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The obligations beyond the annual report

Carbon markets, waste rules and banking directions each have their own arithmetic and deadlines. ESGTrack works them out from the same approved figures as your BRSR — so a correction in one place is a correction everywhere.

EU CBAM

Exporters of cement, iron and steel, aluminium, fertilisers and hydrogen to the EU

The EU's Carbon Border Adjustment Mechanism has applied in its definitive form since 1 January 2026: EU importers declare the embedded emissions of covered goods and, from February 2027, buy certificates for them. Importers bringing in 50 tonnes or less of covered goods a year are exempt (electricity and hydrogen aside). Importers ask their suppliers for actual emissions; otherwise default values apply.

Sources: European Commission, CBAM pages; Regulation (EU) 2025/2083 (simplification). Checked October 2026.

In ESGTrack

  • Embedded emissions per good from your own inventory, precursors included
  • Certificate costs to 2034, actual emissions against the default values
  • A verifier pack, and a file for each EU importer

India's Carbon Credit Trading Scheme

Obligated entities in sectors with notified emission intensity targets

Under the Carbon Credit Trading Scheme, 2023, the Greenhouse Gases Emission Intensity Target Rules, 2025 set targets for aluminium, cement, chlor-alkali and pulp and paper, and an amendment of January 2026 added secondary aluminium, petroleum refineries, petrochemicals and textiles — 490 entities in seven sectors. Entities that beat their target earn carbon credit certificates; those that miss it surrender certificates. The Bureau of Energy Efficiency administers the scheme; FY 2025-26 is the first compliance year.

Sources: Ministry of Power, S.O. 2825(E) of 28 June 2023; MoEFCC, G.S.R. 739(E) of 8 October 2025 and G.S.R. 25(E) of 13 January 2026. Checked October 2026.

In ESGTrack

  • Your emission intensity against the notified target, unit by unit
  • Certificates you will earn or must surrender, and the compensation exposure
  • The report to BEE and a certificate ledger

Carbon credit register

Companies that buy or retire carbon credits

Credits used against a target or a claim need a clear record: which project, which vintage, which serial numbers, retired when and for what. Double counting — the same tonne claimed twice — is the risk to rule out.

In ESGTrack

  • Projects, lots and retirements, each with its certificate
  • A transparent quality score for each lot
  • Overlapping serial numbers flagged as possible double counting

EPR under India's waste rules

Producers, importers and brand owners

Extended producer responsibility applies under separate rules for plastic packaging (the Plastic Waste Management Rules, last amended in March 2026), e-waste (the E-Waste (Management) Rules, 2022), batteries (the Battery Waste Management Rules, 2022), and waste tyres and used oil (under the Hazardous and Other Wastes Rules, amended in 2022 and 2023). Each sets targets met with certificates from registered recyclers.

Sources: the rules named, as notified by MoEFCC. Checked October 2026.

In ESGTrack

  • Obligations for each stream, worked out with their arithmetic
  • Certificates from registered recyclers matched to obligations
  • Annual returns, and the figures BRSR Principle 2 asks for

CSR under section 135

Companies with net worth of ₹500 crore, turnover of ₹1,000 crore or net profit of ₹5 crore or more

A company meeting any one of section 135's thresholds in the preceding year spends at least 2% of its average net profits of the three preceding years on CSR. Unspent amounts follow set dates: to a Schedule VII fund within six months, or — for ongoing projects — to an Unspent CSR Account within 30 days, spent within three years.

Source: Companies Act, 2013, section 135. Proposed amendments (the Corporate Laws (Amendment) Bill, 2026) were not law as of October 2026. Checked October 2026.

In ESGTrack

  • Whether CSR applies, and the 2% to spend
  • Set-offs and unspent amounts, moved by their dates
  • The Annexure II report and Form CSR-2 details, feeding BRSR Section A and Principle 8

Financed emissions (PCAF)

Banks, NBFCs and investors

Financed emissions are Scope 3 category 15 for lenders and investors: borrowers' and investees' emissions attributed by the share financed. The PCAF standard sets the attribution method by asset class and a data quality score from 1 (reported, verified) to 5 (estimated).

In ESGTrack

  • Loans and investments by PCAF asset class, with attribution
  • Data quality scores, financed emissions and WACI
  • Portfolio targets followed from your data

RBI climate-risk directions

Banks and NBFCs

RBI issued directions on climate finance and the management of climate-change risks in November 2025. Its separate disclosure framework on climate-related financial risks was published in draft in February 2024 — governance, strategy, risk management, metrics and targets — and had not been finalised as of October 2026.

Sources: RBI, Climate Finance and Management of Climate Change Risks Directions, 2025; draft Disclosure framework on Climate-related Financial Risks, 2024. Checked October 2026.

In ESGTrack

  • Climate-finance classification of every exposure, with totals and coverage
  • A carbon-price stress test of the loan book, with expected loss before and after
  • Governance records, the draft framework's eleven disclosure items, and a supervisory data export

Product carbon footprints

Manufacturers whose customers ask for product-level emissions

Customers increasingly ask suppliers for the footprint of a product rather than of the company. ISO 14067 and the GHG Protocol Product Standard set how to calculate one; WBCSD's PACT Pathfinder sets how to exchange it.

In ESGTrack

  • Per-unit footprints by life-cycle stage, manufacturing taken from your inventory
  • A footprint declaration as a PDF
  • A PACT Pathfinder file for customers

Work out your obligations from one set of figures

Tell us which programmes apply to you, and we will show them calculated from your own inventory in a demo.