Client Context

The client is a leading Indian cement manufacturer operating 8 integrated cement plants and 4 grinding stations across six states, with a combined clinker capacity of approximately 28 million tonnes per annum (MTPA) and a cement capacity of 42 MTPA. The company is among India’s top five cement producers by installed capacity and is listed on both the BSE and NSE.

As a listed entity, the client has been filing BRSR Core reports since FY 2022–23 and upgraded to BRSR Comprehensive (the “Reasonable Assurance” format) in FY 2024–25. The company’s Principle 6 disclosures — covering environmental performance — include energy consumption, GHG emissions (Scope 1 and 2), water withdrawal and discharge, waste generation, and air pollutant emissions. These disclosures are prepared in accordance with SEBI’s BRSR format and are subject to limited assurance by an external auditor.

The client also participates in the Global Cement and Concrete Association’s (GCCA) Getting the Numbers Right (GNR) database and reports annually to CDP Climate Change. Its sustainability team is experienced, well-resourced, and familiar with multiple reporting frameworks. The company had assumed — reasonably but incorrectly — that its BRSR data infrastructure would substantially satisfy the Carbon Credit Trading Scheme (CCTS) requirements when compliance commenced.

The Challenge

When BEE published the CCTS MRV guidelines in April 2026, the client’s sustainability team conducted an initial self-assessment and identified a fundamental mismatch between BRSR reporting and CCTS compliance requirements. The core issue was structural rather than technical: BRSR and CCTS were designed for different purposes, use different metrics, and require different levels of granularity.

Four critical gaps were identified in the initial assessment:

1. Revenue-based vs. production-based intensity. BRSR Principle 6, Question 7 requires GHG emission intensity expressed as tCO2e per rupee of turnover. CCTS requires production-based intensity — specifically, tCO2 per tonne of clinker and tCO2 per tonne of cementitious product. These are fundamentally different metrics. Revenue-based intensity is influenced by product mix, pricing, currency effects, and non-cement revenue streams (such as ready-mix concrete, building products, and logistics services), making it unsuitable as a compliance baseline for a production-linked carbon market.
2. Corporate-level vs. facility-level reporting. The client’s BRSR disclosures reported consolidated emissions across all 12 facilities (8 integrated plants plus 4 grinding stations). CCTS requires emissions data at the installation level — each kiln line is a separate compliance unit. The client operated 14 kiln lines across 8 plants, each with different fuel mixes, clinker factors, and thermal efficiency profiles. Disaggregation from corporate aggregate to kiln-line level required data restructuring that went well beyond simple pro-rata allocation.
3. Incomplete Scope 1 source coverage. The BRSR’s Scope 1 reporting captured the two largest emission sources in cement production — calcination (from the chemical decomposition of limestone) and fuel combustion in the kiln. However, CCTS requires comprehensive Scope 1 coverage, including emissions from on-site vehicles and mobile equipment, quarry operations (drilling, blasting, and material handling), captive power generation, and non-kiln fuel combustion (e.g., drying operations, laboratory furnaces). These sources, while individually small (collectively 3–5% of total Scope 1), must be quantified and reported under the CCTS framework.
4. Emission factor provenance. The client’s BRSR calculations used IPCC default emission factors applied uniformly across all facilities. The CCTS guidelines require a hierarchical emission factor approach, prioritising plant-specific measured values (e.g., site-specific calorific values for alternative fuels), followed by BEE-published factors, India-specific factors, and IPCC defaults as a last resort. The client needed to overhaul its emission factor selection for all material inputs at each facility.

The client engaged RSustain to conduct a systematic gap analysis, develop a conversion methodology, and build a practical roadmap to CCTS compliance that leveraged — rather than replaced — the existing BRSR data infrastructure.

Our Approach

RSustain deployed a team of two senior consultants and one data analyst over 8 weeks. The engagement was designed to be surgical: rather than building a new compliance system from scratch, we mapped the client’s existing data flows, identified the precise points of divergence between BRSR and CCTS requirements, and designed bridging methodologies to close each gap with minimum disruption to established reporting processes.

Phase 1: Comprehensive Mapping Exercise (Weeks 1–3)

We constructed a detailed crosswalk between every data element in the client’s BRSR Principle 6 disclosure and every requirement in BEE’s CCTS MRV guidelines. The mapping covered 47 BRSR data fields and 62 CCTS requirements, assessed across four dimensions: data availability (does the data exist?), granularity match (is it at the right level of detail?), methodological alignment (is it calculated the same way?), and verification readiness (would it withstand DVA scrutiny?).

The mapping revealed that approximately 55% of CCTS data requirements were partially or fully satisfied by existing BRSR data, 25% required transformation or disaggregation of existing data, and 20% required entirely new data collection. This distribution confirmed that the client’s BRSR infrastructure was a valuable foundation but not a sufficient one.

Among the 62 CCTS requirements, we classified gaps into three severity categories:

• Critical gaps (4): Issues that would prevent CCTS compliance entirely — the four gaps described above (intensity metric, facility disaggregation, source completeness, and emission factor provenance)
• Moderate gaps (7): Issues that would result in data quality penalties or require conservative default assumptions — including uncertainty quantification, monitoring plan documentation, and quality assurance procedures
• Minor gaps (5): Formatting, terminology, and documentation differences between BRSR and CCTS that require procedural adjustment but no new data collection

Phase 2: Conversion Methodology Development (Weeks 4–6)

For each of the four critical gaps, we designed a specific conversion methodology:

Intensity metric conversion: We developed a production-based intensity calculation framework anchored to the GCCA’s established protocol for specific CO2 emissions (gross and net). The methodology allocates emissions to clinker production (the primary carbon-intensive step) and then derives cementitious product intensity using facility-specific clinker-to-cement ratios. This approach is consistent with both CCTS requirements and international cement sector practice (GCCA GNR, CSI/WBCSD Cement CO2 and Energy Protocol), enabling dual-purpose reporting.

Facility-level disaggregation: Rather than a simple pro-rata allocation (which would obscure real performance differences between kiln lines), we designed a bottom-up disaggregation methodology. For each of the 14 kiln lines, we extracted production logs, fuel consumption records, and raw meal composition data from the client’s plant-level ERP and process control systems. Where direct measurement was available, actual data was used; where metering covered multiple units, engineering allocation based on production hours, throughput ratios, and thermal capacity was applied, with uncertainty ranges documented.

Source completeness expansion: We identified 11 emission sources not captured in the client’s BRSR reporting and quantified each one using Tier 1 or Tier 2 methodologies as appropriate. The aggregate contribution of these previously unreported sources was 4.1% of total Scope 1 emissions — small in relative terms but material for CCTS compliance and, more importantly, for establishing a complete and accurate baseline that protects the client against future adjustment risks.

Emission factor upgrade: We worked with the client’s quality control and procurement teams to establish plant-specific emission factors for the five most material inputs: petcoke (the dominant kiln fuel, accounting for 68% of thermal energy), domestic coal, imported coal, alternative fuels (refuse-derived fuel and biomass), and raw meal (limestone, clay, and correctives with varying CaCO3 content). For each input, we specified the analytical protocol, sampling frequency, and factor derivation methodology, creating a sustainable process that improves data quality year-on-year.

Phase 3: Deliverables and Roadmap (Weeks 7–8)

We compiled the analysis into three core deliverables and a forward-looking implementation roadmap.

Deliverables

• BRSR-to-CCTS Gap Report — a 64-page document covering the complete crosswalk of 47 BRSR fields to 62 CCTS requirements, with severity classification, root cause analysis, and recommended remediation for all 16 identified gaps
• CCTS Compliance Action Plan — a prioritised, time-bound action plan with 23 discrete tasks, responsible owners, resource estimates, and dependencies, organised into three workstreams: data infrastructure, methodology and calculations, and governance and verification readiness
• CCTS Data Template — a facility-level data collection template (Excel-based with embedded validation rules and calculation engines) designed to be populated by plant-level teams and aggregated centrally, producing CCTS-compliant installation-level GHG statements directly from operational data
• Conversion Methodology Document — detailed technical documentation of the four bridging methodologies (intensity, disaggregation, source expansion, and emission factors), suitable for inclusion in the client’s GHG Management Plan and available for DVA review during future verification engagements

Outcome

The engagement produced a clear and actionable 6-month roadmap to CCTS compliance readiness, structured in three phases:

Phase 1 (Months 1–2): Quick wins. Three of the four critical gaps were addressable within the first quarter through data restructuring and methodology changes that did not require new metering or capital expenditure. By applying the bottom-up disaggregation methodology to existing plant-level data, the client was able to produce provisional installation-level GHG statements for all 14 kiln lines within 6 weeks of project completion. The production-based intensity calculations were implemented in the data template and populated with FY 2025–26 data, yielding facility-specific clinker emission intensities ranging from 0.62 to 0.78 tCO2 per tonne of clinker — a spread that revealed significant performance variation across the fleet and identified clear targets for operational improvement.

Phase 2 (Months 3–4): Data quality upgrade. The emission factor upgrade programme commenced with the procurement of additional analytical equipment at three facilities and the establishment of quarterly fuel and raw material sampling protocols. Plant-specific petcoke emission factors, derived from actual calorific value and carbon content measurements, replaced the IPCC default values previously used — resulting in a 2.3% downward revision of aggregate Scope 1 emissions, directly improving the client’s CCTS compliance position.

Phase 3 (Months 5–6): Verification preparation. The remaining gap — establishing the governance, documentation, and internal audit procedures required for DVA verification — was the final implementation phase. The client established a cross-functional CCTS Compliance Committee, appointed facility-level data owners, and conducted a mock verification exercise using the RSustain-developed procedures manual as the reference framework.

At the conclusion of the 6-month roadmap, the client reported that 14 of 16 identified gaps had been fully closed, with the remaining 2 (both related to metering capital expenditure at older facilities) on track for closure within 3 additional months. The CCTS data template was operational at all 8 integrated plants and had been incorporated into the client’s annual data collection cycle alongside — and now fully reconcilable with — its BRSR reporting process.

An unanticipated benefit of the engagement was the identification of a 6.2% variance between the client’s previously reported corporate-level Scope 1 emissions (in BRSR) and the sum of disaggregated facility-level emissions calculated using the improved methodology. Investigation revealed that the corporate-level figure had been calculated using a simplified methodology that double-counted certain inter-plant clinker transfers. The correction improved the accuracy of all the client’s external disclosures — BRSR, CDP, GCCA GNR, and the forthcoming CCTS submissions — and eliminated a potential integrity risk in the client’s sustainability reporting.