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Licensing & Regulatory

Environmental clearances, COβ‚‚ storage permitting, MoEFCC and PNGRB engagement, CBAM compliance documentation, carbon registry registration, and navigation of India's emerging CCUS regulatory framework β€” removing regulatory risk from the critical path.

The Service

Regulatory Clarity in an Evolving Framework β€” India's CCUS Permission Landscape

India's CCUS regulatory framework is being built in real time. NCM helps shape it β€” and navigate it.

India does not yet have a comprehensive CCUS-specific regulatory framework. Environmental clearances for capture facilities exist under existing EIA notification processes, but COβ‚‚ geological storage regulation β€” specifying who can grant storage licences, what monitoring is required, and how long-term liability is managed β€” is still under development. This regulatory uncertainty is a significant barrier to project development: DFIs will not commit capital, and boards will not approve FIDs, without a clear understanding of the regulatory pathway.

NCM's Licensing & Regulatory team combines India-specific regulatory knowledge β€” drawn from advisers with direct experience at MoEFCC, PNGRB, and the Ministry of Coal β€” with international regulatory best practice from Australia's Offshore Petroleum & Greenhouse Gas Storage Act, Norway's COβ‚‚ storage regulations, and the UK's Energy Act framework. We use this combination to map the regulatory pathway for each project β€” identifying what permissions are needed, which authority grants them, what the evidence base must demonstrate, and what the realistic timeline is.

We are also active participants in the development of India's CCUS regulatory framework itself β€” providing technical input to Ministry consultations, participating in NITI Aayog working groups, and contributing to the design of carbon storage licensing frameworks that are both environmentally rigorous and commercially workable. This position inside the regulatory process gives NCM clients early visibility of emerging requirements and the ability to shape frameworks in ways that facilitate, rather than obstruct, project development.

Environmental Impact Assessment
MoEFCC EIA notification compliance, public hearing strategy, expert appraisal committee engagement, and Stage 1 & 2 environment clearance for capture facility construction and operation.
COβ‚‚ Storage Permitting
Geological survey coordination, DGH engagement for offshore storage, ONGC and GSPC formation data access, and injection well permitting under India's emerging storage licensing framework.
CBAM Compliance Documentation
Embedded carbon calculation methodology, third-party verification coordination, EU CBAM declarant registration, and annual compliance reporting for Indian exporters of steel, cement, chemicals, and aluminium.
Carbon Registry & Market Access
BEE Carbon Market registration, Verra VCS and Gold Standard verification, Article 6 bilateral agreement structuring with AU, EU, and Japan, and India Carbon Market (ICM) compliance pathway design.
International Regulatory Models

Best-Practice Regulatory Frameworks β€” Applied to India

Australia's Offshore Petroleum & Greenhouse Gas Storage Act (OPGGS Act) is the most comprehensive COβ‚‚ storage regulatory framework in the world β€” covering exploration permits, injection licences, monitoring obligations, site closure, and post-closure long-term liability transfer to the state. NCM's Australian regulatory advisers use this framework as the primary reference model for the storage licensing provisions of India's emerging CCUS regulatory framework.

Norway's COβ‚‚ Storage Directive β€” implemented through the Petroleum Act β€” provides the European model for offshore COβ‚‚ storage regulation, with a 25-year track record at the Sleipner formation demonstrating that rigorous regulatory oversight and successful commercial operation are fully compatible. The Norwegian model has directly informed EU member state storage regulation, and NCM uses it to benchmark the adequacy of India's emerging onshore storage framework.

The UK's energy regulation for CCUS β€” developed through the Energy Act 2023 and the North Sea Transition Authority β€” provides the most recent example of a nation building a comprehensive CCUS licensing regime from scratch in a relatively short timeframe. The UK experience demonstrates that political will, industry engagement, and good regulatory design can compress the timeline for building a workable framework from decades to years.

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Australia β€” OPGGS Act
World's most comprehensive COβ‚‚ storage framework β€” exploration permits, injection licences, monitoring, closure, post-closure liability transfer
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Norway β€” COβ‚‚ Storage Directive
25-year operational track record at Sleipner demonstrating rigorous regulation and successful commercial CCUS are fully compatible
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UK β€” Energy Act 2023
Most recent example of a nation building comprehensive CCUS licensing from scratch in compressed timeframe β€” directly applicable to India's regulatory development challenge
India's Regulatory Bodies

Navigating India's Multi-Ministry CCUS Approval Landscape

MoEFCC
Environmental Impact Assessment, Stage 1 & 2 environment clearance, public hearing coordination, and expert appraisal committee engagement for capture facility construction.
PNGRB
Petroleum and Natural Gas Regulatory Board β€” COβ‚‚ pipeline right-of-way, tariff regulation for shared COβ‚‚ transport infrastructure, and third-party access provisions.
DGH
Directorate General of Hydrocarbons β€” COβ‚‚ geological storage permissions, formation data access, injection well approval, and offshore COβ‚‚ storage licensing under the petroleum concession framework.
BEE / Carbon Market
Bureau of Energy Efficiency β€” India Carbon Market registration, PAT scheme integration, carbon credit issuance, and Perform Achieve & Trade compliance for energy-intensive industries.
NITI Aayog
Policy coordination for national CCUS framework, inter-ministerial working group engagement, and India's NDC and Long-Term Low Emissions Development Strategy (LT-LEDS) alignment.
State Pollution Control
State PCB consents to establish and operate capture facilities, solvent waste management authorisation, groundwater monitoring requirements, and state-level land acquisition coordination.
Deliverables

Regulatory Deliverables β€” From Pathway to Permission

  • Regulatory Pathway Document β€” complete map of all required clearances, responsible authorities, evidence requirements, and realistic timelines
  • EIA Terms of Reference β€” scoping document for MoEFCC expert appraisal committee submission
  • Storage Permit Application β€” geological evidence base, injection design, monitoring plan, and long-term liability framework
  • CBAM Compliance Package β€” embedded carbon methodology, verification protocol, and EU declarant registration
  • Carbon Registry Registration β€” BEE ICM or Verra VCS project documentation and verification coordination
  • Regulatory Risk Register β€” identified risks, probability/impact assessment, and mitigation strategy for each clearance

Ready to Work With India's Leading CCUS Practice?

Whether you are a government body seeking policy advice, an industrial company facing CBAM exposure, or an investor seeking CCUS project opportunities β€” our team is ready to engage.