Author : Avadhi Jain

When the Union Cabinet approved India’s Nationally Determined Contributions(“NDC”) for 2031-35 on 25 March 2026, the only public record was a press release. CLII published an initial read the same day, flagging open questions on forest sink accounting, Article 6, and Carbon Capture, Utilization, and Storage (CCUS). The Government of India has since published the full NDC text. This piece works through what it confirms, what it adds, and what remains unresolved.

The forest sink accounting shift is confirmed – The full text frames the 3.5 to 4.0 billion tonne CO2 equivalent target as measured “from the baseline year of 2005,” removing the word “additional” that appeared in the 2022 NDC. This is a stock-based measure, not a flow-based one. India had already accumulated 2.29 billion tonnes between 2005 and 2021 by its own figures, so the remaining distance to the lower bound is approximately 1.21 billion tonnes over 14 years. Under the previous framing, every tonne had to be new. Under the current framing, prior accumulation counts. The target is structurally easier to meet, but the accounting change matters considerably once Article 6 enters the picture. India states in Annexure A that it intends to use voluntary cooperation under Article 6, and forest-based removals are a natural candidate asset class. If the sink is counted against the NDC on a stock basis while a portion is simultaneously transferred as an internationally transferred mitigation outcome, the accounting interface becomes contested. The NDC does not address this gap, and India has no statutory cap on deforestation to protect the underlying trajectory.

On Article 6, the full text gives us a clearer picture – Annexure A names specific priority areas for international cooperation: green hydrogen, offshore wind, fuel cells, green ammonia, CCUS, and high-end energy efficiency technologies. Prior NDC submissions made no mention of Article 6, so this is a meaningful step forward. However, the text stops at intent. India’s National Designated Authority exists, and the MoEFCC signed a Memorandum of Cooperation with Japan on the Joint Crediting Mechanism in August 2025, but the NDC does not specify the criteria by which India will issue a Letter of Authorisation against the 2031-35 targets, nor how corresponding adjustments will be handled against an economy-wide emissions intensity goal. The Carbon Credit Trading Scheme, the domestic instrument through which CCUS credits would flow, has not yet finalised CCUS methodologies. That the NDC names CCUS as an Article 6 priority before the domestic credit infrastructure exists is a gap, but it is also a signal that the methodology work is coming, and soon.

The conditionality clause is explicit, and legally significant – Annexure A, paragraph 1(f) states that India’s commitments “are contingent upon the receipt of due support, including its due share of international climate finance; and may be modified to match level of support made available.” This is a direct invocation of Article 4.7 of the Paris Agreement, which makes developing country implementation contingent on developed country finance and technology obligations. India draws on the UNFCCC SCF’s Second Needs Determination Report 2024, which projects developing country financing needs at USD 455 to 584 billion annually through 2030. What the NDC does not specify is India’s individual share of that figure, or how it maps against the COP29 New Collective Quantified Goal of USD 300 billion per year by 2035. The conditionality trigger is stated; the threshold that would activate it is not. That gap matters if India ever formally invokes this clause.

The full text also provides more data – India places its cumulative CO2 emissions since 1850 at under 4% of the global total, and its per capita emissions at approximately one-third of the global average. GDP grew at roughly 7% annually between 2005 and 2019 while emissions grew at roughly 4%, with emissions intensity declining 36% by 2020. Ten Inter-Ministerial Working Groups were constituted to develop a Net Zero Roadmap, covering macroeconomic implications, sectoral pathways, climate finance, critical minerals, just transition, and policy synthesis. This institutional process is the basis for the NDC and will matter when India publishes an updated Long-Term Low Emissions Development Strategy.

Three gaps from the original article remain open: corresponding adjustment criteria for Article 6 are absent, CCUS methodology under the CCTS is not finalised, and the five qualitative targets covering Mission LiFE, adaptation investment, technology diffusion, and resource mobilisation still carry no measurable indicators or reporting timelines. Under the Enhanced Transparency Framework, biennial transparency reports must track NDC implementation. Qualitative targets without defined metrics cannot be tracked in any verifiable way, and the NDC text does not resolve this.

The full text confirms the forest sink shift, states Article 6 priorities explicitly for the first time, and grounds the conditionality clause in treaty language. What it does not do is close the gap between stated intent and operational architecture on Article 6 authorisation, CCUS crediting, or the finance threshold that would activate a revision of targets. India reserves the right to make additional submissions. These gaps are the most likely reason it will need to.