Law Updates

Subject

Summary: The Rajasthan State Pollution Control Board (RSPCB) has extended the compliance deadline for tyre pyrolysis units to 30 September 2026, underscoring the need for industry stakeholders to adjust their planning timelines accordingly. For tyre pyrolysis plant owners across Rajasthan, this is not just another date change. It affects how much time remains to plan investment, complete engineering upgrades, and secure fresh Consent to Establish (CTE) and Consent to Operate (CTO) approvals for continuous-type plants. Key Highlights of the Latest RSPCB Notification RSPCB regulates industrial pollution across Rajasthan. Tyre pyrolysis units fall under its watch because the process can release smoke, oil vapour, and other emissions if not properly managed. The latest office order does three simple things. It pushes the compliance date forward and emphasizes that switching to continuous-type technology offers significant safety, environmental, and operational efficiency benefits, thereby encouraging industry confidence. Here is a quick summary of the notification. Quick Facts Table Detail Information Issuing Authority Rajasthan State Pollution Control Board (RSPCB) Earlier Deadlines 31.12.2025 to 31.03.2026 to 30.06.2026 Revised Deadline 30.09.2026 Who Must Comply All existing batch-type tyre pyrolysis units in Rajasthan Approvals Required All existing batch-type tyre pyrolysis units in Rajasthan must obtain Consent to Establish (CTE) and Consent to Operate (CTO) for their new continuous-type plants, thereby clarifying the essential regulatory steps for compliance. Consent to Establish, or CTE, is a permission a business needs before building or modifying a plant. Consent to Operate, or CTO, is the permission required actually to run the plant. Both come from the State Pollution Control Board. RSPCB is telling every batch-type tyre pyrolysis unit in the state to switch to the continuous process, and it has now given three extra months to complete this switch, helping industry stakeholders plan effectively and feel more in control. Background of the Compliance Framework Tyre pyrolysis is a process that breaks down old, waste tyres using heat in a chamber without oxygen. The process produces pyrolysis oil, char, steel wire, and gas. The oil can be used as an industrial fuel, and the char can be processed further. RSPCB had actually stopped approving new tyre pyrolysis units in Rajasthan since 2012. Older batch-type plants raised concerns about smoke, odour, and safety, especially when run manually without proper automation. Over time, national studies changed the picture. The Central Pollution Control Board (CPCB), along with expert institutes such as NEERI and IIT Delhi, studied both advanced batch-automated plants and continuous-type plants. The results showed that continuous-type plants, along with advanced automated batch plants, controlled emissions far better than old-style manual batch units. Based on this research, CPCB issued a Standard Operating Procedure (SOP) for tyre pyrolysis oil units on 16 January 2024. This SOP laid out safety rules, site requirements, and pollution control norms for the sector across India. Following this direction, RSPCB decided that Rajasthan would move fully toward continuous-type technology. Timeline Table Date Development 2012 RSPCB stops granting approvals to new tyre pyrolysis units in Rajasthan 17.08.2023 RSPCB issues the original order requiring conversion to continuous type by 31.12.2025 16.01.2024 CPCB issues national SOP for tyre pyrolysis oil (TPO) units 30.12.2025 RSPCB extends the deadline to 31.03.2026 30.03.2026 RSPCB extends the deadline further to 30.06.2026 14.09.2026 RSPCB extends the deadline again to 30.09.2026 RSPCB is not introducing a brand-new rule. It is giving batch-type tyre pyrolysis units more time to complete a conversion that was already ordered back in August 2023. What Has Changed Under the Latest RSPCB Order? The core requirement has not changed at all. Only the deadline has moved. Under the original 2023 order, RSPCB said that the Consent to Operate for batch-type units would be renewed only if the units converted to a continuous process by 31 December 2025. That date was later pushed to 31 March 2026, then to 30 June 2026. The latest order pushes it once more, to 30 September 2026. Existing batch units that do not convert to continuous-type technology by the new deadline risk losing their Consent to Operate renewal, which could lead to operational shutdowns and regulatory penalties, underscoring the critical need for timely compliance. Old vs New Comparison Table Point Earlier Position Current Position Deadline for conversion 30.06.2026 30.09.2026 Technology required Continuous-type plant Continuous-type plant (unchanged) Approval needed CTE and CTO from RSPCB CTE and CTO from RSPCB (unchanged) New unit approvals Only continuous type allowed Only continuous type allowed (unchanged) Batch type renewal Conditional on conversion plan Conditional on conversion plan (unchanged) So the notification is really a timeline update, not a policy change. The direction of the tyre recycling industry in Rajasthan remains fixed toward continuous-type technology. Why Has RSPCB Extended the Compliance Deadline? RSPCB has not detailed the reasons in the brief order, but recognizing practical challenges such as funding, construction timelines, and application processing helps industry owners feel supported and better prepared during this transition. Below are the likely reasons, explained through the lens of the challenges tyre pyrolysis businesses have reported and the outcomes RSPCB appears to be targeting. Continuous-type plants need significant capital investment. Reason for extension: businesses need more time to arrange funds and select the right technology supplier. Expected benefit: a properly funded conversion instead of a rushed, poorly built plant. The engineering and civil work required to set up a new plant may take several months. Reason for extension: It is not possible to complete construction, equipment installation, and testing within a short period. Expected advantage: Plants will be prepared for inspection. CTE and CTO applications will require documentation and verification. Reason for extension: Regional offices will need time to process multiple applications. Expected advantage: Smoother processing of applications without last-minute bottlenecks. Shutting down batch units not in compliance with the requirements may cause problems in managing tyre waste. Reason for extension: Rajasthan will need continuous tyre-recycling capacity. Expected advantage: Continuous recycling of tyres in Rajasthan. Why Is RSPCB Promoting Continuous-Type Tyre Pyrolysis Plants? A continuous-type plant feeds raw material in and continuously removes finished output, without stopping and restarting the chamber for each batch. This single design difference creates a chain of environmental and safety advantages. Continuous plants generally run at more stable temperatures. A stable process controls smoke and fumes better than a chamber that repeatedly heats and cools. Studies referenced in the CPCB SOP found that continuous-type plants, along with advanced automated batch plants, had no significant negative impact on ambient air quality. Another consideration is automation. Continuous process plants typically have PLCs (programmable logic controllers), sensors, and automatic feeding systems. This leads to less handling of hot materials and, hence, a reduced risk of work-related injuries. The plant also becomes more efficient. By continuously processing the rubber waste without repeatedly shutting down and starting up, the plant consumes less energy per tonne of tyre waste processed than an interrupted cycle would. Benefits Table Area Batch Type Plant Continuous Type Plant Emission control Harder to control, especially during startup More stable and easier to monitor Fuel efficiency Energy lost during repeated heating cycles Energy saved through continuous heat retention Worker safety More manual handling of hot chambers Automated feeding reduces manual risk Long-term outlook Facing regulatory phase-out Preferred and promoted technology Batch-Type vs Continuous-Type Tyre Pyrolysis Plants Both technologies are used to convert waste tyres into pyrolysis oil, char, steel, and gas. The difference lies in how the raw material moves through the reactor. A batch-type plant loads shredded tyre material into a closed chamber. The chamber is sealed, heated, and left to complete the pyrolysis reaction. Once finished, the chamber cools down, and workers remove the output before loading the next batch. Basic batch plants often depend heavily on manual labour and simple temperature controls. A continuous type plant, on the other hand, keeps the reactor running non-stop. Fresh shredded tyre material enters at one end through an automatic feeding system, while oil, gas, char, and steel are separated and collected at the other end. The reactor rarely needs to shut down, apart from scheduled maintenance. Detailed Comparison Table Parameter Batch Type Plant Continuous Type Plant Working method Load, process, unload in cycles Continuous feed-in and output Production process Stop-start operation Uninterrupted operation Capacity Generally suited to smaller volumes Generally suited to larger volumes, above 60 TPD in many state guidelines Fuel use Higher due to repeated heating Lower due to sustained heat Labour requirement Higher, more manual handling Lower, mostly automated Automation Limited in basic units High, with PLC-based controls Pollution Higher risk during load/unload cycles Lower risk with steady-state operation Safety More exposure to hot chambers Reduced worker exposure Maintenance Frequent, tied to each cycle Scheduled, less frequent interruption Product quality Can vary batch to batch More consistent output quality Operating cost Lower entry cost, higher running cost Higher entry cost, lower running cost over time Regulatory acceptance Being phased out for renewal in Rajasthan Actively promoted by RSPCB and CPCB Long-term suitability Limited future for renewal approvals Aligned with future compliance direction Which Technology Is Better for Future Compliance? Continuous-type technology is the clear direction for future compliance in Rajasthan. RSPCB has stopped approving new batch-type units since 2012, and is now phasing out renewal approvals for existing batch units unless they convert. Any business planning to remain in the tyre pyrolysis sector over the next several years should treat continuous conversion as a business necessity, not just a paperwork requirement. Who Is Required to Comply With This Notification? The notification is specific about which units fall under its scope. Existing batch-type units: Every plant currently operating on a batch process in Rajasthan must convert to a continuous process by 30.09.2026. Units holding a current CTO: Even if a batch unit already has a valid Consent to Operate, renewal will depend on completing the conversion. New projects: Any fresh tyre pyrolysis project in Rajasthan can only be approved as a continuous-type plant, since RSPCB does not permit new batch-type units. Expansion projects: Units expanding their existing capacity should plan the expansion around continuous-type technology, since regulatory approval will follow the same direction. Businesses not covered: Units that already operate on continuous-type technology, or units in other industries unrelated to tyre pyrolysis, are not affected by this specific order. Implementation Timeline and Compliance Milestones Businesses should treat 30 September 2026 as the final checkpoint, not the starting point for planning. Working backwards from that date helps avoid a last-minute rush. Timeline Table Milestone Suggested Timeframe Internal compliance review Immediately Budget approval and vendor selection Within 4–6 weeks CTE application submission Within 2–3 months Plant construction and machine installation Ongoing, based on vendor timeline Pollution control equipment installation Before commissioning Site inspection by RSPCB Before CTO application CTO application and approval Before 30.09.2026 Final compliance confirmation On or before 30.09.2026 Numbered Milestone List Review current plant status and pending approvals. Finalise the continuous type technology vendor. Apply for Consent to Establish. Complete civil and mechanical construction. Install pollution control and safety systems. Request site inspection from RSPCB. Apply for Consent to Operate. Obtain final approval before the deadline. Compliance Requirements for Tyre Pyrolysis Units Compliance under this notification covers more than just changing machinery. It touches technology, paperwork, and monitoring. Technology upgrade: The reactor and feeding system must be designed for continuous processing, not a modified batch chamber. Consent to Establish (CTE): This consent is mandatory before construction or modification. This approval assures that the plant design satisfies the pollution control requirements. Consent to Operate (CTO): This consent is required before the plant can commence commercial production. The RSPCB issues it once it has been assured that the plant complies with the approved design. Environmental clearances: As the tyre pyrolysis products fall under the hazardous waste category, additional clearances related to hazardous waste requirements must be obtained, depending on plant capacity and location. Pollution control devices: Scrubbers, condensers, and a gas-handling system must be installed for pollution and odour control. Inspection process: RSPCB officials visit the plant site before issuing a CTO to inspect the installed equipment. Compliance Checklist Confirm current plant classification (batch or continuous) Select a continuous-type technology vendor Prepare technical drawings and process flow documents Apply for CTE with RSPCB Install approved pollution control equipment Complete safety and automation systems Undergo site inspection Apply for and obtain CTO Keep renewal documents updated Step-by-Step Compliance Process for Businesses Step 1: Confirm the current clearance status. See if the existing "Consent to Operate" mentions anything about conversion. It provides the actual deadline for that particular unit. Step 2: Evaluate the existing plant. Find out which parts of the present batch system - land, shredders, or storage spaces - can be re-used in the new continuous process. Step 3: Decide on continuous-type technology. Make a comparison of vendors not only in terms of cost but also in terms of capacity and service support. Step 4: Develop technical documentation. Have the process flow diagrams and the technical description of the equipment ready for submission with the CTE application. Step 5: Apply for Consent to Establish. Submit the CTE application along with required documents to the regional RSPCB office. Step 6: Execute construction and installation. Coordinate closely with the technology vendor to avoid delays in machine delivery or civil work. Step 7: Installation of pollution control devices. Install scrubbers, gas handling system, and monitoring instruments along with the plant, and not as an afterthought. Step 8: Ask for site inspection. Once the plant installation is completed, ask the RSPCB to inspect the plant in accordance with the approved drawings. Step 9: Apply for Consent to Operate (CTO). Get the CTO approved along with the required documents and inspection clearance. Step 10: Comply with CTO requirements. After obtaining the CTO's approval, comply with the requirements to prevent future complications. Documents Required for Compliance Document Purpose Issuing Authority (where applicable) Existing Consent to Operate copy Shows current approval status RSPCB Land ownership or lease documents Confirms legal right to operate at the site Revenue Department / Owner Process flow diagram Explains how the continuous plant will function Prepared by applicant/consultant Equipment specification sheet Details machinery and pollution control systems Technology vendor CTE application form Formal request for establishment approval RSPCB CTO application form Formal request for operation approval RSPCB Hazardous waste authorisation (if applicable) Covers handling of pyrolysis byproducts RSPCB / State Pollution Control Committee Site layout plan Shows plant location, buffer zones, and safety distances Prepared by applicant/consultant Each document helps RSPCB verify that the plant is designed and built to meet environmental and safety standards before it begins full operation. Impact of the Extended Deadline on Businesses Positive Impact More time to raise funds without rushing into loans on unfavourable terms. Better opportunity to select a reliable technology vendor instead of the first available option. Reduced risk of construction shortcuts that could later cause inspection failures. Continued tyre recycling capacity in Rajasthan during the transition period. Business Challenges Businesses that delay planning may still face a time crunch as September 2026 approaches. Vendors may see high demand as many plants convert around the same period, leading to longer waiting times. Regional RSPCB offices may face a higher volume of applications near the deadline. Financial and Operational Challenges Businesses May Face Switching from batch to continuous technology is a bigger commitment than a routine equipment upgrade. Investment: Continuous-type plants generally cost more upfront than basic batch systems because they include automation and advanced pollution-control equipment. Technology upgrade: Businesses need to choose equipment that matches their tyre waste volume, as an oversized or undersized plant can create operational problems later. Downtime: Some units may need to pause batch operations temporarily during construction, affecting short-term revenue. Engineering changes: Continuous plants often need different foundation work, feeding systems, and layout compared to batch units. Documentation: Preparing accurate technical documents takes time and usually needs support from an experienced consultant. Approval timelines: CTE and CTO processing depends on RSPCB's workload and the completeness of submitted documents. Challenge vs Possible Solution Table Challenge Possible Solution High upfront investment Explore phased investment or equipment financing options. Choosing the right vendor Compare multiple vendors and check past installations. Operational downtime Plan construction during a lower-demand business period Complex documentation Engage an environmental compliance consultant early. Approval delays Submit complete, error-free applications the first time. Benefits of Upgrading to Continuous-Type Technology Environmental Advantages: lower emissions, improved odour control, and minimised fugitive gas releases compared with the old-fashioned batch process. Economic Advantages: greater uniformity in product quality and a relatively lower fuel cost per tonne of waste tyre processed. Regulatory Advantages: Continuous plants now and in the future fall under RSPCB approval guidelines. Operational Advantages: Reduced dependence on manpower and decreased safety hazards because of automated material handling. Comparison Table Category Batch Type Outcome Continuous Type Outcome Environment Higher emission risk Lower emission risk Business Variable output quality Consistent output quality Compliance Facing phase-out Fully aligned with regulation Operations Higher manual dependency Higher automation, lower risk Risks of Non-Compliance After September 2026 Missing the 30 September 2026 deadline can create serious business disruption. Regulatory action: RSPCB can refuse to renew Consent to Operate for a batch-type unit that has not converted. Operational restrictions: a unit without valid CTO cannot legally continue production, which can halt operations entirely. Delays in approvals: units that apply late may face longer processing times due to a rush of applications near the deadline. Business impact: production stoppage affects revenue, existing contracts, and supply commitments to buyers of pyrolysis oil. Environmental consequences: the continued operation of poorly controlled batch units contributes to the very emissions and safety concerns that the RSPCB is trying to address. Business Opportunities Created by the Extended Deadline The transition period also opens doors for several types of service providers. Opportunity Table Business Type Opportunity Created Technology suppliers Rising demand for continuous-type pyrolysis reactors and automation systems Engineering companies Rising demand for continuous-type pyrolysis reactors and automation systems Environmental consultants Demand for CTE/CTO documentation and regulatory guidance Compliance agencies Demand for end-to-end approval support and inspection readiness Pollution control equipment manufacturers Demand for scrubbers, condensers, and monitoring instruments Investors Opportunity to fund modernised, compliant tyre recycling capacity in Rajasthan Is This the Right Decision or an Additional Burden? Benefits Challenges Continuous plants control smoke and fumes more effectively than manual batch chambers Continuous type technology needs a much larger upfront investment than a basic batch setup Stable, steady-state operation reduces emission spikes during startup and shutdown cycles Civil work, foundations, and layout often need to be rebuilt, not just upgraded Automated feeding systems cut down manual handling of hot material, improving worker safety Skilled operators and technicians are needed to run automated, PLC-based systems Consistent process conditions lead to more uniform pyrolysis oil, char, and gas quality Vendor selection takes time, and demand for continuous plant suppliers may rise as the deadline nears Lower fuel use per tonne of tyre waste over time, since the chamber does not repeatedly cool and reheat Documentation for CTE and CTO takes technical expertise many small operators do not have in-house Aligns with RSPCB's long-term direction, so future renewals face less regulatory risk Construction and installation may cause temporary downtime, affecting short-term revenue Supports Rajasthan's broader air quality and pollution control goals under CPCB's SOP Smaller, standalone operators may struggle to match the compliance pace of larger, well-funded units Reduces the chance of sudden regulatory action, like non-renewal of Consent to Operate A last-minute rush near 30.09.2026 could strain RSPCB's inspection and approval capacity Positions the business for continued market access to buyers of pyrolysis oil and byproducts Financing options for equipment upgrades may not be easily available to every business Creates a safer, more modern work environment that can help with hiring and retention Learning new operating procedures and safety protocols takes time and training The table leans toward the extension being a workable middle path rather than a pure burden. The environmental and long-term business case for continuous-type technology is strong, but the short-term financial and logistical load falls unevenly; larger units can absorb it more easily than smaller ones, which is where early planning and consultant support matter most. How Businesses Can Prepare Before the New Deadline Conduct a compliance review of the current plant and existing approvals. Prepare a realistic budget covering equipment, construction, and approval costs. Shortlist and finalise a continuous-type technology vendor early. Assemble all required documentation in advance. Select experienced contractors and equipment suppliers. Submit CTE and CTO applications as soon as the plant is ready. Regularly track project progress against the milestone timeline. Compliance Checklist for Tyre Pyrolysis Units Review existing approvals Assess current plant technology Select continuous-type system Prepare engineering plan Apply for CTE (if required) Upgrade pollution control equipment Complete inspection Obtain CTO Complete compliance before the deadline How Corpseed Can Help Corpseed works with businesses across India on environmental compliance, hazardous waste management, and Pollution Control Board approvals. For tyre pyrolysis units in Rajasthan, this kind of support can make the RSPCB tyre pyrolysis compliance deadline easier to manage. Compliance Position Review Checks the plant's current Consent to Operate for any conversion condition or attached deadline. Identifies gaps between the existing batch setup and continuous type requirements. Flags pending renewals or missing approvals early, before they become urgent. Technical and Legal Documentation Prepares process flow diagrams and equipment specification sheets for submission. Drafts CTE and CTO application forms with accurate, consistent details. Reviews site layout plans against RSPCB's buffer zone and safety norms. CTE and CTO Application Support Assists with submitting the Consent to Establish application to the regional RSPCB office. Coordinates the site inspection process once construction is complete. Follows up on the Consent to Operate application to avoid unnecessary delays. Hazardous Waste Authorisation Advises on hazardous waste authorisation where pyrolysis byproducts require it. Helps align hazardous waste handling and storage practices with regulatory expectations. End-to-End Project Coordination Acts as a single point of contact between the business and regulatory offices. Tracks project milestones against the 30 September 2026 deadline. Reduces the risk of missing the deadline due to documentation gaps or process delays. The RSPCB has granted an extension of the deadline for batch-type tyre pyrolysis units to be converted to continuous-type units until 30 September 2026. However, the core condition remains the same. Every single batch unit must make the transition and obtain new CTE & CTO approvals. This grace period must be treated as additional time for planning purposes, not as grounds for procrastination. The process of choosing the right technology, building, and getting required permits takes months of effort. An early start will guarantee smooth legal operations in the future, prevent last-minute rushes among vendors and RSPCB officials, and contribute positively to the environment. The only practical recommendation for business owners is to begin the conversion process before 30 September 2026.

Subject

Summary: In its notice dated March 27, 2026, the Directorate General of Foreign Trade ( DGFT ) has amended Para 9.05 of the Foreign Trade Policy (FTP) 2023. Under the new amendment, there is no longer any limit on the value of goods exported through a courier service or foreign post office. Until now, businesses exporting goods through a registered courier service could send goods worth only up to Rs 10,00,000 (Rs 10 lakh) per consignment. With this amendment, that value cap is withdrawn entirely, effective April 1, 2026. This is significant because thousands of exporters, mostly MSMEs, use courier services to transport their cargo out of the country. Fixed-value limits per consignment meant that exporters had to either split their high-value consignments or resort to more costly export channels. The removal of the courier export value limit under this notification affects manufacturers, exporters, e-commerce brands, and MSMEs that use the courier and post channels for international transactions. Everyone exporting high-value cargo through the courier channel needs to know the implications of this amendment. This article explains the notification in plain language, what has changed, who is affected, and how businesses can adjust their export compliance processes. Key Highlights of the Notification Issued by DGFT, Department of Commerce, Ministry of Commerce and Industry. Published in the Gazette of India (Extraordinary), Part II, Section 3, Sub-section (ii), Gazette No. 4016, dated July 29, 2026. Amends Para 9.05 of the Foreign Trade Policy (FTP) 2023, which deals with exports through Courier Service/Post. Issued using powers under Section 5 of the Foreign Trade (Development and Regulation) Act, 1992, read with Paragraphs 1.02 and 2.01 of FTP 2023. The earlier version of Para 9.05 fixed a value limit of Rs 10,00,000 per consignment for exports through courier service. The revised Para 9.05 removes this value limit completely. No per-consignment value ceiling is now prescribed for courier exports. Exports through a registered courier service or Foreign Post Office remain permitted only as per notifications issued under the Customs Act, 1962. Exportability of goods continues to be governed by the FTP/Export Policy in ITC(HS), as notified separately. The amendment does not change any other part of Para 9.05, such as which items are eligible for export through courier. This amendment shall be in force with effect from April 1, 2026. This notice is signed by Lav Agarwal, Director General of Foreign Trade and Ex-officio Additional Secretary. This amendment shall apply uniformly to all registered couriers and foreign post offices notified under the Customs Act, 1962. This notice does not provide for any transition period, exception, or carve-out. This notice makes no mention of changes to forms; businesses are expected to follow the current customs/courier export practices until further notice. The Regulatory Framework Relevant Act: Foreign Trade (Development and Regulation) Act, 1992. Section 5 empowers the Central Government to make and modify the export-import policy. Policy Document Modified: Foreign Trade Policy (FTP) 2023, specifically Paragraph 9.05 relating to exports through Courier Services/Post. Issuing Authority: Directorate General of Foreign Trade (DGFT), under the Department of Commerce, Ministry of Commerce and Industry, Government of India. Legislative Background: FTP 2023 serves as the comprehensive policy governing India's import-export framework. In particular, Paragraph 9.05 refers to the conditions for exporting goods via couriers or foreign post offices rather than the cargo/freight channel. Purpose of Paragraph 9.05: For regulation and facilitation of export of goods through courier/post offices, as per Customs Act notifications and relevant export policy of ITC(HS). Scope of the Modification: It relates only to the limit of value of goods provision in Paragraph 9.05. It does not change the eligibility criteria, restrictions on items and any other condition for courier export not specified in the notification. Applicability: To all exporters, including manufacturers, traders, online exporters and MSMEs exporting goods through registered courier service or foreign post offices as per the Customs Act, 1962. What Has Changed? The amendment is narrow but significant. It changes only one sentence within Para 9.05 of FTP 2023. Old Provision vs New Provision Aspect Existing Para 9.05 (Before Amendment) Revised Para 9.05 (After Amendment) Export channel Registered courier service/Foreign Post Office, as per Customs Act 1962 notifications Same no change Exportability of items Regulated as per FTP/Export Policy in ITC(HS) Same no change Value limit per consignment Rs 10,00,000 (Rs 10 lakh) No value limit prescribed Effective date of this limit removal Not applicable April 1, 2026 In Simple Words Earlier, if a business wanted to export goods through a courier company or foreign post office, the total value of a single shipment (consignment) could not exceed Rs 10 lakh. If the shipment value was higher, the exporter had to either split the consignment or use a different export route, such as standard cargo shipment with a customs broker. From April 1, 2026, this cap no longer applies. A single courier consignment can now carry goods of any value, provided it meets other applicable conditions, such as the item being permitted for export under the ITC(HS) policy and the courier or foreign post office being registered under the relevant Customs Act notification. What has not changed: The requirement to use a registered courier service or notified foreign post office remains. The export eligibility of specific goods under the ITC(HS) classification and the export policy also remain unchanged. This amendment only removes the value ceiling it does not open up new categories of goods for courier export. Implementation Timeline / Compliance Deadlines Milestone Date Notification issued by DGFT March 27, 2026 Notification published in Gazette of India July 29, 2026 Amendment comes into effect April 1, 2026 Value limit stands withdrawn from April 1, 2026 According to the notice, the amended provisions will be effective from April 1, 2026, and the per-consignment value ceiling for export shipments via courier services will be withdrawn from the same date. The notice makes no provision for any transition period, grandfathering, or phased implementation. For practical purposes, the businesses need to consider April 1, 2026, as the effective date. Why This Amendment Was Introduced? The notification itself does not spell out detailed reasons for the change; it only states the legal basis and the effect of the amendment. Based on what is stated, the change appears to serve the following broad objectives, several of which are commonly associated with such trade facilitation measures: Ease of Business: Abolishing the ceiling on fixed value would facilitate the export process for goods shipped via courier channels. Support for increased export volume: As export volume and value grow through courier channels, especially for MSMEs and e-commerce players, the Rs 10 Lakh cap may become restrictive for genuine businesses. Simplification of export procedure: Exporters no longer need to split high-value shipments into multiple smaller consignments solely to remain below a value threshold. Alignment with courier trade growth: Courier and postal export channels have become a significant route for cross-border trade, especially for time-sensitive and high-value goods. The notification does not mention consumer protection, environmental impact, or safety as objectives for this specific amendment. These are not stated in the source document and should not be assumed. Impact on Businesses Manufacturers:  Manufacturing companies that used courier services to export their final goods could ship higher-value consignments as single shipments. Importers:  The current notification applies only to exports, not to imports. The notification does not amend the import provisions of the FTP 2023. Exporters:  Exporters that had been complying with the existing Rs 10 lakh limit by splitting shipments would be able to ship in consolidated consignments. Brand Owners:  Brand owners who sell premium products internationally via courier-based fulfillment can now ship single high-value consignments without any value-based restrictions, provided the product is eligible for export under the ITC(HS) policy. MSMEs:  MSMEs that rely heavily on courier export for cost and speed advantages stand to benefit from reduced procedural complexity, since they no longer need to plan shipments around a fixed value threshold. Start-ups:  Start-ups engaged in exports, especially in the D2C or e-commerce space, frequently deliver high-value wholesale shipments via courier. The above amendment eliminates a regulatory hurdle that could delay shipment times. Large Enterprises:  Large enterprises that use courier services for specific high-value or time-sensitive shipments (for example, samples, prototypes, or premium products) can have greater flexibility without having to switch to standard freight solely because of value. Service Providers:  Courier service providers and foreign post offices registered under the Customs Act, 1962, are the service providers through which facilitation will be provided. Logisticians and freight forwarders may experience an increase in high-value shipments through couriers. Summary of Impact Areas Impact Area Effect of Amendment Operational Fewer split shipments; simplified consignment planning Financial Potential reduction in per-shipment courier and documentation costs Documentation No new documentation format specified in this notification Compliance Value-limit compliance check for courier exports is no longer required Supply Chain Greater flexibility to route high-value goods through courier instead of standard cargo How Businesses Can Achieve Compliance This notification does not introduce any new requirements for registration, licensing, or documentation. It just abolishes the existing cap on value. Yet, organizations using courier service for their exports must check the below-mentioned requirements, which are still needed according to Para 9.05: Internal Audit: Assess the existing export process to identify shipments previously split due to the Rs 10 lakh value cap, and determine whether consolidation would be beneficial now. Documentation Audit: Ensure that the shipping bill and courier export documents accurately reflect the consignment value, without any value cap. Registration Check: Determine whether the courier service used or the foreign post office is registered in accordance with the applicable notification under the Customs Act, 1962. ITC(HS) Export Policy Check: Confirm that the goods being exported remain permitted for export under the current ITC(HS) classification and export policy. The removal of value limits does not change item-level restrictions. Testing and Certifications: If the goods to be exported require specific testing and certifications under other relevant regulations, those regulations will still apply regardless of the shipment's value. Maintenance of Records: Keep records of consignment values, invoices, and shipping documents, as higher-value shipments may receive more scrutiny than others. Compliance Monitoring: Track any further DGFT circulars or trade notices, as the source notification does not mention accompanying procedural changes any additional guidance would be issued separately. Compliance Tip: Despite the elimination of the value cap, exporters should note that this does not imply unlimited export of goods via couriers. There remain requirements for the eligibility of each good according to the ITC(HS) code and the customs notification. Benefits for Businesses Legal Compliance: Businesses can ship high-value consignments through courier without breaching a policy-based value cap. Reduced Penalties: Lower risk of inadvertent non-compliance from misjudging consignment value splits. Market Access: Easier fulfilment of large or high-value international orders through an existing courier relationship. Customer Trust: Faster, uninterrupted fulfilment of high-value export orders. Brand Reputation: Consistent order fulfilment without procedural delays caused by value-based shipment splitting. Operational Efficiency: Fewer shipments to manage per high-value order. Competitive Advantage: Exporters can offer higher-value courier shipments faster than competitors still adjusting to the new provision. Export Opportunities: Better suited to fulfil bulk or premium-value export orders through courier instead of routing them through standard freight. Right Decision or Additional Burden? This amendment is a compliance simplification rather than a new compliance burden. It removes a restriction rather than adding one. Advantages: No more artificial splitting of high-value shipments. Simpler consignment planning for exporters using courier as their primary export channel. Potential cost and time savings on documentation per shipment. Challenges: This notification fails to address whether the courier companies themselves would revise their internal value and insurance limits, which may still hinder the shipment of extremely valuable items even at that stage. Businesses should ensure that their internal systems are in place so that there is no value-based limit for the purpose of the courier export policy. Item-level exportability of the ITC(HS) code remains the same, and businesses cannot assume that all valuable items are now eligible for export via courier. Compliance Costs: This notification does not state any increase in compliance costs. Compliance costs may decrease because several smaller shipments can be consolidated into a single shipment. Industry Readiness: This is a case of ease of compliance rather than imposing an obligation. Thus, industry readiness should be instantaneously achieved after April 1, 2026. Long-Term Benefit: Over time, this change may encourage more exporters, particularly MSMEs and e-commerce businesses, to use courier as a primary export channel for higher-value goods. Business Opportunities Created •    Manufacturers and Exporters: Ability to fulfil larger, higher-value export orders directly through courier, without restructuring shipments. •    Importers: Not directly affected by this notification, as it applies only to exports. •    Testing Labs: Where export goods require testing or certification, demand may rise as higher-value and possibly higher-volume consignments move through courier channels. •    Consultants: Businesses transitioning their export documentation and internal processes to reflect the new provision may need regulatory guidance to confirm continued compliance with ITC(HS) and Customs Act requirements. •    Technology Providers: Providers of logistics and export management solutions may need to revamp their rules for value-limit validation, which were designed around the Rs 10 lakh limit. •    Service Providers: Companies requiring guidance on the list of items still eligible for shipment via courier services and the document format for such shipments may need compliance assistance. Why Businesses Choose Corpseed? Regulatory changes like this one are usually simple to read but not always simple to apply correctly across daily export operations. Even a single-clause amendment can affect invoicing formats, courier agreements, item eligibility checks, and internal audit processes. Corpseed works with manufacturers, exporters, MSMEs, and startups across India on regulatory advisory, licensing, registration, and documentation support related to foreign trade compliance. This includes: Reviewing whether specific goods remain eligible for export under current ITC(HS) and export policy provisions. Assisting with documentation and shipping bill accuracy for courier-based export consignments. Supporting registration and compliance checks related to courier services and foreign post offices under Customs Act notifications. Helping businesses track and interpret ongoing DGFT circulars and FTP amendments that affect their specific export category. Providing end-to-end compliance support, from internal audit to renewal and reporting, for businesses expanding their courier export operations. Rather than treating this as an isolated update, professional guidance helps businesses map how this change fits into their broader export compliance framework, including customs, taxation, and sector-specific regulatory obligations. Corpseed's Core Message The deregulation steps, such as eliminating the maximum value for courier export consignments, can only be helpful if the firm uses them effectively. Errors such as those made during documentation, item export qualification, and courier registration verification can cause problems regardless of any regulatory simplification. Corpseed helps firms turn such regulations into export operations that comply with applicable laws. This ranges from checking the export eligibility of the consignment to ensuring that the documents for high-value consignments via couriers are in order. If you are a firm that exports via couriers and need to learn more about the amendment regarding your product category, talking to a regulatory expert should be your first step. Conclusion Notification DGFT does away with the Rs 10 lakh ceiling per consignment for exports through a registered courier service or a foreign post office, as mentioned in Para 9.05 of the FTP 2023. The said amendment will come into force from April 1, 2026. The basic rules have not changed. Exports will need to continue to be affected through a registered courier service or foreign post office as specified under the Customs Act 1962, and the item-level exportability rules will continue to be as per the ITC (HS) Export Policy. From a compliance standpoint, for business, it is a facilitative measure that addresses a procedural issue rather than adding to the compliance process. It will allow manufacturers, exporters, MSMEs, and even ecommerce brands to ship high-value consignments through couriers without dividing consignments or diverting exports. Businesses planning to scale up high-value courier exports should still confirm item eligibility, courier registration status, and the accuracy of documentation. If you are unsure how this amendment applies to your specific export category, consulting a regulatory compliance expert like Corpseed can help you apply this change correctly and avoid avoidable compliance risk.

Subject

Summary: The Government of India and the Government of Japan have introduced the Rules of Implementation (RoI) for the India-Japan Joint Crediting Mechanism (JCM), creating a structured framework for developing and implementing bilateral carbon credit projects under Article 6.2 of the Paris Agreement. For businesses seeking India-Japan Joint Crediting Mechanism consulting, Article 6 compliance services, carbon credit project registration or carbon credit advisory, the framework provides clear guidance on project approval, carbon credit issuance, monitoring, verification and international transfer of mitigation outcomes. The new rules create opportunities for renewable energy developers, manufacturers, industrial facilities, waste management companies, infrastructure developers and ESG-focused organisations to collaborate with Japanese partners, access international climate finance, and generate internationally recognised carbon credits. At the same time, they introduce defined compliance requirements that businesses must follow throughout the project lifecycle. Background and Context India and Japan signed a Memorandum of Cooperation (MoC) on 7 August 2025 to establish the Joint Crediting Mechanism as a bilateral framework for implementing greenhouse gas (GHG) mitigation projects. The newly issued Rules of Implementation operationalise this partnership by defining how projects will be approved, validated, registered, monitored, verified and issued carbon credits. The framework is aligned with Article 6.2 of the Paris Agreement, and establishes clear rules for carbon credit accounting, international transfers and measures to prevent double counting. For businesses, this creates new opportunities to participate in international carbon markets, secure carbon credit revenue, attract Japanese investment, and adopt advanced low-carbon technologies through bilateral partnerships. What is the India-Japan Joint Crediting Mechanism (JCM)? The India-Japan Joint Crediting Mechanism (JCM) is a bilateral carbon market framework that enables India and Japan to jointly implement projects that reduce greenhouse gas (GHG) emissions. In return, the emission reductions achieved through these projects are converted into JCM credits, which are shared between both countries based on their agreed technical and financial contributions. The mechanism operates under Article 6.2 of the Paris Agreement, allowing eligible carbon credits to be transferred internationally as Internationally Transferred Mitigation Outcomes (ITMOs). It promotes investment in low-carbon technologies, supports sustainable development and helps both countries achieve their climate commitments while ensuring transparency and preventing double counting of carbon credits. Key Objectives of the India-Japan JCM The Rules of Implementation have been introduced to achieve several strategic objectives including: Create a transparent framework for bilateral carbon credit projects. Encourage investment in low-carbon and climate-friendly technologies. Facilitate technology transfer between Indian and Japanese organisations. Support India's Nationally Determined Contributions (NDCs) under the Paris Agreement. Enable the generation and international transfer of verified carbon credits. Promote sustainable development alongside greenhouse gas emission reductions. Ensure environmental integrity by preventing double counting of carbon credits. Key Highlights of the India-Japan JCM Rules The newly issued Rules of Implementation establish a complete governance framework for developing, registering, monitoring, and issuing carbon credits under the India-Japan Joint Crediting Mechanism. Some of the major provisions include: Key Area What the Rules Provide Framework Establishes the complete governance structure for implementing JCM projects in India. Covered Greenhouse Gases CO₂, CH₄, N₂O, HFCs, PFCs, SF₆ and NF₃ are eligible under the mechanism. Crediting Period Projects can select a crediting period of up to 10 years, including renewals where approved. Carbon Credit Calculation JCM credits are calculated based on the difference between Reference Emissions and Project Emissions. Credit Sharing Credits are allocated according to the technical, financial and operational contributions made by each participant. Project Validation Independent Third-Party Entities (TPEs) must validate all proposed projects. Sustainable Development Every project must prepare and implement a Sustainable Development Implementation Plan (SDIP). Carbon Credit Registry India and Japan will each maintain their own carbon credit registry. Double Counting The framework prohibits double issuance and requires corresponding adjustments for authorised credits. International Transfers Eligible JCM credits may be transferred as ITMOs under Article 6.2 of the Paris Agreement. Which Businesses Can Benefit from the India-Japan JCM? The framework is designed for organisations that can demonstrate measurable greenhouse gas emission reductions through technology upgrades, energy efficiency improvements, or sustainable infrastructure projects. It also encourages collaboration between Indian businesses and Japanese investors or technology providers. Some of the sectors expected to benefit include: Renewable energy developers Green hydrogen projects Energy-efficient manufacturing facilities Steel and cement industries Chemical and petrochemical companies Waste management and waste-to-energy projects Industrial decarbonisation projects Electric mobility and charging infrastructure Smart buildings and green infrastructure Carbon capture and methane recovery projects Japanese technology providers investing in India ESG-focused businesses seeking international carbon finance How Will the India-Japan Joint Crediting Mechanism Work? The Rules of Implementation establish a structured project lifecycle to ensure transparency, environmental integrity and accurate carbon accounting. Every project must pass through multiple approval and verification stages before carbon credits can be issued. The typical JCM project cycle includes: Project Idea Note (PIN) submission to the Joint Committee. Methodology approval for calculating emission reductions. Preparation of the Project Design Document (PDD). Submission of the Sustainable Development Implementation Plan (SDIP). Independent validation by an approved Third-Party Entity (TPE). Registration of the project by the Joint Committee. Project implementation and continuous monitoring of emission reductions. Submission of monitoring reports and Sustainable Development Implementation Report (SDIR). Independent verification of achieved mitigation outcomes. Issuance, allocation, and registration of JCM carbon credits. Carbon credits under the India-Japan JCM are issued only after emission reductions are independently verified, helping maintain transparency and compliance with Article 6.2 of the Paris Agreement. How Are JCM Credits Calculated and Shared? One of the most important aspects of the India-Japan Joint Crediting Mechanism is the transparent calculation and allocation of carbon credits. Unlike conventional carbon markets, the JCM follows a structured methodology to ensure that only genuine and measurable emission reductions are rewarded. Under the Rules of Implementation, JCM credits are calculated as the difference between Reference Emissions and Project Emissions. To maintain environmental integrity, the reference emissions are intentionally set below the expected Business-as-Usual (BaU) emissions, ensuring that projects deliver real as well as additional climate benefits. Carbon Credit Calculation Framework Emission Type Meaning Business-as-Usual (BaU) Emissions Estimated emissions if the project had not been implemented. Reference Emissions Conservatively determined emissions used as the benchmark for credit calculation. Project Emissions Actual greenhouse gas emissions after the project is operational. JCM Credits Difference between Reference Emissions and Project Emissions. How Will JCM Credits Be Shared? The Rules do not prescribe a fixed percentage for sharing carbon credits. Instead, the Joint Committee, with approval from both governments, determines the allocation based on the contribution of each participant. The following factors are considered while allocating credits: Financial investment made by Indian and Japanese participants. Government grants or subsidies provided to the project. Technology transfer and technical expertise contributed. Operational and in-kind support. Overall impact of carbon credit revenue on project viability. Commercial and financial arrangements between project participants. This flexible approach allows every project to have a customised credit-sharing arrangement based on its investment structure rather than a standard allocation formula. What Are the Major Compliance Requirements for Project Participants? Businesses that want to register a project under the India-Japan Joint Crediting Mechanism must complete several regulatory and technical steps before they can receive carbon credits. The process begins with project planning and continues through validation, registration, monitoring, verification, and finally the issuance of JCM credits. Since every stage is reviewed by the relevant authorities, businesses should ensure that their project documents, emissions data and supporting records are complete and accurate throughout the crediting period. Key Compliance Requirements To participate under the JCM, project participants are required to: Submit a Project Idea Note (PIN) outlining the proposed project. Prepare a Project Design Document (PDD) using an approved JCM methodology. Develop a Sustainable Development Implementation Plan (SDIP). Nominate a focal point to communicate with the Joint Committee and the secretariat. Get the project validated by an approved Third-Party Entity (TPE). Apply for project registration after receiving the required approvals. Monitor greenhouse gas emission reductions according to the approved monitoring plan. Prepare monitoring reports and a Sustainable Development Implementation Report (SDIR) for each monitoring period. Get the monitored emission reductions independently verified before requesting carbon credit issuance. Open a registry account to receive JCM credits after approval. Role of the Joint Committee and Third-Party Entities (TPEs) The Rules establish a governance framework to ensure that every project is assessed objectively and follows internationally accepted carbon accounting principles. Two key institutions oversee this process the Joint Committee and the Third-Party Entities (TPEs). The Joint Committee is responsible for approving projects and making key decisions, while Third-Party Entities (TPEs) independently validate and verify projects before carbon credits are issued. Responsibilities of the Joint Committee The Joint Committee is jointly constituted by representatives from the Governments of India and Japan. It is responsible for: Reviewing Project Idea Notes (PINs). Approving or rejecting project registration. Approving methodologies used for calculating emission reductions. Determining project crediting periods. Deciding the allocation and issuance of JCM credits. Approving revisions to registered projects where required. Ensuring compliance with the Rules of Implementation. Role of Third-Party Entities (TPEs) Third-Party Entities independently validate and verify JCM projects before carbon credits can be issued. Eligible TPEs include organisations that are: Accredited under ISO 14065 by an International Accreditation Forum (IAF) member. Accredited under the Indian Carbon Market (ICM) and recognised by NABCB. Approved as Designated Operational Entities (DOEs) under the Clean Development Mechanism (CDM) or accredited under the Paris Agreement Article 6.4 mechanism. Their primary responsibilities include: Validating project documentation. Verifying monitored emission reductions. Reviewing monitoring reports. Issuing validation and verification reports. Maintaining transparency and technical integrity throughout the project lifecycle. Sustainable Development Requirements under the India-Japan JCM The India-Japan Joint Crediting Mechanism requires projects to support sustainable development in addition to reducing greenhouse gas emissions. Businesses must demonstrate these benefits before their projects can qualify for carbon credit issuance. To achieve this, project participants must prepare both a Sustainable Development Implementation Plan (SDIP) before project registration and a Sustainable Development Implementation Report (SDIR) during project implementation. Sustainable Development Compliance Framework Before registration, businesses must: Prepare an SDIP describing expected sustainable development benefits. Submit the SDIP along with the Project Design Document. Participate in the public consultation process. Address any potential negative environmental or social impacts identified during review. During project implementation, businesses must: Prepare an SDIR for every monitoring period. Demonstrate that the commitments outlined in the SDIP have been implemented. Cooperate during evaluations and site visits, where required. Implement corrective actions if adverse impacts are identified. Projects that fail to adequately address sustainable development concerns may face delays in verification or carbon credit issuance, making SDIP and SDIR compliance an integral part of the JCM framework rather than a procedural requirement. Impact of the India-Japan JCM Rules on Indian Businesses The Rules of Implementation create a structured pathway for Indian businesses to participate in international carbon markets while attracting investment and advanced low-carbon technologies from Japan. However, they also introduce new compliance responsibilities that organisations must meet before they can generate and trade JCM credits. The level of impact will vary depending on the industry, project type, and the extent to which businesses plan to participate in carbon credit generation. Renewable Energy Developers Renewable energy companies are among the biggest beneficiaries of the JCM framework. Projects involving solar, wind, biomass, hydropower, and other clean energy technologies can potentially qualify for carbon credit generation, provided they satisfy the approved methodologies and monitoring requirements. Business Impact Area Impact Project Financing Carbon credit revenue can improve project viability and attract additional investment. Technology Access Easier collaboration with Japanese technology providers and investors. International Recognition Projects can generate internationally recognised mitigation outcomes. Compliance Developers must comply with project registration, monitoring, verification, and reporting requirements. Manufacturing and Industrial Facilities Energy-intensive industries such as steel, cement, chemicals, textiles, automotive and engineering can use the JCM to implement emission reduction projects and improve operational efficiency. Business Impact Area Impact Process Modernisation Encourages adoption of cleaner production technologies. Carbon Revenue Additional income through verified carbon credits. ESG Performance Supports sustainability reporting and decarbonisation targets. Investment Opportunities Increases the attractiveness of projects to international investors. Waste Management and Circular Economy Businesses Projects involving landfill gas recovery, methane capture, waste-to-energy, recycling, composting, and industrial waste treatment can benefit from the new framework. Business Impact Creates additional revenue through carbon credit generation. Encourages investment in advanced waste treatment technologies. Supports circular economy and resource efficiency initiatives. Improves project bankability through international climate finance. Infrastructure and Real Estate Developers Developers implementing energy-efficient buildings, green infrastructure, district cooling systems or smart city projects may also explore opportunities under the JCM. The framework encourages businesses to integrate low-carbon technologies during project planning while improving long term environmental performance, and investor confidence. Japanese Investors and Technology Providers The Rules provide greater certainty for Japanese companies investing in emission reduction projects in India. Key advantages include: Clearly defined project approval procedures. Transparent carbon credit allocation mechanisms. Internationally accepted accounting under Article 6.2. Stronger protection against double counting. Greater confidence in long-term project investments. Business Opportunities Created by the New Framework Beyond regulatory compliance, the India-Japan Joint Crediting Mechanism creates new commercial opportunities for businesses that invest in climate friendly technologies. Organisations that successfully register JCM projects can strengthen both their financial performance and sustainability credentials. Some of the key opportunities include: Generate additional revenue through verified carbon credits. Access Japanese climate finance and technical expertise. Improve project bankability for lenders and investors. Accelerate adoption of advanced low-carbon technologies. Enhance ESG ratings and sustainability disclosures. Strengthen competitiveness in international supply chains. Support corporate net-zero and decarbonisation strategies. Participate in internationally recognised carbon markets. Build long-term partnerships with Japanese businesses. Improve brand reputation through verified climate action. For many businesses, carbon credits may become an additional revenue stream that complements the commercial benefits of energy savings, operational efficiency, and sustainable business practices. Compliance Challenges Businesses Should Prepare For While the framework creates significant opportunities, it also introduces a comprehensive compliance process that businesses must manage throughout the project lifecycle. Organisations should assess these requirements early to avoid delays in project approval or carbon credit issuance. Some of the major compliance challenges include: Challenge Business Implication Project Documentation Preparing PINs, PDDs, SDIPs, monitoring reports, and verification documents requires technical expertise. Methodology Selection Projects must use an approved JCM methodology before registration. Third-Party Validation Independent validation and verification may increase project timelines and costs. Continuous Monitoring Businesses must maintain accurate emissions data throughout the crediting period. Sustainable Development Reporting Projects must demonstrate positive environmental and social outcomes in addition to emission reductions. Government Approvals Multiple approvals from both India and Japan are required at different stages of the project. Registry Management Participants must open and maintain registry accounts for receiving JCM credits. Credit Allocation Carbon credit sharing depends on technical and financial contributions, requiring clear commercial agreements between project partners. Step-by-Step Compliance Roadmap for Businesses Registering a project under the India-Japan Joint Crediting Mechanism involves several approvals before carbon credits can be issued. Businesses should understand the requirements at each stage and keep the necessary technical documents ready to avoid unnecessary delays. 1. Check Whether Your Project Qualifies Start by confirming that the proposed project falls within the activities approved under the India-Japan JCM and can use an approved methodology. 2. Submit the Project Idea Note (PIN) Prepare the Project Idea Note (PIN) and submit it to the secretariat for initial review. Once the Joint Committee does not object, the project can move to the next stage. 3. Prepare the Required Project Documents Develop the Project Design Document (PDD) and the Sustainable Development Implementation Plan (SDIP) along with the supporting technical information required for registration. 4. Get the Project Validated An approved Third-Party Entity (TPE) reviews the project documents and validates that the project meets the applicable JCM requirements. 5. Apply for Project Registration After validation and the required approvals from both governments, submit the registration request to the Joint Committee. 6. Monitor the Project Once the project is registered, monitor greenhouse gas emission reductions according to the approved monitoring plan and maintain records for every monitoring period. 7. Apply for Carbon Credit Issuance After the monitored results are independently verified, submit the verification documents and request the issuance of JCM credits through the prescribed process. Following this roadmap helps businesses remain compliant while improving the efficiency of project implementation and carbon credit generation. Why the India-Japan JCM Rules Are a Significant Step for India's Carbon Market The India-Japan JCM Rules set out how carbon credit projects will be approved, implemented, and credits issued, giving businesses greater clarity on participating in the mechanism. Key Benefits for India's Carbon Market Area Potential Impact International Climate Finance Encourages investment from Japanese public and private entities into eligible mitigation projects. Carbon Market Development Strengthens India's participation in international carbon markets through a structured bilateral mechanism. Technology Transfer Promotes adoption of advanced low-carbon technologies across multiple sectors. Industrial Decarbonisation Supports businesses in reducing emissions while improving operational efficiency. Climate Commitments Helps India achieve its Nationally Determined Contributions (NDCs) through verified emission reductions. Carbon Market Integrity Introduces robust monitoring, verification, and accounting mechanisms to improve transparency. Is the New JCM Framework an Opportunity or an Additional Compliance Burden? Like any new regulatory framework, the India-Japan Joint Crediting Mechanism introduces additional compliance obligations. Businesses must prepare detailed documentation, undergo third-party validation, maintain continuous monitoring records and obtain approvals before carbon credits can be issued. While the new framework introduces additional documentation, validation and reporting requirements, it also provides businesses with a recognised process for developing carbon credit projects under the India-Japan JCM. Clear rules on project approval, carbon credit allocation and international transfers can make it easier for businesses to plan long-term investments and collaborate with Japanese partners. Why the Framework Is a Positive Development It's creates a defined process for registering and implementing JCM projects. Boosts carbon credit opportunities through India-Japan collaboration. Greater certainty on how carbon credits will be calculated and shared. A framework that supports investment in emission reduction projects. Opportunities to work with Japanese technology providers and investors. Recognition under the Article 6.2 framework for eligible projects. A structured mechanism that links climate action with sustainable development. Challenges Businesses Should Consider Preparing technical documentation can be resource-intensive. Validation and verification may increase project timelines. Continuous monitoring and reporting require dedicated compliance systems. Carbon credit allocation must be clearly agreed between project participants. Businesses may need specialised technical and regulatory support during project development. Although the framework introduces new compliance requirements, it also gives businesses a clear route to develop carbon credit projects and participate in international carbon markets. How Businesses Can Prepare for the New JCM Framework Businesses planning to register a project under the India-Japan JCM should review the requirements before starting the application process. Preparing the necessary documents and identifying the right project at an early stage can help avoid delays during registration and approval. Before applying, businesses should: Check whether the proposed project is eligible under the India-Japan JCM. Select the applicable approved methodology for the project. Prepare the required technical and project documents. Identify Japanese partners or investors, where required. Put a system in place to monitor and record greenhouse gas emission reductions. Plan for project validation, verification, and carbon credit issuance. Keep all supporting documents ready for review by the Joint Committee and the Third-Party Entity (TPE). This approach can help businesses complete the approval process more smoothly and avoid unnecessary delays during project implementation. How Corpseed Can Help With the introduction of the India-Japan Joint Crediting Mechanism (JCM), businesses must comply with detailed requirements related to project registration, validation, monitoring, verification, and carbon credit issuance. Corpseed offers comprehensive advisory services to help organisations successfully develop and manage JCM projects while ensuring full regulatory compliance. 1. JCM Project Eligibility Assessment Evaluate whether your proposed project qualifies under the India-Japan JCM framework and Article 6.2 of the Paris Agreement.  Assess sector eligibility, emission reduction potential, and project feasibility before investment.  2. Project Documentation and Registration Support Prepare and review the Project Idea Note (PIN), Project Design Document (PDD), and other mandatory documents.  Support businesses throughout the project registration process with the Joint Committee and relevant government authorities.  3. Methodology Selection and Carbon Credit Advisory Identify the most suitable approved JCM methodology for the proposed project.  Assist in calculating reference emissions, project emissions, and expected carbon credit generation.  4. Sustainable Development Compliance Prepare the Sustainable Development Implementation Plan (SDIP) and Sustainable Development Implementation Report (SDIR).  Help businesses address environmental and social impact requirements while meeting sustainable development obligations.  5. Validation, Verification and Registry Support Coordinate with approved Third-Party Entities (TPEs) for project validation and verification.  Assist with registry account creation, carbon credit issuance applications, and credit allocation documentation.  6. Ongoing Compliance and Regulatory Advisory Provide continuous support for monitoring, reporting, verification, regulatory updates, and long-term compliance throughout the project's crediting period.  Help businesses stay aligned with evolving India-Japan JCM requirements and maximise the value of their carbon credit projects.

Subject

Summary: On 16 July 2026, the Delhi Electricity Regulatory Commission (DERC) issued the Second Amendment to its Net Metering Guidelines. Those of you who have gone through the rooftop solar installation process in Delhi know all too well how difficult it was. There was always so much paperwork involved, and physical meetings were a must. The DERC Net Metering Guidelines 2026 change that. This amendment empowers small domestic consumers by removing fees and streamlining steps, making rooftop solar more accessible and less daunting. This article breaks down what changed, why it changed, and what it means for you, whether you're a homeowner, a business, a solar installer, or a compliance professional. Clear language and step-by-step guidance aim to make you feel more confident and supported in navigating the new process. What is Net Metering and How Does It Work? Rooftop solar means installing solar panels on your roof to generate electricity from sunlight. Most homes and businesses don't use all the power they generate during the day, especially when nobody is home or machines are idle. This unused electricity doesn't have to go to waste, it can be sent back into the shared electricity network, known as the grid, and credited to your account. Net metering is the system that makes this exchange possible. Here's what it involves: The grid is the shared electricity network that supplies power to your area and receives any surplus power you generate. The net meter is a special meter that tracks both directions of electricity flow, how much you draw from the grid and how much you send back to it. Extra electricity refers to the solar power your system produces that you don't use immediately and that flows automatically into the grid. Electricity credits are the value assigned to the power you export, adjusted against what you consume from the grid. Billing adjustment happens at the end of each cycle, when your consumption and export are compared to determine your net usage. At the end of your billing cycle, only the net electricity you drew from the grid is billed. If you exported more than you consumed, the surplus can either reduce your bill or roll over as credit, depending on your DISCOM's policy. This is what makes net metering valuable, it rewards you for generating clean energy, even during hours when you aren't around to use it yourself. Background of the DERC Net Metering Framework To understand why the 2026 amendment matters, it helps to know where the rules came from. DERC (Net Metering for Renewable Energy) Regulations, 2014: This was the original framework that allowed Delhi consumers to install rooftop solar and connect it to the grid through net metering. First Amendment Guidelines, 2025: It offered some fee concessions and initial process changes, but in essence the approval process remained largely paper-based. PM Surya Ghar: Muft Bijli Yojana: It is a major program of the Central Government aimed at encouraging rooftop solar installations in homes through subsidies and a national portal. Under the earlier system, applicants had to go through a three-tier process: Feasibility Analysis, Registration, and a separate Connection Agreement. Each stage required its own paperwork and waiting period. The new guidelines streamline these steps, so stakeholders should now follow the simplified two-stage process-Technical Feasibility and the Integrated Stage-making it clearer what actions are needed and when. The problems this created were well known among applicants and installers alike: Multiple separate approvals meant multiple opportunities for delay. Physical documents and, in some cases, physical signatures were needed for the Connection Agreement. Deficiencies in an application were sometimes flagged one at a time, forcing applicants to make repeated corrections rather than fixing everything at once. The problems this created were well known among applicants and installers alike: Multiple approvals meant delays. The new guidelines cap timelines at 25 days for systems above [10 kW], ensuring greater predictability and trust in the process. Small residential systems underwent the same rigorous process as large commercial installations. These friction points slowed down solar adoption in Delhi, even though demand for rooftop solar, pushed by rising electricity costs and the PM Surya Ghar subsidy, kept growing. Why DERC Introduced the 2026 Amendment Too Many Separate Stages The earlier three-tier process meant an applicant could clear feasibility and registration, only to be stuck waiting on a separate connection agreement. DERC merged the process into two stages: Technical Feasibility and an Integrated Stage covering verification, inspection, and installation. Fewer handoffs between departments means fewer chances for a file to sit untouched. No Single Route for Different Types of Consumers Domestic consumers using the PM Surya Ghar scheme and commercial or industrial consumers were not clearly distinguished in the process, causing confusion about which portal to use. To reduce confusion, the amendment clearly identifies two routes: Route A for domestic consumers under the PM Surya Ghar scheme and Route B for commercial and industrial consumers. This clarity helps applicants feel more in control from the start. Applicants know exactly which portal to use from day one. Silence from DISCOMs Caused Indefinite Delay If a DISCOM didn't respond on feasibility within the expected time, applicants had no clear fallback. A deemed approval clause was introduced, if the DISCOM doesn't respond within 15 days, feasibility is automatically treated as granted. Applicants are no longer held hostage to administrative inaction thanks to the deemed approval clause, but they must still ensure timely submission of complete applications and respond promptly to deficiency notices to maintain compliance and avoid delays. Deficiencies Were Flagged Piecemeal An applicant might fix one issue, only to be told about a second issue a week later, and then a third. DERC now requires a single, consolidated deficiency notice. Applicants get the full picture at once and can fix everything in one go. Physical Paperwork Slowed Down the Connection Agreement Signing a physical agreement meant printing, signing, and submitting documents in person or by post. The Connection Agreement is now fully digital, with a tick-box for small domestic systems and e-signature or digital signature for larger or non-domestic systems. No more waiting on courier timelines or office visits to sign a form. Key Highlights of the Amendment Two-Stage Process Replaces the Three-Tier System The old feasibility, then registration, then connection agreement structure is now just two stages. Technical Feasibility and an Integrated Stage that covers verification, inspection, and installation. Fewer checkpoints mean fewer opportunities for a file to get stuck. Route A and Route B for Applicants Route A is for domestic consumers applying under PM Surya Ghar through the National Portal. Route B is for everyone else- non-domestic, commercial, industrial consumers, and domestic consumers not using the subsidy scheme- via the DISCOM or Delhi State Portal. Businesses now have a dedicated pathway separate from the subsidy-driven residential process. Fully Online, Time-Bound Approvals The entire process, from the connectivity application, must be completed online, with no physical or offline forms. Feasibility is to be done within 15 days; if not done within this period, the DISCOM is said to have approved it. Systems below 10 kW do not go through this stage. Stage II: Verification, Inspection, and Net Meter Installation needs to be done within 10 days. The entire process has to be done within 25 days (if more than 10 kW) or 10 days (if up to 10 kW), not counting the time taken by the applicant. Single Consolidated Deficiency Handling All deficiencies or defects must be raised in a single notice, not across multiple rounds. Applicants get 15 days to cure issues, after which the DISCOM completes the process in 5 more days. Minor deviations that don't affect safety or grid compatibility can no longer be used to delay approval. Digital Connection Agreement The agreement is executed digitally at the time of Stage II submission, no separate physical document is required. Domestic consumers up to 10 kW use a simple tick-box; everyone else uses an e-signature or a digital signature. Fee Waivers for Small Domestic Systems No Application Fee or Registration Charges apply to domestic consumers installing rooftop solar up to 10 kW, whether or not they use the PM Surya Ghar subsidy. This removes a key financial barrier for the average household considering solar. Section-wise Analysis Amendment Earlier Rule New Rule Business Impact Guideline 3 - Process Structure Three-tier process: Feasibility, Registration, Connection Agreement Two-stage process: Technical Feasibility & Integrated Verification/Inspection/Installation Faster, simpler approvals Application Routes No formal route split Route A (PM Surya Ghar) and Route B (all other consumers) Clear pathway depending on consumer type Feasibility Timeline Timeline existed, weak fallback 15 days, deemed approval on DISCOM silence, skipped entirely up to 10 kW Predictability and automatic protection Stage II Timeline No combined timeline 10 days for integrated verification, inspection, and installation Faster net meter activation Deficiency Handling Could be raised in multiple rounds Single consolidated notice, 15 days to cure Fewer rounds of correction Minor Deviations Could be treated as a deficiency Cannot delay approval if safety/grid unaffected Reduces unnecessary rejections Outer Timeline No firm cap 25 days (above 10 kW) / 10 days (up to 10 kW) Time-bound certainty Connection Agreement Physical execution Digital: tick-box or e-signature Removes paperwork and visits Fees Charged with limited exemptions Waived for domestic systems up to 10 kW Lower cost of entry Old Process vs New Process Parameter Old Process New Process Number of Stages 3 (Feasibility, Registration, Agreement) 2 (Feasibility, Integrated Stage) Application Mode Mixed online/offline Fully online, end-to-end Feasibility for ≤10 kW Required Deemed approved, no analysis needed Deficiency Notices Could be issued in multiple rounds One consolidated notice only Connection Agreement Physical signature Digital tick-box or e-signature Application Fee (≤10 kW domestic) Chargeable Waived Registration Charges (≤10 kW domestic) Chargeable Waived Physical Visits Often needed Not required Outer Time Limit Not clearly capped 25 days (>10 kW) / 10 days (≤10 kW) Consumer Effort Higher, multiple submissions Lower, single integrated submission Complete Approval Process Choose your route. Domestic PM Surya Ghar applicants use Route A (National Portal), all other consumers use Route B (DISCOM portal or Delhi State Portal). Submit the application online. No physical forms are accepted under the amended guidelines. DISCOM reviews technical feasibility. This applies only to systems above 10 kW or those on a different supply type, smaller domestic systems skip this. Feasibility outcome within 15 days. If the DISCOM doesn't respond within the time frame, feasibility is deemed granted automatically. Install the rooftop solar system. The applicant installs the system after feasibility is granted or deemed granted. Submit registration documents and Single Line Diagram. This is done through the applicable online portal. DISCOM conducts the integrated Stage II review. Document verification, physical inspection, and testing happen together, within 10 days. Net meter is installed and registration number assigned. This happens as part of the same integrated stage, along with grant of connectivity. Digital Connection Agreement is executed, tick-box for domestic systems up to 10 kW, e-signature or digital signature for others. Connectivity is granted. The consumer can now use net metering and start receiving credit for exported electricity. If deficiencies exist, they are communicated once in a single notice, and the applicant has 15 days to fix them, after which the DISCOM completes the remaining steps within 5 more days. Implementation Timeline Activity Timeline Responsible Authority Notes Technical Feasibility Analysis 15 days Distribution Licensee (DISCOM) Deemed approved if missed, not required up to 10 kW System Installation As per applicant's schedule Applicant Time excluded from DISCOM's outer limit Stage II (Verification, Inspection, Installation) 10 days DISCOM Runs from date of electronic acknowledgement Deficiency Cure Period 15 days Applicant Applies only if a deficiency notice is issued Post-Cure Completion 5 days DISCOM After applicant resolves deficiencies Overall Cap (above 10 kW) 25 days DISCOM Excludes applicant-side time Overall Cap (up to 10 kW) 10 days DISCOM No feasibility stage required Guideline Applicability From 16 July 2026 DERC Applies to pending and new applications alike Scope and Applicability Domestic consumers: Apply under Route A (beneficiaries of PM Surya Ghar Scheme) and also under Route B (Non-Scheme Domestic Consumers). Commercial consumers: Apply under Route B using DISCOM/Delhi State Portal. Industrial consumers: Apply under Route B and have the same time for integrated approvals. Consumers belonging to Government & Institutional category: Apply under Route B except for cases where there is a specific scheme. Beneficiaries of PM Surya Ghar Scheme: Should apply under Route A through the National Portal, and fee waivers are applicable till 10 kW. Compliance Requirements Compliance Checklist: Apply through the correct portal: National Portal for Route A and DISCOM/Delhi State Portal for Route B. Prepare a Single-Line Diagram showing the connection between your solar system and the existing wiring. Keep proof of ownership or occupancy of the premises ready. Ensure the installed system matches safety and grid-compatibility standards. Document Submission and Connection Agreement signing must be completed electronically. Monitor the feasibility and timelines of Stage II for knowledge on how to apply for deemed approval. Respond to any deficiency notice within 15 days. Common mistakes to avoid: Incomplete Single Line Diagrams submitted resulting in deficiency notice issuance. Physical documents being submitted as they are no longer required per the amended process. Failing to meet the 15 days for a deficiency notice. Applying through the wrong route (for example, a commercial consumer mistakenly using the National Portal meant for Route A). Responsibilities of DISCOMs Complete technical feasibility analysis within 15 days or let it be deemed granted. Process Stage II verification, inspection, testing, meter installation, registration, and connectivity within 10 days in one process. Only one consolidated notice regarding deficiencies or defects shall be issued, not multiple. Do not make minor non-safety deviations an excuse for delay. The digital Connection Agreement process must be made available through the portal. Application fees and registration fees should be waived for qualified domestic consumers up to 10 kW. Keep the entire process online, without requiring offline or physical submissions. Responsibilities of Applicants Choose the correct route based on consumer category. Submit a complete and accurate application to avoid feasibility delays. Install the rooftop solar system only after feasibility is granted or deemed granted. Upload the Single Line Diagram and all required documents through the portal. Execute the digital Connection Agreement at the time of Stage II submission. Cure any flagged deficiency within 15 days. Retain digital copies of all submissions and approvals for future reference. Impact on Stakeholders Residential Consumers Fee waivers up to 10 kW and deemed feasibility approval make solar more affordable and accessible for the average household. A fully digital process removes the need for paperwork or office visits, encouraging faster adoption of small rooftop systems. First-time applicants may still need some guidance to navigate the online documentation requirements. Commercial Establishments A defined 25-day outer cap on approval gives businesses clear visibility for planning solar investments. Larger systems still undergo full technical feasibility assessment, so documentation accuracy plays a greater role in avoiding delays. Predictable timelines are likely to encourage more commercial properties to consider rooftop solar. Industrial Units The integrated Stage II reduces coordination overhead between feasibility, inspection, and connection steps. Industrial systems often involve more complex Single Line Diagrams that require careful preparation before submission. Simplified approvals support captive solar generation as part of broader energy cost management strategies. MSMEs Lower administrative burden makes solar a realistic option even for businesses with limited compliance resources. Some MSMEs may need external support to navigate the online portal and technical documentation smoothly. Faster approvals translate directly into quicker cost savings from self-generated power. EPC Companies Predictable, time-bound approvals allow EPC companies to commit to firmer project delivery timelines for clients. Installations must strictly match submitted technical documents to avoid triggering a deficiency notice. Streamlined approvals are likely to support higher project volumes in the future. Consultants and Compliance Professionals A clearer, rule-bound process makes it easier to advise clients accurately and confidently. Professionals need to stay current on portal-specific procedures for both Route A and Route B. Rising rooftop solar adoption is expected to increase demand for compliance and advisory support. Benefits For Consumers: Fee Waivers for small rooftop systems. Deemed Approval avoids any delay by DISCOM. No need to visit and submit any paperwork. For Businesses: Timely and definite time frame for planning. Unified process for deficiencies ensures less hassle. Digital Connection Agreement ensures efficient working. For Government: Helps in achieving rooftop solar target under PM Surya Ghar Program. Demonstrates measurable ease-of-doing-business improvement in the power sector. For the Renewable Energy Sector: Encourages more EPC and consultancy activity around rooftop solar. Reduces regulatory friction that previously discouraged smaller installations. Challenges A good process design still faces its own real-world friction issues: Digital literacy issues: Some customers, particularly first-timers, may feel out of place with the entirely digital application process. DISCOM preparedness: The very stringent 10-day integrated Stage II requires that DISCOMs be well prepared. Documentation accuracy: Because defects are only detected once, applicants need to get everything right on their first attempt to avoid delays caused by the 15-day cure period. Solutions: Customers can seek help from installers and compliance consultants in drafting accurate documentation. DISCOMs need to improve their back-end coordination efforts among their technical and administrative staff to meet the new deadlines. Is This a Progressive Reform or Additional Compliance Burden? Aspect Advantages (Progressive Reform) Possible Concerns (Compliance Burden) Process Structure The two-stage process replaces the older three-tier system, reducing the number of approval checkpoints. Larger or non-domestic consumers still go through a full technical feasibility check. Timelines Firm, capped timelines, 25 days (above 10 kW) and 10 days (up to 10 kW), give applicants certainty. Meeting these timelines consistently depends on DISCOM readiness and internal coordination. Documentation Deficiencies are now consolidated into a single notice instead of multiple rounds. Since only one notice is issued, applicants must obtain the documentation promptly, as there's less room for gradual correction. Fees Application fees and registration charges are waived for domestic systems up to 10 kW No fee relief for larger domestic systems or non-domestic consumers Mode of Application Fully online process removes the need for physical visits or paperwork Assumes reliable, consistent access to the online portal, which may not hold for all applicants Connection Agreement Digital execution (tick-box or e-signature) replaces physical signing Non-domestic consumers still need e-signature or digital signature infrastructure to comply Minor Deviations Safety-neutral deviations can no longer be used to delay approval Applicants must still be careful that deviations genuinely don't affect safety or grid compatibility Overall Effort Significantly reduced effort for small domestic consumers, who are the majority of applicants. Slightly higher documentation precision expected from commercial and industrial applicants Balanced View: Overall, the amendment is more about lessening the burden of compliance than adding to it. The increased documentation requirements can be justified in exchange for fast, inexpensive, and predictable approvals. Business Opportunities EPC Companies: Can sell faster project timescales to their clients due to certainty of regulations. Consultants: Increasing demand for application preparation, documentation review, and assistance navigating the portal. Contractors: Fast approvals lead to faster turnarounds and greater project volume. Manufacturers: Solar energy adoption leads to increased sales of panels, inverters, and net metering systems. Financial Institutions: Predictable timelines make solar financing products easy to offer and underwrite. Energy Auditors: Rising installations create ongoing demand for performance audits and compliance verification. How Businesses Can Achieve Compliance? Identify the correct application route before starting: Route A or Route B. Have all documents ready, including the Single Line Diagram, to prevent deficiency notices. Watch out for the 15 days for feasibility and 10 days for Stage II. Appoint a person to handle portal submissions and digital signing. Provide your response to deficiency notices within 15 days. Keep digital copies of all approval stages for possible audits/disputes. Be aware of any additional DERC circulars, as there may be more information. How Does the Amendment Support India's Renewable Energy Goals? The amendment is part of a bigger effort by India to shift to renewable energy sources. Simplified approvals for rooftop solar systems by DERC help increase the use of PM Surya Ghar in Delhi and thus achieve Indian goals in this area. The move toward a fully digital, time-bound process also reflects the government's broader Ease of Doing Business agenda, applying the same principle of process simplification used in other regulatory areas. Digital governance, replacing physical paperwork with online systems, reduces both cost and delay for citizens and businesses alike, while giving regulators better data on installation trends across the city. How Can Corpseed Help? Application Route Guidance Helping you determine whether your case falls under Route A (PM Surya Ghar) or Route B (all other consumers). Advising on which portal to use, National Portal, DISCOM portal, or Delhi State Portal, based on your consumer category. Technical Documentation Support Preparing an accurate Single Line Diagram that matches your actual installation. Reviewing system specifications and capacity details before submission to avoid mismatches. Ensuring documents meet safety and grid-compatibility requirements up front. End-to-End Application Filing Managing the online submission process from application to registration. Coordinating document uploads at the correct stage and within the timeline. Tracking the 15-day feasibility window and 10-day Stage II window on your behalf. Deficiency Resolution Assistance Reviewing any consolidated deficiency notice issued by the DISCOM. Helping you cure flagged issues within the 15-day window without missing deadlines. Digital Connection Agreement Handling Guiding you through the tick-box or e-signature process depending on your consumer category. Ensuring the agreement is executed correctly at the time of Stage II submission. Ongoing Compliance and Advisory Keeping you informed about any more DERC circulars or explanations that arise during the process. Maintaining an electronic record of your approval stages for future reference.  Helping EPC companies, commercial establishments, and homeowners with compliance advisory.

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Summary: SEBI issued a new circular on July 21, 2026. It changes the certification rules for people who sell or distribute Specialized Investment Fund (SIF) products. The circular brings in a new certification called NISM Series-V-D - Mutual Fund - Specialized Investment Fund Distributors Certification. Anyone employed or engaged in SIF sale or distribution now needs this certificate. Here is some good news for distributors. If you hold NISM Series-V-D, you can distribute both Mutual Fund and SIF products. You do not need to hold NISM Series V-A separately. If you only distribute Mutual Fund products, nothing changes for you. You continue to follow the existing Series V-A rule. The rules also change how NISM Series XIII works for SIF distribution. This certificate will stop applying after September 21, 2026, though some existing holders get extra time. The revised rules took effect immediately on July 21, 2026. This article explains what SIFs are, what SEBI changed, who must comply, the important dates, and how distributors and AMCs can prepare. What Is the Specialized Investment Fund (SIF) Framework? What Are Specialized Investment Funds? A Specialized Investment Fund, or SIF, is a type of investment product regulated by SEBI. It sits between regular mutual funds and portfolio management services. SIFs allow fund managers to use more flexible investment strategies than a typical mutual fund scheme. Because SIF products can carry higher risk and more complex strategies, SEBI wants the people who sell them to have specific product knowledge. When Did SEBI Introduce the SIF Framework? SEBI first created the SIF framework through a circular dated February 27, 2025. Later, these rules were added to Chapter 21 of the SEBI Master Circular for Mutual Funds, dated March 20, 2026. Paragraph 21.10 of this Master Circular covers certification requirements for SIF distribution. Why Does SIF Distribution Need Specific Certification? SIF products are different from regular mutual funds. A distributor selling SIF products should understand these differences well. This is why SEBI wants a dedicated certification, separate from the standard mutual fund certification. Who Comes Under the SIF Distribution Rules? The rules apply to any person employed or engaged in the sale or distribution of SIF products. This includes distributors, sales staff, distribution personnel, agents, and other people involved in selling SIF products. We will look at each group in more detail later in this article. What Has SEBI Changed in the SIF Certification Requirements? New NISM Series-V-D Certification for SIF Distributors The circular introduces a new certificate: NISM Series-V-D - Mutual Fund - Specialized Investment Fund Distributors Certification. Under the revised paragraph 21.10.1 of the MF Master Circular, any person employed, engaged, or to be employed or engaged in the sale or distribution of SIF products must hold a valid Series-V-D certificate. This certificate matters because it becomes the main certification path for anyone selling SIF products in the future. Can Series-V-D Holders Distribute Both Mutual Funds and SIFs? Yes. The circular states that entities holding the Series-V-D certificate are eligible to distribute both Mutual Fund products and SIF products. They do not need to hold NISM Series V-A separately. In simple words, one certificate now covers both product types for these distributors. What Happens to Mutual Fund-Only Distributors? If a distributor sells only Mutual Fund products, and not SIF products, nothing changes. They continue to comply with NISM Series V-A - Mutual Fund Distributors Certification, as specified under the Gazette notification dated May 31, 2010. What Happens to NISM Series XIII? Before this circular, SIF distributors relied on NISM Series XIII - Common Derivatives Certification. The revised rule states that this requirement will not apply after September 21, 2026, for SIF distribution. Some existing Series XIII holders get transitional relief, which we explain in the next sections. Old vs New Certification Requirements for SIF Distributors The table below shows how the certification position has changed for different types of distributors. Distributor Type Earlier Position New Position SIF distributors Required NISM Series XIII (Common Derivatives Certification) Required NISM Series-V-D (Mutual Fund - Specialized Investment Fund Distributors Certification) Mutual Fund-only distributors Required NISM Series V-A Continue to require NISM Series V-A. No change. Existing Series XIII holders covered by transition rules Held Series XIII for SIF distribution Can continue on Series XIII until it expires, if obtained on or before September 21, 2026, while also holding valid Series V-A Distributors handling both Mutual Fund and SIF products Needed Series V-A and Series XIII separately Series-V-D alone is enough for both product types Two changes stand out here. First, SIF distribution now has its own dedicated certificate instead of relying on a derivatives certificate. Second, a distributor handling both Mutual Fund and SIF products no longer needs two separate certifications. Series-V-D covers both. Why Did SEBI Revise the SIF Certification Framework? Industry Participants Requested a Review According to the circular, SEBI received representations from industry participants about the SIF certification requirement. This means market participants raised concerns or suggestions with SEBI about how the earlier rule worked. SEBI Discussed the Requirement With NISM SEBI held discussions with the National Institute of Securities Markets (NISM). NISM is the body that designs and conducts certification exams for securities market professionals in India. Based on these discussions, SEBI reviewed the SIF certification requirement. Why a Dedicated SIF Certification Can Help This type of certification, tailor-made for SIF products, can take into consideration the issues, risks, and techniques related to SIF. This is unlike a generic derivatives certificate that has not been made with any consideration for the SIF products. Link With Investor Protection The circular states that it is issued to protect the interests of investors in securities and to promote the development of, and regulate, the securities market. This is SEBI's stated statutory purpose. The new certification requirement supports this goal, though it does not by itself guarantee investor protection outcomes. What Is the Implementation Timeline for the Revised SIF Certification? Date What Happens February 27, 2025 SEBI introduced the SIF regulatory framework March 20, 2026 SIF provisions included in the MF Master Circular (Chapter 21) July 21, 2026 Revised certification circular issued July 21, 2026 Revised provisions come into force immediately September 21, 2026 Revised provisions come into force immediately After existing Series XIII expiry Distributors using the transition move to the Series-V-D requirement July 21, 2026 - Circular Issued SEBI issued this circular to amend paragraph 21.10 of the MF Master Circular. July 21, 2026 - Revised Rules Take Effect It is clear from the circular that the provisions of the circular will become effective with immediate effect. This means the certification requirement came into effect from the date of issuance of the circular, not from some future date. September 21, 2026 - Important Cut-Off Date September 21, 2026 is an important cut-off date in one aspect only. After September 21, 2026, the requirement of Series XIII certification for SIF distribution ceases to apply, except where the transition provision applies to a particular distributor. Transitional Relief for Existing Series XIII Holders Where a SIF distributor already has a Series XIII certificate that was issued on or before September 21, 2026, then the distributor does not have to obtain Series-V-D immediately. He can continue with the Series XIII certification until the expiry of his certificate. What Must They Continue to Hold During the Transition? During this transition period, these distributors must continue to hold a valid NISM Series V-A certificate, as required under the earlier framework. So the transition benefit applies to Series XIII, but Series V-A must still stay valid. Who Needs to Comply with the Revised SIF Certification Rules? SIF Distributors Anyone employed or engaged in selling or distributing SIF products needs the NISM Series-V-D certificate, unless the Series XIII transition applies to them. Mutual Fund-Only Distributors Distributors who sell only Mutual Fund products are not affected. They continue with NISM Series V-A. Existing Series XIII Holders Those holding a valid Series XIII certificate obtained on or before September 21, 2026, can use it until expiry, while keeping their Series V-A valid. Employees and Sales Personnel The rule covers not just distributor firms but also individual employees and sales staff who are engaged in SIF sale or distribution. Asset Management Companies AMCs must make sure that their distributors and agents meet the certification requirement before allowing them to sell SIF products. AMFI and Agents Stakeholder What They Need SIF distributors (new) NISM Series-V-D Mutual Fund-only distributors NISM Series V-A Existing Series XIII holders (qualifying) Series XIII (till expiry) + valid Series V-A AMCs and AMFI Must verify and ensure distributor/agent compliance The circular places a clear responsibility on AMFI and AMCs to ensure compliance with these certification requirements by distributors and agents. How Can SIF Distributors Achieve Compliance? Step 1 - Check Whether SIF Products Are Being Distributed Start by confirming whether your firm or your staff sell SIF products, Mutual Fund products, or both. Step 2 - Review Existing NISM Certifications Next up is the review of existing NISM certifications. Series V-A and Series XIII along with dates of certification must be checked. Step 3 - Check Whether Transitional Relief Applies If your team holds a valid Series XIII certificate obtained on or before September 21, 2026, the transition rule may apply. Step 4 - Obtain Series-V-D Where Required In case the transition provision does not apply to you, or after the expiry of your Series XIII certificate, acquire Series-V-D certificate. Step 5 - Keep Certification Records Updated Make sure that you have updated records about which certificates are held by which of your employees and their dates of certification. Step 6 - Update Internal Compliance Records Update your internal compliance registers to match the changed categories of certificates. Step 7 - Coordinate With the AMC Since AMCs are responsible for checking distributor compliance, keep your AMC informed about your certification status. Step 8 - Track Expiry and Renewal Track certificate expiry dates closely, especially for staff relying on the Series XIII transition, so there is no compliance gap. The circular does not give details about the NISM exam process, application steps, fees, or certificate validity periods. Distributors should check the official NISM website for these specifics. What Is the Impact of the New SIF Certification Rules on Businesses? Impact on SIF Distributors SIF distributors now have a dedicated certification requirement. This may mean training and exam preparation for some staff, and better records of certification status. Impact on Mutual Fund Distributors Distributors who deal only in Mutual Fund products see no change. Those planning to expand into SIF distribution will need to plan for Series-V-D first. Impact on AMCs AMCs now need to check certification status more carefully. Since AMFI and AMCs must ensure distributor and agent compliance, this may mean stronger monitoring and updated records. Impact on Existing Series XIII Holders Distributors with a valid Series XIII certificate obtained on or before September 21, 2026 get breathing room, as long as Series V-A also stays valid. Impact on New SIF Distribution Businesses Any business planning to start SIF distribution should understand these requirements first, since Series-V-D is now the primary route. Is the New SIF Certification Requirement a Compliance Burden or a Positive Change? Aspect Compliance Burden Angle Positive Change Angle New certification exam Staff selling SIF products who don't qualify for the Series XIII transition must prepare for and pass NISM Series-V-D A dedicated SIF-focused exam may build stronger product knowledge than the earlier general derivatives certificate Training Distribution firms may need to organise or fund training for staff moving to Series-V-D Better-trained staff may be more confident explaining SIF products to investors Record keeping Firms must track who holds which certificate, when it was obtained, and when it expires Clear certification categories make records easier to structure than under the old overlapping V-A/XIII setup Renewal monitoring Ongoing tracking is needed, especially for staff on the Series XIII transition, to avoid a compliance gap when it expires The transition rule removes the need for sudden, forced renewals, expiry can be tracked and planned for in advance Number of certificates required None removed for MF-only distributors, they still need Series V-A as before For distributors handling both MF and SIF products, one certificate (Series-V-D) now replaces the earlier need for two (Series V-A + Series XIII) Cost and time Exam fees, study time, and possible re-training add cost for distributors who must newly obtain Series-V-D Distributors already covered by the Series XIII transition avoid immediate cost, since they can wait until their existing certificate expires Transition handling Distributors must correctly work out whether their Series XIII certificate qualifies (obtained on or before September 21, 2026), an added compliance check The transition avoids an abrupt cut-off; qualifying distributors get a clear, workable runway instead of an immediate switch AMC/AMFI oversight AMCs and AMFI now carry explicit responsibility to verify distributor and agent compliance, adding an oversight task A clearer certification structure makes it easier for AMCs and AMFI to check and confirm compliance Mutual Fund-only distributors No burden, this rule does not add any new requirement for them No change needed, they simply continue as before under Series V-A Overall effect Adds a certification task for distributors newly required to get Series-V-D Makes the certification structure clearer, especially for distributors covering both MF and SIF products Overall view: The new rule does add a certification step for some distributors, particularly those not covered by the Series XIII transition. But for distributors handling both Mutual Fund and SIF products, it simplifies things by replacing two certificates with one, and the transition provision softens the impact for existing Series XIII holders rather than forcing an immediate switch. What Are the Benefits of the Revised SIF Certification Framework? Dedicated SIF certification: Series-V-D is built specifically for SIF products, unlike the earlier derivatives-based certificate. Better product knowledge: A focused certificate can help distributors understand SIF products more clearly. Clearer certification requirements: Distributors now know exactly which certificate applies to them. One certification route for MF and SIF: Series-V-D holders do not need Series V-A separately. Better compliance tracking: AMCs and AMFI have a clearer structure to check compliance against. Better distributor preparedness: An examination on its own can equip distributors to deal with their specific SIF risks. Transitional support: Existing Series XIII holders are not forced into an abrupt change. Potential support for investor protection: The certification aligns with SEBI's stated goal of protecting investors, though it does not guarantee this outcome alone. What Business Opportunities Can the New SIF Framework Create? Certification and Training Support Distributors preparing for the Series-V-D exam may need study support. This may create demand for exam preparation services. Compliance Tracking Services AMCs and larger distribution networks may need systems to track certification status. This could increase the need for compliance tracking tools. Regulatory Advisory New businesses venturing into SIF distribution may need an advisory on relevant requirements. Documentation and Record Keeping Certification records and documentation for transition eligibility may be improved through proper record management. Technology for Compliance The companies may need technological support which automatically identifies when certificates expire and when they can transition. Support for Businesses Expanding into SIF Distribution Companies distributing only Mutual Fund products, but intending to distribute SIF products, may need assistance on how to go about obtaining certification. What Should SIF Distributors Do Before September 21, 2026? Check whether your firm or staff distributes SIF products Check current NISM certifications held by your team Verify the exact date the Series XIII certificate was obtained Check the Series XIII certificate's expiry date Confirm that Series V-A status is valid, where applicable Determine whether the transition rule applies to each staff member Understand exactly where the Series-V-D requirement applies Update internal certification records Coordinate with your AMC on compliance status Plan the next certification step for staff who need Series-V-D SIF Certification Compliance Checklist for Distributors This checklist can help distributors and compliance teams quickly review their certification position against the revised SEBI requirements. Compliance Area What to Check SIF distribution Is the person or entity distributing SIF products? Series-V-D Is the new certification required for this person or entity? Series XIII Is a valid existing Series XIII certificate held? Certification date Was Series XIII obtained on or before September 21, 2026? Series V-A Is the applicable Mutual Fund certification valid? Expiry date When does the existing certificate expire? Records Are certification documents maintained and updated? AMC/AMFI checks Has the required compliance verification been completed? NISM Series V-A vs Series XIII vs Series-V-D: What Is the Difference? NISM Series V-A - Mutual Fund Distributors Certification This is the standard certification for people who distribute only Mutual Fund products. It continues to apply exactly as before, under the Gazette notification dated May 31, 2010. NISM Series XIII - Common Derivatives Certification Under the earlier SIF framework, this certificate was used for SIF distribution. In the future, it will not apply to SIF distribution after September 21, 2026, except where the transition provision gives existing holders extra time until their certificate expires. NISM Series-V-D - Mutual Fund - Specialized Investment Fund Distributors Certification This is the new, dedicated certificate for anyone selling or distributing SIF products. It also allows Mutual Fund distribution without a separate Series V-A certificate. Which Certification Applies to Which Distributor? Certification Main Use MF Distribution SIF Distribution Status NISM Series V-A Mutual Fund distribution Yes No Continues, unchanged NISM Series XIII Derivatives (used earlier for SIF) No Only under transition rule, till expiry Being phased out for SIF after September 21, 2026 NISM Series-V-D Combined MF + SIF distribution Yes Yes New requirement How Can Corpseed Help With SIF Regulatory Compliance? Understanding a new SEBI certification requirement, along with a transition rule and cut-off date, can be confusing for distributors and AMCs. Corpseed can support businesses in working through these requirements. Understanding Applicable SIF Compliance Requirements Corpseed can help distributors understand which certification rule applies to their specific business, based on the products they distribute. Certification Requirement Assessment Corpseed can help review existing certification status against the new Series-V-D requirement and the Series XIII transition rule. Regulatory Compliance Advisory Corpseed offers advisory support on SEBI and mutual fund-related regulatory requirements. Documentation and Record Management Corpseed can help businesses set up and maintain proper certification and compliance documentation. Regulatory Update Monitoring Corpseed helps businesses stay informed about relevant SEBI circulars and regulatory changes that may affect their operations. Ongoing Compliance Support Corpseed provides continued support to help businesses track compliance requirements as regulations evolve. If your business needs help understanding and preparing for the applicable SIF certification requirements, Corpseed's team can walk you through the relevant SEBI compliance services and financial services compliance support available. Through this circular, SEBI has revised the certifications for SIF distributors. NISM Series-V-D certification will be mandatory for any person engaged in the sale or distribution of SIF products and will include Mutual Fund distribution without the need for Series V-A separately. SEBI has amended the certification criteria for SIF distributors by way of its circular dated July 21, 2026. The NISM Series-V-D Certification is the only path that is available to any individual who sells or distributes SIF products, as well as Mutual Funds without Series V-A certification. It is the responsibility of AMCs and AMFI to ensure that their distributors and agents conform to the above requirements. It will help distributors to analyze the certification requirement at present, determine if they fall within the transition rule, and plan their actions ahead of time.