timeline 2023-2027 · How the CCTS offset mechanism works