An Indian project developer with a viable emission reduction activity faces a decision before choosing a methodology, and getting it wrong is expensive to reverse: sell domestically into India's compliance scheme, sell internationally into CORSIA or the voluntary market, or attempt both.
The three pathways have different requirements, different buyers and different risks. This article is about choosing between them.
For the general position of CORSIA in India — DGCA's role, what Indian carriers face, the obligation trajectory — see CORSIA in India. This piece is the developer's pathway decision.
The Three Pathways
| Domestic (CCTS) | International compliance (CORSIA) | Voluntary market | |
|---|---|---|---|
| Buyer | Obligated Indian entities | Aircraft operators | Corporates, by choice |
| Governing framework | Energy Conservation Act | ICAO Emissions Unit Criteria | Crediting standard rules |
| Host-State authorisation | Not required | Required | Increasingly wanted |
| Corresponding adjustment | Not applicable | Required | Premium where present |
| Price | Domestic market | Premium, scarce | Very wide range |
| Main risk | Scheme design still settling | Authorisation may never come | Quality scrutiny |
The row that decides most cases is the third. Domestic sale requires no corresponding adjustment; international sale cannot happen without one.
Why the Authorisation Question Comes First
Under Article 6 of the Paris Agreement, a host State authorising credits for international use must add those tonnes back into its own national accounting, forgoing them against its Nationally Determined Contribution.
India has been building the Carbon Credit Trading Scheme as a domestic compliance market, and has signalled in various contexts a preference for retaining mitigation outcomes domestically. The interaction between that scheme, Article 6 authorisation and CORSIA eligibility is still being worked through.
For a developer this produces a specific and uncomfortable position: you cannot know with certainty today whether an international pathway will be open to your project when it starts issuing.
That uncertainty is the thing to plan around, not to resolve. Three consequences follow.
Consequence One: Establish the Position Before the Methodology
Methodology choice is difficult to reverse. A project designed under a domestic protocol does not automatically satisfy an ICAO-approved programme's requirements, and migrating between standards mid-project is costly and sometimes impossible.
So the sequence has to be: establish the realistic authorisation position, then choose the pathway, then choose the methodology. Not the other way round.
Practically, that means engaging early with the relevant authority, asking about your specific project type rather than about policy in general, and asking what has actually been authorised rather than what is possible in principle. Public statements describe intent; issued authorisations describe practice.
Consequence Two: Design for Optionality Where You Can
The strongest position for most Indian developers is not to bet on one pathway.
Design to the stricter standard. A project built to satisfy an ICAO-approved programme's requirements will generally also satisfy domestic and voluntary requirements. The reverse is not true.
Keep the documentation an international buyer would demand, even while selling domestically. Verification reports, monitoring evidence and safeguards documentation retain value across pathways.
Do not build a financial model that only works with international placement, in a jurisdiction where authorisation is genuinely uncertain. That is a concentrated bet on a government decision.
The additional cost of designing for optionality at the outset is modest. The cost of retrofitting is not, and in some cases the option is simply gone.
Consequence Three: Sequence Revenue Realistically
A domestic pathway generally reaches revenue sooner, because it removes the authorisation step — the least predictable element in an international timeline.
An international pathway offers a higher price where it completes, because corresponding-adjusted supply is scarce and CORSIA demand steps up from 2027.
For a developer with financing to service, the practical question is not which is worth more per credit but which produces cash when you need it. A higher price two years later may be worth less than a lower price next year.
Which Project Types Suit Which Pathway
| Project type | Domestic fit | International fit | Note |
|---|---|---|---|
| Industrial energy efficiency | Strong | Moderate | Overlaps CCTS coverage directly |
| Waste methane, biogas | Good | Strong | Clean additionality, no permanence issue |
| Wastewater treatment | Good | Strong | Same reasoning |
| Cookstoves | Moderate | Moderate | Usage-rate scrutiny applies either way |
| Afforestation | Moderate | Moderate | Permanence and tenure questions |
| Grid solar and wind | Weak | Weak | Additionality hard where least-cost |
| Soil carbon | Weak | Weak | Measurement immaturity |
Two patterns worth noting. Industrial efficiency overlaps the domestic scheme's own coverage, which is an argument for the domestic pathway but also raises questions about whether the reduction is already captured by an obligation. And waste methane suits the international pathway best, because its additionality argument survives scrutiny that other categories struggle with.
What This Means for Timelines
Working backwards from second-phase CORSIA demand from 2027:
A new project needs eighteen months to three years from concept to first issuance. Host-State authorisation, where required, is the least predictable element within that span and can extend it considerably.
A developer intending to serve that demand should be resolving the authorisation question now, not when demand becomes visible. Supply that is ready when demand arrives will be contracted; supply that starts the process then will arrive late.
For the domestic pathway the timing pressure is different, driven by the CCTS compliance cycle rather than by ICAO's phases.
Getting Advice on This Specific Decision
This is a bounded question with a clear output, and it is worth buying as a discrete piece of work rather than as part of a larger engagement.
What a useful assessment produces: a written position on the realistic authorisation prospects for your project type, an assessment of methodology options under each pathway, a timeline comparison with revenue implications, and a recommendation with the reasoning stated so it can be revisited if the policy position moves.
What it should not produce: a recommendation to proceed regardless. A genuine assessment must be capable of concluding that the international pathway is not realistically available, because for a number of project types and jurisdictions that is the correct answer today.
DSTechnoverse runs this assessment for Indian developers from Indore, Madhya Pradesh. See CORSIA eligible projects in India and becoming a CORSIA supplier.
Financing Implications of the Pathway Choice
The decision is not only regulatory. It changes what the project looks like to a lender or investor.
Revenue certainty differs sharply. A domestic pathway has a defined buyer base under a compliance scheme. An international pathway has a higher price and a sovereign step that neither the developer nor the financier controls. Lenders price that difference.
Timing to first revenue matters more than headline price for a project servicing debt. An international pathway that pays more in year four may be worse than a domestic one paying less in year two, depending on the financing structure.
Offtake agreements are what make either bankable. A signed forward agreement with a credible counterparty converts an uncertain revenue line into something a lender can assess. This is a strong argument for pursuing offtake discussions earlier than feels natural.
Optionality has financing value too. A project designed to satisfy the stricter international requirements, while retaining a domestic fallback, presents a better risk profile than one committed to a single route — even before considering the price difference.
Questions to Settle Before Committing
Six questions, in order. Each is answerable in weeks, and answering them in this sequence prevents the expensive reversals.
- Does a designated national authority and an authorisation process exist for our project type?
- Has anything comparable actually been authorised, and on what timeline?
- What conditions attach — fees, revenue sharing, benefit distribution?
- Which methodologies are available under each pathway, and are any under review?
- What does the revenue timeline look like under each, against our financing?
- Can we design to satisfy the stricter requirement while retaining the fallback?
A developer who can answer all six has made a decision. One who cannot has a plan resting on an assumption, and in this market the assumption most often wrong is that authorisation will follow because the project deserves it.
Frequently Asked Questions
Can an Indian project sell into CORSIA? Only if India authorises the transfer and applies a corresponding adjustment. That is a governmental decision, not a market transaction.
Should I default to the domestic pathway? Not automatically. It removes the authorisation risk and generally reaches revenue sooner, but forgoes the international premium. The right answer depends on your project type, financing and timeline.
Can I switch pathways later? Sometimes, at cost. Design for optionality at the outset rather than assuming you can migrate.
What if the authorisation position is unclear? Treat it as a material risk to be priced, not as an implicit yes. Design to the stricter standard and keep a fallback.
Which project types are best placed internationally? Waste methane, biogas and wastewater treatment, because their additionality arguments survive scrutiny. Grid renewables are difficult.
How long does the decision take to make properly? Weeks, not months. It is a bounded assessment and it is far cheaper than a methodology chosen against the wrong pathway.
Who decides authorisation in India? The designated national authority under the Article 6 framework. Engage directly and ask about your specific project type.
