Author : Avadhi Jain

On 25 March 2026, the Union Cabinet approved India’s Nationally Determined Contribution (“NDC”) for 2031-35. The targets, 47% emissions intensity reduction from 2005 levels, 60% non-fossil installed electricity capacity, and a forest carbon sink of 3.5-4 billion tonnes CO2 equivalent, showcase a genuine escalation of ambition under the Paris Agreement.

India’s delivery record on prior NDCs has been credible. The 2030 emissions intensity target was met 11 years ahead of schedule. Non-fossil capacity stood at 52.57% in February 2026, already past the 50% target set for 2030. The FAO ranked India third globally in net forest area gain. Critics have questioned whether the targets were set conservatively enough to allow early achievement. That debate is separate from the question of delivery. On delivery, India’s record is consistent.

The Forest Sink: A Methodological Shift with Legal Consequences

The most consequential change in the proposed 2031-35 NDC is the accounting language used. The 2015 and 2022 NDCs used the word “additional” for the forest sink target, tracking new carbon removal against a baseline. The new NDC uses “from 2005 level,” a stock-based approach measuring total accumulated carbon. This shifts the measurement methodology from flow to stock, with direct implications for how forest carbon credits under Article 6 or voluntary carbon markets can be counted against India’s NDC. India has already reached 2.29 billion tonnes CO2 equivalent by 2021. The path to 3.5-4 billion tonnes by 2035 depends significantly on avoiding deforestation, for which India currently has no statutory cap.

New Instruments, Absent Frameworks

Carbon Capture Utilisation and Storage(“CCUS”) and nuclear energy appear as named instruments in an Indian NDC for the first time. CCUS is already embedded within the Carbon Credit Trading Scheme (CCTS), notified in June 2023 under the Energy Conservation (Amendment) Act 2022. However, methodologies for CCUS credits under the CCTS have not yet been finalized by the Bureau of Energy Efficiency. At the international level, CCUS credit eligibility and permanence accounting under the Article 6.4 Supervisory Body remain contested. The NDC’s CCUS inclusion is therefore operationally ahead of where both domestic implementation and international rules currently stand.

Five Qualitative Targets

The 2031-35 NDC introduces five qualitative targets alongside its quantitative commitments, a structural departure from prior NDCs. Without domestic elaboration and measurable indicators, these targets will not translate into verifiable baselines for carbon market purposes or meet the reporting requirements under the Paris Agreement’s Enhanced Transparency Framework. Further clarity is needed as the full NDC text is published.

Global Stocktake Alignment

The 2031-35 NDC explicitly references the first Global Stocktake outcome from COP28, a first for India’s NDC submissions. The GST called for transitioning away from fossil fuels. India acknowledges the GST but does not adopt its fossil fuel transition language, consistent with India’s negotiating positions at COP28 and COP29.

Article 6: Progress Underway, More to Follow

India has moved on Article 6, not within its NDC submissions but through parallel action. In August 2025, MoEFCC signed a Memorandum of Cooperation with Japan on the Joint Crediting Mechanism under Article 6.2 of the Paris Agreement. India also established a National Designated Authority for Article 6 implementation. These are concrete steps forward.

The Cabinet approval press release of 25 March 2026 does not reference Article 6, corresponding adjustments, or Letter of Authorisation criteria. That absence is noted. It does not foreclose action, but it means the picture remains incomplete. How India intends to manage the interface between the CCTS and international transfers, and how corresponding adjustments will be handled against the new NDC targets, will need to be assessed once the full NDC text is published. That document will be the more definitive read and CLII will follow up once it is available.