CCUS project viability in India depends critically on policy — not just on technology and geology. The commercial case for CCUS investment rests on three policy-dependent revenue streams: carbon credit revenue (requiring a functioning domestic carbon market with CCUS-eligible credit types); CBAM compliance value (requiring EU regulations that impose costs on unabated industrial exports); and government support mechanisms (requiring sector-specific incentive frameworks analogous to the UK's Carbon Capture Contract or Australia's Safeguard Mechanism). All three are in various stages of development in India.
This tracker provides NCM's assessment of the current status, likely timeline, and commercial implications of each relevant policy instrument. NCM does not merely report what governments have announced — we assess the likelihood of implementation on stated timelines based on NCM's direct engagement with Ministry officials, DFI project teams, and regulatory drafting processes. Where NCM assesses that a stated timeline is optimistic or that a proposed instrument needs significant modification before it will be commercially effective, we say so.
The tracker is organised into six thematic sections: India Carbon Market (ICM); International Frameworks (Article 6, CBAM); CCUS-Specific Regulation (storage licensing, capture standards); Sector-Specific Policy (PAT scheme, industrial decarbonisation mandates); Finance & Investment Enablers (DFI programmes, green bond frameworks); and State-Level Initiatives (Gujarat, Maharashtra, Andhra Pradesh, Odisha, Rajasthan CCUS programmes).
Policy instruments actively tracked by NCM's regulatory advisory team
Next major India Carbon Market rule update — expected notification of CCUS credit methodology
EU CBAM full implementation year — when Indian exporters face full carbon cost liability
State CCUS policy initiatives currently in active development tracked by NCM
India's Carbon Credit Trading Scheme (CCTS), established under the Energy Conservation (Amendment) Act 2022, is the foundation of India's domestic carbon pricing framework. NCM tracks all ICM instruments relevant to CCUS project development and credit generation.
| Status | Instrument | Authority | Sectors | NCM Last Review | NCM Assessment |
|---|---|---|---|---|---|
| Active | Energy Conservation (Amendment) Act 2022 | BEE / MoP | All covered industries | Feb 2025 | Foundational legislation enacted. Carbon Credit Trading Scheme framework operational. Credit issuance and trading rules under BEE notification process. |
| Active | Carbon Credit Trading Scheme (CCTS) — Phase 1 | BEE / MoP | Large energy consumers (PAT scheme entities) | Feb 2025 | Phase 1 covers PAT-scheme obligated entities. CCUS-generated credits not yet explicitly eligible. NCM advocating for CCUS credit methodology notification in Q2 2025. |
| Proposed | CCUS Credit Methodology — ICM | BEE / MoEFCC | All CCUS projects | Feb 2025 | Draft methodology under preparation. NCM has submitted detailed technical input to BEE on measurement, verification, and reporting (MVR) standards. Expected notification Q2–Q3 2025. |
| Draft | Negative Emission Credit Standard | BEE / MoEFCC | BECCS, DAC, basalt mineralisation | Jan 2025 | Concept paper circulated by MoEFCC. Biogenic CO₂ fraction accounting methodology not yet finalised. NCM input submitted. Timeline: 2025–2026. |
| Consultation | Green Urea Certification Standard | Department of Fertilizers | Urea, ammonia, fertilisers | Jan 2025 | Stakeholder consultation underway. Lifecycle boundary definition being finalised. NCM has provided technical comment. Expected notification mid-2025. |
| Proposed | Green Hydrogen Certification — ICM Integration | MoNRE / BEE | Hydrogen production, SMR+CCS | Feb 2025 | India Hydrogen Mission certification framework under development. Blue hydrogen (SMR+CCS) eligibility being determined. NCM advocating for CertifHy-equivalent standard. |
India's CCUS commercial landscape is shaped significantly by international policy — particularly the EU's Carbon Border Adjustment Mechanism and India's bilateral Article 6 agreements with Japan, Australia, and Singapore. NCM tracks these frameworks and their implications for Indian industry.
India currently has no dedicated CO₂ geological storage legislation. NCM tracks the development of the regulatory framework across all relevant ministries and regulators — and provides the policy advocacy that is required to close the regulatory gap on the timeline India's first CCUS projects need.
| Status | Instrument | Authority | Scope | Timeline | NCM Assessment |
|---|---|---|---|---|---|
| In Development | Dedicated CO₂ Geological Storage Bill (Onshore) | MoPNG / DGH | Onshore saline aquifer and depleted reservoir storage | Feb 2025 | No standalone legislation yet. NCM has submitted a draft Onshore CO₂ Storage Bill modelled on Australia's OPGGS Act to DGH for consideration. Expected consultation 2025, legislation 2026–2027. |
| In Development | Offshore CO₂ Storage Licensing — TCZMA Amendment | MoPNG / DGH | Offshore EEZ CO₂ storage | Jan 2025 | DGH scoping study for offshore storage regulation underway. NCM's draft Offshore Storage Licensing Schedule (modelled on OPGGS Act) submitted. Timeline: 2026–2027 for operational framework. |
| Interim Pathway | CCUS Storage via Existing EC Framework | MoEFCC / SPCB | Near-term first projects — interim permitting | Feb 2025 | NCM's proposed interim pathway: use existing Environmental Clearance framework with CCUS-specific conditions to enable first-mover projects before standalone legislation. Discussion paper with MoEFCC. |
| Draft | CO₂ Pipeline Safety Standards | PNGRB / BIS | CO₂ transport pipelines | Jan 2025 | No specific CO₂ pipeline standards in India. NCM has mapped international standards (ISO 27913, ASME B31.4 CO₂ supplement, DNV ST-F101) for adoption or adaptation. PNGRB engagement underway. |
| Consultation | CO₂ Storage Atlas — GSI Programme | GSI / MoES | National CO₂ storage characterisation | Feb 2025 | NCM engaged with GSI on national CO₂ storage atlas programme. Phase 1 (desktop characterisation) design underway. Target: first CO₂ storage atlas publication 2026. |
| Proposed | Basalt Mineralisation Storage Standard | MoEFCC / GSI | Deccan Traps basalt CO₂ storage | Jan 2025 | No existing standard for basalt mineralisation CO₂ storage. NCM developing India-specific standard based on CarbFix methodology. Target: consultation draft 2025. |
Several Indian states have moved ahead of the national government in developing CCUS-friendly policy and investment environments. Gujarat leads — the state government has formally identified CCUS as a priority decarbonisation pathway in its Industrial Policy 2025 and is in active discussions with GNFC, GSPC, and ONGC on specific CCUS project development. Gujarat's existing industrial cluster infrastructure (Hazira-Dahej-Vadodara), Cambay basin storage geology, and port access for CO₂-derived product export make it India's most commercially advanced CCUS state.
Maharashtra has identified CCUS as relevant to its Net Zero Maharashtra commitment — particularly for the cement sector and the Deccan Traps basalt mineralisation opportunity in the state. The Maharashtra Industrial Development Corporation (MIDC) has engaged with NCM on a preliminary assessment of Deccan Traps storage characterisation and cement sector CCUS cluster development. Andhra Pradesh's focus on the KG offshore basin and the state's cement and steel sector make it the third-priority state engagement for NCM, alongside Jharkhand and Odisha for the steel sector.
NCM's 2025–2027 policy timeline assessment: the India Carbon Market CCUS credit methodology (2025) and the interim storage permitting pathway via Environmental Clearance (2025–2026) are the two most commercially critical near-term milestones. Projects that are designed and documented today to align with these frameworks will be positioned for FID in 2026–2027 — ahead of the wave of CCUS project development that full CBAM implementation in 2026 will trigger. NCM's advisory services are specifically designed to position clients for this FID window.
Australia's Offshore Petroleum and Greenhouse Gas Storage (OPGGS) Act is the world's most comprehensive offshore CO₂ storage legislation — covering exploration permits, holding leases, injection licences, and post-closure long-term stewardship. NCM has submitted a draft adaptation of the OPGGS framework for India's DGH consideration, covering both onshore and offshore CO₂ storage licensing under Indian constitutional and environmental law constraints.
Norway's CO₂ Storage Directive (implementing EU Directive 2009/31/EC) and the UK's Energy Act 2023 together represent the most current European regulatory models. The UK's Energy Act 2023 is particularly relevant for India because it includes a Carbon Capture, Usage and Storage licensing regime with specific provisions for CO₂ transport networks, storage permitting, and long-term liability transfer to the Crown — elements that India's regulatory framework will need to replicate for offshore CO₂ storage liability management.
The US EPA's Underground Injection Control Class VI well programme — which regulates CO₂ geological storage under the Safe Drinking Water Act — provides an alternative regulatory model for India's onshore storage permitting, particularly for the interim permitting pathway through existing environmental legislation. NCM has reviewed all three international models against India's constitutional framework and identified the OPGGS Act as the most appropriate primary reference, with specific elements of the UK Energy Act and US UIC Class VI incorporated for specific regulatory scenarios.
Whether you are a government body seeking policy advice, an industrial company facing CBAM exposure, or an investor seeking CCUS project opportunities — our team is ready to engage.