Two carbon schemes now bear on Indian companies, and they are frequently confused because both produce something called a carbon credit. They cover different entities, sit under different ministries, use different instruments and serve different buyers.
Working out which applies to you takes about ten minutes and prevents a great deal of misdirected effort.
The Two Schemes Side by Side
| CORSIA | CCTS | |
|---|---|---|
| Established by | ICAO, international | Energy Conservation Act, domestic |
| Administered by | National authority (DGCA in India) | Bureau of Energy Efficiency, Ministry of Power |
| Covers | International aviation | Notified energy-intensive sectors, plus offset projects |
| Obligation basis | Emissions growth above a baseline | Greenhouse gas emission intensity targets |
| Instrument | Eligible emissions units | Carbon Credit Certificates |
| Buyers | Aircraft operators with offsetting duties | Obligated entities short of target |
| Trading venue | Bilateral, brokers, programmes | Notified power exchanges |
| Geographic reach | International route pairs | Domestic |
Which One Applies to You
If you are an airline or aircraft operator: CORSIA, for international flights. Your domestic operations sit outside CORSIA. See CORSIA compliance for Indian airlines.
If you are an energy-intensive manufacturer: CCTS, if your sector and entity have been notified as obligated. Aluminium, cement, iron and steel, pulp and paper, chlor-alkali, fertiliser, petrochemicals, refineries and textiles have featured in the notified sectors. See the Indian carbon market and CCTS explained.
If you are a project developer: potentially both, and the choice matters. The domestic offset mechanism under CCTS issues Carbon Credit Certificates for the domestic market. CORSIA supply requires an ICAO-approved programme, an eligible vintage and a corresponding adjustment. The documentation, the buyer and the price differ substantially.
If you are neither: you may still be a voluntary buyer in either market, but you have no compliance obligation under either scheme.
Why a Developer Cannot Simply Do Both
The same emission reduction cannot be counted twice. A tonne credited under the domestic offset mechanism and used by an obligated Indian entity is a tonne that has been used domestically. The same tonne cannot also be exported with a corresponding adjustment for an airline's CORSIA obligation.
That forces a genuine choice at project design stage:
| Route | Requires | Buyer | Trade-off |
|---|---|---|---|
| Domestic CCTS offset | Approved domestic methodology, registration | Obligated entities, voluntary buyers | No export policy exposure; price set by domestic scheme dynamics |
| CORSIA supply | ICAO-approved programme, vintage, corresponding adjustment | Airlines with obligations | Scarcity premium; authorisation is a government decision |
| Voluntary market | Recognised standard | Corporates with commitments | Broadest access; price driven by quality and story |
Decide before development, not after issuance. The methodology, the registry, the documentation and the buyer differ, and retrofitting a project from one route to another is expensive and sometimes impossible — particularly where vintages have aged outside an eligibility window.
For a Company With Both Exposures
Some groups have both — an airline subsidiary with CORSIA obligations and a manufacturing arm within CCTS scope. Practical consequences:
Separate compliance functions, shared discipline. The obligations are legally distinct and reported to different authorities on different timetables. The underlying capability — emissions data, controls, verification readiness — is the same discipline, and there is real value in a shared approach to data governance.
Do not cross-use instruments. Carbon Credit Certificates under CCTS and CORSIA eligible emissions units are different instruments serving different obligations. One does not discharge the other.
One group-level tracker. Two schemes, two authorities, two calendars. A single register of obligations, owners and deadlines prevents the classic failure of two functions each assuming the other was tracking a change.
Shared market intelligence. Both functions need a view on carbon pricing, and a single internal source of that view is more useful than two.
What to Do Next
| If you are | First action |
|---|---|
| An aircraft operator | Confirm your MRV applicability and monitoring plan status with the DGCA requirement |
| A notified obligated entity | Confirm your target, baseline and verification arrangements with BEE guidance |
| A project developer | Decide the target market before design, and test the corresponding adjustment position if CORSIA |
| A voluntary buyer | Decide what claim you need to make, then buy the instrument that supports it |
| Unsure | Run the applicability tests for both schemes and document the conclusion |
The authoritative sources are the DGCA for CORSIA in India, the Bureau of Energy Efficiency for CCTS, and ICAO for the CORSIA framework itself. Treat summaries — including this one — as orientation rather than as the operative rule.
A Worked Applicability Example
A diversified Indian group operates a regional airline, a cement plant and a distillery that captures methane from its effluent treatment. Three entities, three different answers.
| Entity | Scheme | Obligation | First action |
|---|---|---|---|
| Regional airline | CORSIA | MRV on international sectors above the threshold; offsetting subject to the route-pair test | Confirm applicability and monitoring plan status with the DGCA requirement |
| Cement plant | CCTS | Emission intensity target if notified as an obligated entity | Confirm notification status and target; build the GHG inventory |
| Distillery methane project | Neither, by default | No compliance obligation; a potential credit supplier | Decide target market before development — domestic offset, CORSIA or voluntary |
Three observations from that table.
The airline's domestic sectors are outside CORSIA entirely, however large they are. A regional carrier with mostly domestic flying may have a very small CORSIA footprint and still carry a full MRV obligation on the international portion.
The cement plant's obligation is intensity-based, not absolute. Growing output does not itself breach the target; failing to improve efficiency does.
The distillery project has a genuine choice, and it is a one-way door. The same tonnes cannot serve the domestic offset mechanism and a CORSIA export. Making that decision at design stage — informed by the corresponding adjustment position — is worth more than any downstream optimisation.
The group-level lesson: three entities, three authorities, three calendars, one shared discipline. The emissions data governance, verification readiness and record retention practices are the same craft in each case, and a group that builds them once and applies them three times is materially ahead of one treating each obligation as unrelated.
How the Two Schemes May Converge
Both schemes are evolving, and an Indian company with exposure to either should watch three areas rather than assuming today's boundaries are permanent.
Instrument recognition. Whether domestic instruments could ever be recognised for international purposes, or vice versa, is a policy question rather than a technical one. The accounting obstacle — that the same tonne cannot serve two obligations — is fundamental, but the routes by which a project chooses its market may change.
Export policy. India's position on authorising credits for international transfer shapes how much domestic supply reaches CORSIA at all. That position responds to India's own NDC trajectory, which means it can tighten as much as loosen.
Sectoral coverage. CCTS coverage expands as sectors are notified. A company outside scope today may be inside it in a future compliance cycle, and the lead time for building an emissions inventory is longer than the notice period is likely to be.
The practical response is the same in each case: build the underlying capability rather than the scheme-specific compliance. An organisation with a defensible greenhouse gas inventory, documented data flows, calibrated instruments and verification-ready records can meet whichever obligation arrives. One that has built a narrow process around a single scheme's current requirements has to start again when the requirements move.
That is also the honest answer to "which scheme should we prepare for?" — prepare the data, and the scheme becomes a reporting format rather than a project.
Frequently Asked Questions
What is the difference between CORSIA and CCTS? CORSIA is ICAO's international aviation offsetting scheme administered in India by the DGCA. CCTS is India's domestic carbon market under the Energy Conservation Act, administered by the Bureau of Energy Efficiency.
Which applies to an Indian airline? CORSIA, for international flights. Domestic aviation sits outside CORSIA.
Which applies to a manufacturer? CCTS, if the sector and entity are notified as obligated.
Can a project sell into both? Not the same tonnes. A reduction used domestically cannot also be exported with a corresponding adjustment.
Are Carbon Credit Certificates usable for CORSIA? No. They are a domestic instrument. CORSIA requires eligible emissions units meeting its own criteria.
Which route pays better for a developer? It depends on the corresponding adjustment position, domestic scheme dynamics and your project type. Assess both before designing the project.
Do both schemes require verification? Yes, both rely on independent third-party verification, though under different frameworks and to different authorities.
What if my group has both exposures? Keep the compliance functions separate, share the data governance discipline, and maintain one group-level obligations register.
Where do I find the current rules? The DGCA for CORSIA in India, BEE for CCTS, and ICAO for the CORSIA framework.
Planning your CORSIA position? DSTechnoverse advises Indian operators and project developers on CORSIA compliance strategy — offsetting requirement forecasting, unit procurement due diligence, SAF and efficiency trade-offs, and readiness assessment before the compliance year begins. We are based in Indore, Madhya Pradesh and work with clients across India. See our CORSIA carbon credit services, our carbon credit portal at carboncredit.dstechnoverse.com, or talk to our team.
This article is general information, not legal, financial or regulatory advice. CORSIA rules, participating-state lists and eligibility criteria change — verify the current position with ICAO and the DGCA before acting.
