Green Credits and BRSR Principle 6: What Indian Companies Can Report

ESG, CSR, and finance teams at Indian companies are being asked for a number that planting-day albums cannot supply: how many Green Credits the company generated or procured. SEBI placed that question in BRSR Principle 6. A survival percentage, a green-belt photo set, or a modeled tonne of CO₂e does not answer it.

This guide is for those teams, and for the agencies that keep their plantation files. It reads the SEBI circular and the Green Credit notifications, then separates the credit count from plantation and green-belt evidence. It is a reading of public instruments. It is not legal, accounting, or assurance advice. The circular, the gazette text that applies to your parcel, and your assurance provider control the filing.

Takeaways

• SEBI circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42 of 28 March 2025 adds an eighth leadership indicator to BRSR Principle 6. It asks how many Green Credits were generated or procured by the listed entity, and by its top ten value-chain partners. The circular's subject calls this a voluntary disclosure. The section applies to BRSR disclosures for FY 2024-25 onwards.
• A Green Credit is not a carbon credit. The Green Credit Rules, 2023 state that the programme is independent of the Carbon Credit Trading Scheme, 2023.
• For tree plantation, G.S.R. 592(E) of 29 August 2025 is the current calculation method. A claim report is eligible after minimum five years of restoration on a degraded forest land parcel and a minimum canopy density of 40%. One Green Credit is awarded for each new tree older than five years, and only the Administrator may issue it after a designated agency's evaluation.
• Keep three labels in the working paper: CLAIM (what the company declares), OBSERVATION (what was measured on the ground), and ESTIMATION (what was modeled). A planting register is not a Green Credit certificate.
• Aranyix provides audit-prep evidence and modeled estimates only. It does not issue, verify, register, or trade Green Credits, Verra, Gold Standard, or any carbon credits.

What Principle 6 actually asks

Principle 6 of the Business Responsibility and Sustainability Report is the environmental principle: businesses should respect and make efforts to protect and restore the environment. Plantation stories often land in its narrative. From FY 2024-25, Green Credits have their own line.

SEBI's circular of 28 March 2025 modifies the master circular for the LODR Regulations. In Principle 6, Annexure 16 of that master circular, it adds a leadership indicator in this format:

8. How many Green Credits have been generated or procured: a. By the listed entity b. By the top ten (in terms of value of purchases and sales, respectively) value chain partners

Two limits follow from that sentence.

The unit is Green Credits generated or procured. It is not saplings planted, hectares greened, a survival percentage, or a modeled removal. If the Administrator has not issued a credit, there is nothing yet to report as generated. If you do not hold an instrument that shows procurement, do not invent a procured count. "Not available" and "nil" are different statements. Use nil only when you have checked and the count is zero.

The value-chain line is the top ten partners by value of purchases and the top ten by value of sales, respectively. It is not a request to estimate credits across the whole supply chain. If a partner has not given you a figure, the working paper should say the figure was not received. Do not fill the cell from their plantation photographs.

The circular's subject describes this as a voluntary disclosure on green credits. The same section says the indicator shall be included and that the section applies to BRSR disclosures for FY 2024-25 and onwards. Quote both when you brief the board. This guide does not choose between them. Your company secretary and assurance provider apply the format the exchange expects this year.

The rest of that circular, on value-chain ESG scope and on assessment versus assurance, is outside this note.

A Green Credit is not a carbon credit

The Green Credit Rules, 2023 were notified on 12 October 2023 as S.O. 4458(E) under the Environment (Protection) Act, 1986. The preamble states that the Green Credit programme is independent of the carbon credit under the Carbon Credit Trading Scheme, 2023. An activity that generates a Green Credit may also have climate co-benefits, and the rules say that activity may also obtain a carbon credit under that scheme. The two units stay separate. A Verra, Gold Standard, or other carbon-credit serial does not go in the Green Credit cell, and a Green Credit does not go in a carbon-credit account.

Rule 3 defines a Green Credit as a singular unit of an incentive for a specified activity that delivers a positive impact on the environment. Rule 7 names the Indian Council of Forestry Research and Education (ICFRE) as the Administrator. Rule 13 provides for a designated agency to verify activities and report to the Administrator. Rule 4(7) says that, on a verifying report, the Administrator shall grant a certificate of green credit. Rule 10 provides for a Green Credit Registry that registers activities and issues credits. That registry is the programme's registry. A company's plantation spreadsheet is not it.

Rule 14 says participation is voluntary. Rule 4 lists several activities, including tree plantation to increase green cover. Water, waste, mangroves, and the other listed activities have their own methodologies when the Central Government notifies them. This guide stays on tree plantation, because that is the activity companies try to connect to plantation and green-belt files.

What must be true before a tree-plantation credit exists

On 22 February 2024, S.O. 884(E) notified a methodology for calculating Green Credit for tree plantation. Paragraph 10 of that notification calculated one Green Credit per tree grown on the assigned land, subject to a minimum density of 1,100 trees per hectare, on the Forest Department's certificate of completion.

G.S.R. 592(E), dated 29 August 2025, supersedes S.O. 884(E) except for things already done or omitted before that supersession. For tree plantation, read the 2025 methodology as the current calculation text, and read paragraph 6 before you assume an older parcel is untouched.

In plain language, the 2025 paragraphs that decide whether a credit exists are these.

1. After minimum five years of restoration on the degraded forest land parcel, and after a minimum canopy density of 40%, the applicant may submit a claim report in the Administrator's format and must pay the verification fee the Administrator specifies in consultation with the Central Government.
2. The credit is calculated from vegetation status, including the change in canopy density and the number of surviving trees.
3. Issuance requires that 40% canopy density in the degraded forest land parcel. One Green Credit is awarded for each new tree older than five years.
4. On the claim report, the Administrator, based on evaluation and verification through designated agencies, may generate and issue the credit against those criteria. "May" is the notification's word. A claim report is not itself an issuance.
5. Green Credit generated for compensatory afforestation or tree plantation under the programme shall be non-tradable and non-transferable, except for a transfer between the holding company and its subsidiary companies.

Paragraph 6 is the transitional case. Where the applicant had already deposited payment against the Administrator's demand, and that payment was recorded on the Green Credit portal (https://www.moefcc-gcp.in/) under S.O. 884(E), implementation modalities for that land parcel continue to be governed by the 2024 notification. Calculation of the credit, and its usage, follow the criteria in the 2025 notification. Match your portal record to that paragraph before you choose which sentences apply. This guide cannot do that match for you.

Paragraph 7 says a Green Credit generated under the programme may be exchanged once, for any of these purposes: compensatory afforestation compliance where forest land is diverted for non-forestry purposes under the Van (Sanrakshan Evam Samvardhan) Adhiniyam, 1980 and its rules and guidelines; a corporate social responsibility requirement under law in force, based on the cost incurred for forest restoration; or a tree-plantation requirement that fulfils a condition of a project approval under law in force. Paragraph 8 says that once exchanged for any of those purposes, the credit is extinguished to the extent it was used, and cannot be used again to that extent.

Paragraph 9 says Green Credit generated in lieu of tree plantation under the rules may be used for reporting under an environmental, social, and governance leadership indicator, as per the law in force. That is the bridge to the BRSR line. The bridge carries the credit, not the planting register.

The 2023 rules still say, in rule 2, that the programme generates green credit which shall be tradable on a domestic market platform, and the proviso says that green credit generated or procured to fulfil an obligation under any law shall not be tradable. The 2025 methodology is the later, activity-specific text, and it says tree-plantation credits are non-tradable except for the holding-company transfer above. Put both texts in front of counsel if someone proposes a trade. Do not describe these credits as traded in the BRSR note.

Three labels for the working paper

Use the same three words a plantation audit uses, so a reviewer can see what kind of statement each row is. Plantation audit freezes a planting claim and sets it beside field observations. The labels below are the disclosure version of that habit.

Label	Meaning	Belongs in the Green Credit cell?
CLAIM	Declared by the company. "We generated N Green Credits" is a claim, and it needs the Administrator's certificate or registry entry for that N. "We planted these saplings" is a separate claim.	Only the credit claim, and only for credits actually generated or procured
OBSERVATION	Measured. A GPS point, a dated photo, an alive / dead / replaced count, a canopy reading with its method and date.	No. Observations support a claim report to the Administrator. They are not the credit
ESTIMATION	Inferred. Modeled biomass or CO₂e, or a satellite flag used to choose which block to walk.	No. Label the figure as an estimate and keep it in its own column

A survival percentage is an observation only when the counts behind it were measured, the denominator is the saplings actually planted, and the survey date is stated. The formula and the usual mistakes are in the tree survival rate formula. That percentage still does not enter the Green Credit cell. Under the 2025 methodology the credit depends on canopy density and on surviving trees older than five years, as verified for the Administrator, not on a 12-month CSR survival rate.

Modeled CO₂e stays an estimation even when the arithmetic is careful. It is not a Green Credit and it is not a carbon credit.

Plantation and green-belt evidence stay in their own file

Most factory green belts, mine belts, and CSR planting blocks are not degraded forest land parcels inside this programme. They still need evidence, because Principle 6 reviewers and clearance inspections ask where the trees are and whether they lived. The stack for that question — geo-tags, programme tags, survival, and an export — is set out in BRSR plantation evidence for Principle 6.

Keep the two files side by side and do not merge them.

• Green Credit file. Parcel ID as recorded on the Green Credit portal, demand and payment references, claim-report date, designated-agency report if you have a copy, and the Administrator's certificate or registry entry. The count in leadership indicator 8 ties to that entry.
• Plantation or green-belt file. Your block ID, boundary, species, planting date, geo-tagged observations, survival resurvey, and the EC, consent, or CSR code the block serves. This file can support other Principle 6 working papers. It does not fill indicator 8 unless the Administrator has issued credits for that parcel.

If both exist, store both IDs on the row so a sample can tell them apart. A green-belt condition in an environmental clearance is answered with the plantation file. It is not answered by relabelling the belt as a Green Credit.

Where a programme already uses acoustic biodiversity monitoring, a recording can sit with the plantation file as an optional observation of fauna at that site. It is not a canopy measurement, not a surviving-tree count, and not a Green Credit. It does not verify a credit.

What to hand finance, and what to leave out

Finance will see two different numbers and will want one. Give them the split.

The credit count is the generated or procured figure that traces to issuance or to a permitted transfer or exchange. Paragraph 7's CSR use is based on the cost incurred for forest restoration, and paragraph 8 extinguishes the credit to the extent it is used. Whether any of that is recognised in the financial statements is a question for your statutory auditor. This guide does not answer it.

The plantation cost is the spend on saplings, labour, and maintenance for a block you operate. That spend can be real while the Green Credit count is still nil, because five years and a 40% canopy have not passed, or because the block was never in the programme.

Leave these out of the Principle 6 credit cell:

• Saplings planted, pits dug, or a proposal target
• A survival percentage, including a strong one
• Modeled CO₂e or any figure labelled as a carbon credit
• Verra, Gold Standard, or other registry serial numbers
• Credits you expect to claim after the five-year mark
• A partner's planting photographs offered as that partner's credit count
• A green-belt compliance status from an EC letter

A checklist before the number goes into BRSR

• The indicator text in the file matches the 28 March 2025 circular, including the listed entity and the top ten value-chain partners by purchases and by sales.
• Every credit in "generated" has an Administrator certificate or registry entry, with the date and the parcel ID.
• "Procured" is either nil, not available, or tied to a holding-company / subsidiary transfer or other instrument your counsel has matched to the rules. It is not an assumed market purchase.
• Parcels with a payment already recorded on the Green Credit portal under S.O. 884(E) are flagged so paragraph 6 of G.S.R. 592(E) can be read against them.
• Planted counts, survival, and modeled CO₂e sit in other columns, each marked CLAIM, OBSERVATION, or ESTIMATION.
• Green-belt and CSR blocks that are outside the programme are tagged to their own condition or project, not to a Green Credit.
• The methodology note cites G.S.R. 592(E) and states known gaps: parcels under five years, canopy not yet measured, credits not issued.
• No customer anecdote and no borrowed number fills a gap.

Where Aranyix fits

Aranyix keeps the plantation side of this file: a geo-tagged record of what was planted, survival resurveys, dated photos, and an export an assurance team can sample. Where you choose acoustic biodiversity monitoring, that recording can travel as an optional related observation with the same block. Modeled figures, where the export shows them, stay labelled as estimates.

The BRSR workflow for that evidence pack is on BRSR and ESG evidence. Checking a planting claim against ground observations is the plantation audit workspace. Neither workflow issues a Green Credit.

Issuance stays with the Administrator, after a designated agency's verification, under the Green Credit Rules and the methodology that applies to the parcel. BRSR filing stays with your company and your assurance provider. Portal uploads stay with the organisation that holds the login.

Important — honesty box Aranyix provides audit-prep evidence and modeled estimates only. Aranyix does not issue, verify, register, or trade Green Credits, Verra, Gold Standard, or any carbon credits. Aranyix is not a registry, not a certification body, and not a government-approved tool. Aranyix does not file on PARIVESH or e-Green Watch, and it does not file on the Green Credit portal for users. A CLAIM is what you declare. An OBSERVATION is what was measured. An ESTIMATION is what was modeled. The Administrator's certificate is the issuance record. A field export is not that certificate.

Sources

• SEBI, circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42, 28 March 2025, "Measures to facilitate ease of doing business with respect to framework for assurance or assessment, ESG disclosures for value chain, and introduction of voluntary disclosure on green credits," including the Principle 6 leadership indicator on Green Credits and its applicability to BRSR disclosures for FY 2024-25 onwards: sebi.gov.in.
• Ministry of Environment, Forest and Climate Change, Green Credit Rules, 2023, S.O. 4458(E), 12 October 2023, including the statement that the programme is independent of the Carbon Credit Trading Scheme, 2023, and rules 2, 3, 4, 7, 10, 13, and 14: egazette.gov.in PDF.
• MoEFCC, methodology for calculation of Green Credit in respect of tree plantation, S.O. 884(E), 22 February 2024, paragraph 10 (one Green Credit per tree, subject to a minimum density of 1,100 trees per hectare, on the Forest Department's completion certificate). Superseded by G.S.R. 592(E) except as that later notification preserves: moef.gov.in PDF.
• MoEFCC, methodology for calculating Green Credit in respect of tree plantation activity, G.S.R. 592(E), 29 August 2025, paragraphs 1 to 9: egazette.gov.in PDF.
• Green Credit portal named in paragraph 6 of G.S.R. 592(E): moefcc-gcp.in.