India's GHCI Certification Scheme: A Complete Landscape for the 158-Project, 11.9 MMTPA Pipeline

Key Highlights

• India's Green Hydrogen Certification Scheme (GHCI), launched on 29 April 2025 by Union Minister Pralhad Joshi, creates a mandatory compliance framework for an industry with 158 announced projects and approximately 11.9 MMTPA of capacity in the pipeline.
• The scheme uses a four-stage certificate architecture: Concept (voluntary, free), Facility (mandatory after consent to operate), Provisional (auto-generated, monthly), and Final (mandatory, ₹5 per 100 kg H2).
• The emission threshold is ≤2.0 kg CO2eq per kg H2 measured as an annual average over one financial year. This is nearly 40 percent stricter than the EU RFNBO threshold of 3.38 kg CO2eq per kg.
• BEE accreditation of Accredited Carbon Verification (ACV) agencies remains in early stages. As of March 2026, only two agencies are listed under second-round provisional eligibility, and zero GHCI certificates have been issued.
• The first batch of mandatory final certificates for FY 2025-26 is expected to issue by June-September 2026, creating a narrow operational window for project-level compliance readiness work.

Why GHCI Matters Now

The National Green Hydrogen Mission committed India to 5 MMTPA of green hydrogen production capacity by 2030. The announced pipeline already exceeds that target by 2.4 times, with 158 projects totalling approximately 11.9 MMTPA at various development stages. Per IEEFA's November 2025 briefing note, the reality check is that 94 percent of this capacity (around 11.2 MMTPA) remains at the announcement stage with no further development confirmed. Approximately 9,770 TPA is under construction. Around 0.3 MMTPA (300,000 TPA) is operational.

GHCI sits at the centre of the compliance architecture that will determine which of those 158 projects actually delivers certified green hydrogen to market. It is mandatory for facilities receiving SIGHT or state-scheme incentives, for producers selling or using hydrogen domestically, and for facilities receiving any form of government concession. Exemptions exist for small producers (≤10 tons per year, voluntary certification only) and for 100 percent exporters who do not avail Indian incentives.

For everyone else, GHCI compliance is a prerequisite for monetising the scheme's incentives and for participating in domestic hydrogen markets.

The Four Certificate Stages

GHCI operates through a progressive certification architecture with two facility-level certificates and two production-level certificates.

Concept Certificate (voluntary, free)

Available after design and FEED approval. Certifies that a facility's design meets MRV framework prerequisites. Documents are verified by an ACV agency, then submitted via the Green Hydrogen Portal. The Technical Committee reviews and issues the certificate during the subsequent month. Phased projects at the same site can obtain multiple concept certificates.

Facility Certificate (mandatory, free)

Required after obtaining consent to operate. Involves on-site verification by an ACV agency. This is a prerequisite for either provisional or final certificates. Separate facility certificates are required for each phase of a multi-phase project.

Provisional Certificate (voluntary, auto-generated, free)

Covers a minimum of one calendar month and a maximum of 11 months per evaluation cycle. The producer submits actual production data monthly via the portal, and the certificate is auto-generated. Applications for a given calendar month must be submitted by the end of the next calendar month. Critically, the product carbon footprint is not stated on provisional certificates, so the document is useful for production tracking but not for commercial carbon-intensity claims.

Final Certificate (mandatory, ₹5 per 100 kg H2)

Issued once per financial year. The producer submits all documentation post-ACV verification by 31 May. The Technical Committee reviews and issues by 30 June, with extensions to 31 August or 30 September if clarifications are required. Each final certificate carries a unique identification per 100 kg of hydrogen. Unlike the original draft scheme, final certificates in the launched version are transferable and can be used to claim carbon credits under the Carbon Credit Trading Scheme (CCTS) 2023. The certificate functions as a Guarantee of Origin.

Emission Threshold, System Boundary, and GHG Methodology

The core requirement is ≤2.0 kg CO2eq per kg H2 of non-biogenic greenhouse gases (CO2, CH4, N2O only), measured as an annual average over one financial year (April to March). If any facility exceeds this threshold, no hydrogen from that facility qualifies as green for the entire year. Results are rounded to one decimal place per IS 2:1960.

The well-to-gate system boundary for the electrolysis pathway covers water treatment, electrolysis, gas purification, drying, compression, and on-site storage. For biomass conversion, it covers biomass pre-treatment, heat and steam generation, conversion, purification, drying, compression, and on-site storage. Explicitly excluded are construction and decommissioning of capital goods, emissions from renewable electricity generation and transmission, transport beyond plant boundaries, and conversion to hydrogen carriers.

The GHG calculation for electrolysis follows:

E_Total = E_Feedstock + E_Electricity + E_Fuel + E_Steam + E_InputMaterials − EA_Co-product

Grid electricity uses CEA's Weighted Average Grid Emission Factor (approximately 0.71 kg CO2eq per kWh with T&D losses). Co-product allocation uses the Economic Value Allocation Method based on selling price ratios.

Materiality threshold mechanics

A single emission source may be excluded as immaterial if it contributes less than 1 percent of the 2.0 kg threshold (less than 0.02 kg CO2eq per kg H2). However, all excluded immaterial sources combined must total less than 5 percent of the threshold (less than 0.10 kg CO2eq per kg H2). If adding one more sub-1-percent source would breach the 5 percent cumulative cap, that source must be treated as material. Similar sources must be aggregated to prevent gaming, and ACV agencies verify these materiality assessments.

Temporal Matching, RE Sourcing, and Pathways

GHCI uses annual (fiscal year) averaging. There is no formal hourly matching requirement. Renewable electricity can be sourced through any of the following:

• PPAs (dedicated or common transmission lines)
• Grid banking under the Open Access framework (which operates on 15-minute blocks)
• Green Day-Ahead Market (G-DAM)
• Green Tariff mechanisms from DISCOMs
• Energy storage charged exclusively from renewable energy

Unbundled RECs and carbon credits cannot be used to claim energy as renewable.

Two production pathways are covered: electrolysis (water electrolysis powered by renewable energy) and biomass conversion (biogas reforming and biomass gasification, counting only non-biogenic emissions). Stakeholders may propose new pathways to BEE with supporting evidence.

The BEE Accreditation Bottleneck

BEE accredits Accredited Carbon Verification (ACV) agencies through an application-based process requiring demonstrated expertise in lifecycle assessment, ESG assessment, GHG accounting, and emission verification. ACV agencies must provide "reasonable assurance" and cannot demand sensitive commercial data. Producers must appoint an ACV agency by 31 March each year.

As of March 2026, BEE accreditation remains in early stages. In the second round of provisional eligibility (October 2025), only two agencies were listed:

• KBS Certification Services Limited (Faridabad)
• Design2Occupancy Services LLP (Jaipur). The latter is the only agency to explicitly list "Green Hydrogen Certification" in its sectoral scope.

This verification bottleneck is a critical market constraint. With 158 announced projects and only two provisionally eligible ACV agencies, even modest growth in active certification demand will outstrip the current verifier capacity.

Applicable ISO Standards

ISO 19870:2023 (hydrogen technologies GHG methodology) serves as the primary reference standard for lifecycle assessment, with the February 2026 water emissions draft guidelines specifically aligning with it. IS/ISO 14064 (Parts 1, 2, 3) applies for GHG inventory, project-level quantification, and verification where GHCI does not provide specific guidance. IPCC emission factors are used for fuel, steam, and input materials. CEA grid emission factors and T&D loss data are mandatory inputs.

The 158-Project Pipeline by Player

Government-allocated capacity through the SIGHT scheme includes 19 companies with 862,000 TPA production capacity and 15 firms with 3,000 MW of electrolyser manufacturing capacity. The SIGHT Mode-2A (green ammonia for fertilizer) has allocated 724,000 TPA across 13 auctions.

The major Indian players and their green hydrogen postures as of Q1 2026:

• ACME Group dominates SIGHT auctions: 370,000 TPA across six Mode-2A auctions (51 percent of total allocation), plus 90,000 TPA in Mode-1. Pursuing both GHCI (domestic) and RFNBO (Oman export project certified by TÜV Rheinland). Karnataka project: ₹52,000 crore for 1.2 MTPA.
• Reliance Industries targets 3 MMTPA by 2032. Won 90,000 TPA SIGHT Mode-1 at the lowest incentive bid (₹18.9 per kg) and 300 MW of electrolyser manufacturing. Building the Kandla Hub (1.4 MTPA H2, 7 MTPA ammonia) with L&T, Greenko, and Welspun.
• NTPC is developing the Pudimadaka Green Hydrogen Hub in Andhra Pradesh: USD 22 billion investment, 7 GW, 1,500 TPD hydrogen. Foundation stone laid in January 2025.
• Adani New Industries (ANIL) commissioned India's first off-grid 5 MW pilot in Kutch (June 2025), targeting 1 MMTPA by 2030 with a USD 50 billion investment alongside TotalEnergies.
• AM Green (Greenko) reached FID on Kakinada in August 2024: India's first commercial-scale green ammonia facility, Phase 1 at 1 MTPA, with India's first RFNBO pre-certification under CertifHy. Offtake: Uniper (500,000 TPY), Yara, Keppel.
• L&T contracted for IOCL Panipat (10,000 TPA, 25-year BOO) and commissioned India's first indigenously built 1 MW electrolyser at Hazira.
• GAIL operates India's first green hydrogen plant (Vijaipur, 10 MW PEM, 4.3 TPD, commissioned April 2024).
• JSW Energy commissioned India's largest green H2 plant (Vijayanagar, 3,800 TPA, November 2025) with offtake to JSW Steel for low-carbon DRI steelmaking.

Domestic vs export split

Most near-term commercial projects fall into three categories:

• Domestic-focused (GHCI mandatory): SIGHT Mode-2A winners supplying fertilizer plants (IFFCO, Paradeep Phosphates), Mode-2B refinery supply (IOCL, BPCL, GAIL), and industrial users (JSW Steel).
• Export-focused (RFNBO required): AM Green (Kakinada, around 75 percent for EU), Hygenco (Gopalpur, RFNBO pre-certified), ReNew (Kerala, 220 KTPA for export), ACME (Oman).
• Dual-focus: Reliance, Adani, NTPC Pudimadaka, and the Kandla Hub consortium.

All SIGHT winners (19 companies, 862,000 TPA) need GHCI. An estimated 5-8 major exporters also need RFNBO.

GHCI vs EU RFNBO: Stricter on Paper, Looser in Practice

The central paradox of GHCI is that its emission threshold (2.0 kg CO2eq per kg H2) is nearly 40 percent stricter than the EU RFNBO threshold (3.38 kg CO2eq per kg, based on 70 percent reduction from the 94 gCO2e per MJ fossil comparator). Yet GHCI's operational requirements are significantly less demanding.

Dimension	GHCI	EU RFNBO
GHG threshold	≤2.0 kg CO2eq per kg H2	≤3.38 kg CO2eq per kg H2
System boundary	Well-to-gate (on-site storage)	Well-to-delivery gate (includes transport)
Temporal matching	Annual (fiscal year)	Monthly until 2030; hourly from 1 January 2030
Geographic correlation	None (unified national grid)	Same bidding zone or adjacent with price convergence
Additionality	Not required	Required after 1 January 2028 (36-month commissioning window)
Verification	BEE-accredited ACV agencies	EU-recognised voluntary schemes (ISCC, CertifHy, RedCert)
Certification fee	₹5 per 100 kg (~USD 0.006 per kg)	Scheme-dependent (typically thousands of EUR per audit)

The bidding-zone issue is a major regulatory barrier for Indian exporters. India has multiple official electricity bidding zones, yet EU RFNBO requires renewable energy sourcing from the same zone as the electrolyser. Legal analysis published in late 2025 argues that India functions as a single bidding zone with less than 2 percent price variance across all IEX bid areas.

The additionality gap means GHCI allows producers to use existing grid renewable energy, while RFNBO (post-2028) requires new, unsubsidised renewable energy installations. An Argus Media study estimated that hourly correlation adds approximately USD 200 per ton to Indian ammonia production costs versus annual averaging.

Dual certification creates a real operational burden

Companies pursuing both certifications must maintain separate verification processes (BEE ACV versus CertifHy or ISCC), different system boundaries, different monitoring infrastructure, separate compliance documentation, and different reporting calendars. A PtX Hub whitepaper (July 2025, commissioned by the German BMWK) specifically addresses achieving "dual compliance without duplication or retrofit risk".

Active harmonisation efforts include the EU-India Green Hydrogen Forum (2nd meeting, May 2025, Rotterdam), the India-EU TTC joint task force on green hydrogen, CertifHy's direct engagement with Indian stakeholders, and the SECI-H2Global MoU (November 2024). However, no formal mutual recognition agreement exists between GHCI and RFNBO as of March 2026.

H2Global and India

The SECI-H2Global MoU (November 2024) establishes a framework for international trade corridors. H2Global's second auction round (EUR 3 billion, launched February 2025) includes an "Asia" regional lot with a minimum EUR 484 million budget where Indian producers can bid. No specific Indian bidders have been publicly identified, though ACME, AM Green, L&T, and Reliance are likely candidates. H2Global requires RFNBO compliance, so any Indian company participating in both SECI domestic auctions and H2Global tenders would need dual certification.

ISCC EU RFNBO Pre-Certification Arrives March 2026

ISCC formally introduced RFNBO Pre-Certification at its 3rd Technical Stakeholder Meeting on 5 February 2026 (with 230-plus participants). A guidance document was scheduled for release by end of March 2026, with a formal webinar on 27 March 2026.

Pre-Certification is a document-based readiness assessment for Economic Operators at pre-FEED, FEED, or later project stages. It uses qualified auditors from authorised Certification Bodies following the same ISCC EU RFNBOs Audit Procedures as full certification. The assessment covers management systems, traceability, GHG emissions, and renewable electricity sourcing. It results in a Pre-Audit Report but does not result in a certificate or certification decision, and cannot be used for sustainability claims or EU regulatory compliance.

ISCC EU is one of only three EC-recognised voluntary schemes for RFNBOs (alongside CertifHy and RedCert), having received official recognition on 19 December 2024. ISCC's sister company Meo Carbon Solutions offers supporting services including workshops, consulting, eligibility assessments, and pilot audits.

For Indian projects, ISCC RFNBO Pre-Certification provides a way to demonstrate alignment with EU requirements early in development, attract European offtakers, and identify gaps before costly construction decisions. As of March 2026, no Indian company has confirmed initiating ISCC EU RFNBO Pre-Certification, though Bureau Veritas and SGS, both authorised ISCC certification bodies, have significant Indian presence.

The Verification and Certification Services Market

The Indian market for green hydrogen certification services is in early formation. Carbon Check India Pvt Ltd (Noida) is a Validation and Verification Body (VVB) and Certification Body (ISO/IEC 17065), with 2,000-plus GHG projects across 100-plus countries and accreditations including UNFCCC Article 6.4 DOE, Gold Standard, Verra VCS, and AA1000. Its disclosed man-day rate is approximately USD 800 per day (around ₹65,000-70,000), with typical 20-man-day certification projects costing around USD 16,000.

A systematic search across TIC companies (Bureau Veritas, TÜV Rheinland, DNV, SGS), Big 4 firms (KPMG, EY, Deloitte, PwC), Indian consultancies (Consultivo, R3 Sustainability, cKinetics, CRISIL), and law firms reveals that no company currently offers a packaged GHCI gap analysis or readiness assessment product. Several firms have published thought leadership on green hydrogen (KPMG's "India's Green Hydrogen Ambition", EY's "Hydrogen Toolkit"), but none have a productised GHCI compliance offering as of Q1 2026.

Bureau Veritas is notable for having granted RFNBO pre-certification to Hygenco Green Energies under the CertifHy scheme, but this is EU RFNBO, not GHCI. Atmen (Munich) is recognised as a Compliance Technology Provider for CertifHy EU RFNBO, having processed approximately 70,000 data points per 10 MW audit. Atmen does not currently have an India presence.

What to Watch in the Next Twelve Months

Several thresholds will determine how the GHCI certification market develops through 2026-27:

1. First final certificate issuance (expected June-September 2026). The first batch will reveal how the verification bottleneck affects actual issuance timelines and whether the auto-generated provisional certificate flow operates as designed.
2. BEE accreditation pipeline. Additional ACV agencies must be accredited to handle the 158-project pipeline. The pace of accreditation will determine whether the bottleneck eases or hardens.
3. GHCI-RFNBO mutual recognition discussions. The EU-India Green Hydrogen Forum and the India-EU TTC task force are the active channels. Any formal recognition framework would materially change the dual-certification burden for Indian exporters.
4. Water-emissions guidelines finalisation. The February 2026 draft guidelines align with ISO 19870:2023. Final adoption will close one of the remaining methodology gaps in the scheme.
5. CertifHy and ISCC engagement with Indian producers. Both schemes are actively engaging Indian stakeholders. Adoption rates of ISCC RFNBO Pre-Certification by Indian projects through 2026 will signal how seriously Indian developers treat early EU readiness work.

HyGOAT Implications

GHCI creates a mandatory certification obligation for nearly every Indian green hydrogen project that touches government incentives or domestic markets. The infrastructure to support compliance, particularly BEE-accredited ACV capacity, is still being built. Projects that begin readiness work today benefit from a less crowded verifier queue and from the ability to design compliance into project parameters before final investment decision.

The most defensible posture for Indian developers is dual readiness: alignment with GHCI for domestic monetisation and with RFNBO for any export ambition, even speculative. The regulatory gap between India's annual-averaged emission threshold and the EU's evolving correlation requirements creates the kind of complex, rule-based compliance challenge that benefits from structured screening before contractual decisions harden.

For pre-FID projects, the next twelve months are decisive. Project parameters set today will be the parameters audited in 2026-27. Screening against both frameworks during the design phase is materially cheaper than retrofitting at COD.