September 2026 Climate Brief: CCTS Nears First Trades, CBAM Widens, BRSR Core Counts Down

August was a month of consolidation rather than drama. India's Carbon Credit Trading Scheme moved past its first compliance filing and towards the machinery that actually matters - verification, issuance and the opening of exchange trading. Brussels tightened rather than loosened, with EU finance ministers backing an expansion of the carbon border levy deep into the downstream supply chain. And the voluntary market kept doing what it has done all year: separating credits that carry a label from credits that do not. Following on from our August 2026 climate brief, here is what moved in the last 30 days and what it means if you run sustainability, compliance or procurement at an Indian company.

India's CCTS: verification now, price discovery next

Roughly 490 obligated entities across seven energy-intensive sectors - aluminium, cement, chlor-alkali, pulp and paper, petroleum refining, petrochemicals and textiles - filed verified FY 2025-26 emission intensity data by 31 July 2026. That filing is now working its way through verification review and true-up, which is the step that determines who holds a surplus and who must buy. Grid Controller of India operates the Indian Carbon Market registry, and both obligated entities with surplus certificates and non-obligated buyers must be registered there before they can transact anything. Trading of compliance Carbon Credit Certificates on the designated power exchanges is still guided to around October 2026. We set out the trading mechanics in our note on how to trade carbon credit certificates in India.

Four things worth watching between now and the first trade:

• Registry registration is a gating item, not a formality. Companies that leave it until the exchange opens will watch the first sessions from the sidelines.

• Compliance certificates and offset certificates are not interchangeable instruments. Know which one your internal mandate or board resolution actually permits you to buy.

• Price expectations remain modest. Most Indian analysts put an early certificate well below USD 10 per tonne, against an EU ETS benchmark that has been running closer to USD 70 - a gap that matters enormously for CBAM offsetting.

• Intensity targets ratchet in FY 2026-27. A surplus this cycle is not a surplus next cycle, so treat any early sale as a decision about future compliance cost, not free money. Non-obligated companies can still generate certificates through the CCTS offset mechanism.

India is about to learn its own carbon price. Every abatement business case written before October rests on an assumption. Every one written after rests on a number.

EU CBAM: the perimeter widens while the data bar rises

CBAM's definitive regime has been live since 1 January 2026. Certificate purchase and surrender begins in February 2027 for emissions embedded in 2026 imports, with the first annual CBAM declaration due by 30 September 2027. Two developments in the last month sharpened the picture. First, EU finance ministers agreed a general approach on updating the CBAM regulation, extending its coverage to more than 180 products - largely a response to circumvention through downstream goods that were previously outside the net. Second, the Commission's August guidance package carried an unambiguous message: data quality now has direct financial consequences, because default values are set punitively high by design.

The commercial effect is already visible. Indian iron and steel exports to the EU have fallen by roughly a third and aluminium by double digits, driven less by the levy itself than by EU buyers pricing in the coming carbon cost and refusing to commit without firmer emissions data. The 50-tonne annual de minimis threshold for cement, iron and steel, fertiliser and aluminium removes the smallest importers from the system but does nothing for anyone shipping at commercial scale. On 18 August the Department of Commerce, with the National Accreditation Board for Certification Bodies and EEPC India, ran a CBAM awareness session in New Delhi for around a hundred exporters - a useful signal of how early most of the exporter base still is. Our full walkthrough sits in the EU CBAM 2026 guide for Indian exporters.

BRSR Core: one reporting cycle from the top 1,000

Mandatory assessment or assurance of BRSR Core applies to the top 500 listed entities for FY 2025-26 and extends to the top 1,000 from FY 2026-27. Value chain disclosure sits on a voluntary footing from FY 2025-26, with the corresponding assessment or assurance obligation voluntary from FY 2026-27, and the definition of value chain has been narrowed to significant upstream and downstream partners only. SEBI also introduced a voluntary green credit disclosure alongside these changes.

If your company sits between rank 501 and 1,000 by market capitalisation, FY 2026-27 has already started. Assurance providers test evidence trails, not intentions, and an evidence trail is assembled across a year rather than reconstructed at the end of one. The indicators that cause the most trouble are consistently the ones that depend on third-party data: purchased electricity, water withdrawal by source, waste routed to recyclers and supplier-level emissions. Our breakdown of the BRSR Core assurance expansion sets out what auditors are actually asking for.

Article 6.4: supply is building, quality still needs checking

The Paris Agreement Crediting Mechanism issued its first credits in February 2026, to a clean cookstove programme in Myanmar. The institutional build-out has continued through the year: as of 10 July 2026, 129 of 198 countries - close to two-thirds - had appointed designated national authorities for the mechanism, and the number of former Clean Development Mechanism projects that have secured host-government approval to transition has passed 400. India has named green hydrogen, storage and CCUS among the activity types it is prepared to authorise.

The buyer-side caution has not changed. A transition from the CDM is a registration event, not a quality verdict, and a wave of CDM-era vintages entering the pipeline is exactly the moment to keep additionality and baseline scrutiny switched on. Our primer on what Article 6.4 means for Indian companies covers the corresponding-adjustment question in more detail.

Voluntary market: labels harden, removals concentrate

The Integrity Council approved Cercarbono as a CCP-Eligible programme in August, following the Global Carbon Council in May. Cumulatively, around 107 million credits have now been approved to carry the CCP label, of which roughly 63 million appear available in the market and 44 million have been retired or cancelled. Set against annual retirements measured in the hundreds of millions, labelled supply remains scarce - which is precisely why it prices at a premium. High-integrity credits now trade at multiples of low-quality avoidance, with nature-based credits broadly in the range of EUR 7 to 24 per tonne and durable technological removals between EUR 150 and 500.

The removals picture is more concentrated than the headline numbers suggest. More than 90 million tonnes of durable carbon removal is under contract or commitment for future delivery, but a single buyer, Microsoft, accounts for close to 80 per cent of disclosed durable tonnes contracted, and over 80 per cent of high-durability capacity is at risk of never being built without additional offtake. For an Indian corporate buyer the read-across is simple: durable removal pricing is not going to fall because the market is oversupplied, because it is not. Our explainer on what makes a carbon credit high integrity sets out how the CCP label works and why most Indian supply does not yet carry it.

The road to Antalya

COP31 runs from 9 to 20 November 2026 at the Antalya Expo Centre, hosted by Turkiye with Australia's climate minister Chris Bowen presiding over negotiations - the compromise struck after the two countries' competing bids in 2025. A pre-COP meeting takes place in Fiji from 5 to 8 October, including a leaders' event in Tuvalu. The agenda is framed around implementation rather than new headline pledges: turning Global Stocktake mandates into measurable action, closing the emissions gap, and operationalising climate finance, adaptation and loss and damage. For Indian companies the item to track is Article 6 authorisation practice - specifically how host countries handle corresponding adjustments, because that determines whether credits generated in India can be used for buyers' international claims.

Five things to do this quarter

1. If you are obligated under CCTS: complete registry registration and model your true-up position at several price points before the exchange opens.

2. If you are not obligated: screen your project pipeline against the notified offset methodologies while registration queues are still short.

3. If you export to the EU: assume the downstream product list grows, and get verified embedded emissions data to your buyers rather than letting default values set your price.

4. If you rank 501 to 1,000 by market capitalisation: build the FY 2026-27 BRSR Core evidence trail now, starting with indicators that depend on third-party data.

5. If you buy voluntary credits: write CCP or Article 6.4 eligibility into procurement policy, and budget for the label premium rather than being surprised by it at contract stage.

Where Csquare fits

Csquare works with Indian companies across the whole span of this brief: sourcing high-integrity carbon credits, developing CCTS offset projects, building BRSR and CBAM data readiness, and setting net-zero targets that survive assurance. The next ninety days are unusually consequential - India's first carbon price, a wider CBAM perimeter and the start of a BRSR cycle that ends in an audit. If that work lands on your desk and you would rather not build the capability in-house from scratch, get in touch with our team and we will map your obligations against the calendar.

This brief reflects developments reported through 8 September 2026. Positions on CCTS trading timelines, the CBAM downstream extension and BRSR value chain assurance are still moving; confirm the current position before acting on any single item.