India’s Climate Transparency Gap: Why Delay Undermines Credibility

Nothing exposes a credibility gap faster than missed deadlines. In this case, it is India’s failure to deliver its first Biennial Transparency Report (BTR) just as the world ushers in a ‘New Era of Climate Transparency’. This delay is more than procedural; it reflects deeper structural challenges and raises critical questions about India’s readiness to meet rising international expectations. These steps toward enhanced transparency are not only critical for fulfilling international reporting obligations but are equally vital for India’s domestic climate strategy. In fact, current timelines suggest that reporting requirements may remain unmet until 2026. As the country expands carbon markets and performance-linked incentive schemes, credibility depends on accurate, verifiable, and publicly accessible data. Without it, risks of double-counting, weak price discovery, and malpractice in offset projects threaten active emission reduction goals. Transparency is equally vital for aligning climate finance with national priorities, revealing where interventions succeed, where gaps persist, and where funds can be most effective. Yet India’s latest submissions to the UNFCCC point in the opposite direction, exposing the very weaknesses that undermine both its market ambitions and its climate credibility.

Transparency is equally vital for aligning climate finance with national priorities, revealing where interventions succeed, where gaps persist, and where funds can be most effective.

The Current State of Transparency in India

While considering India’s latest submission, the fourth Biennial Update Report (BUR), several key shortfalls can highlight India’s misalignment with the new standards required under the Enhanced Transparency Framework. Under this regime, Parties (except SIDS and LDCs) are now required to submit Biennial Transparency Reports (BTRs), which demand far greater rigour than BURs. Provisions once “encouraged” are now mandatory, with expanded coverage across timeseries, projections, pollutants, and topics. Beyond the GHG inventory (now mandated to follow 2006 IPCC standards), BTRs must also include a National Inventory Report with National Inventory Document (NID) and Common Reporting Tables, reports on climate impacts, progress on NDCs, capacity, financial and technological needs, uncertainty and completeness assessments, and data quality assurance plans. These additions transform BTRs from procedural submissions into substantive accountability tools. Against this backdrop, India’s continued reliance on BURs underscores capacity gaps and limited transparency.

The lack of transparency and avenues for independent verification reflects a systemic disconnect between India’s domestic reporting processes and the enhanced requirements of the global regime.

The deficiencies are evident in the data itself. In sectors such as Energy, Waste, Land Use, Land-Use Change and Forestry, and Agriculture, India has not provided sector-level estimates for four of the six mandated gases. Where data is available, gaps remain, with several subsectors marked as “not occurring,” pointing to absent measurement or inability to estimate emissions. The BUR relies on inputs from 30 government agencies, 25 organisations, and 21 research institutes, yet their outputs are rarely accessible in analysis-friendly formats, even at a granular level. Details on collection, collation, and methodologies are often missing, undermining accountability. Most critically, institutional fragmentation results in non-standardised and disjointed data systems. Even where granular data exists (e.g., petroleum use data or coal statistics), it is not integrated into a unified, publicly accessible platform. The lack of transparency and avenues for independent verification reflects a systemic disconnect between India’s domestic reporting processes and the enhanced requirements of the global regime. These disconnects, their causes and their consequences exist in plain sight.

India’s Efforts towards Raising Domestic Standards of Transparency

At their core, the capacity constraints emerge from deficiencies that exist in the systemparticularly in funding, digital infrastructure, human capital, and standardisation of processes. These gaps fuel institutional fragmentation and procedural delays, undermining coordination, comparability, and efficiency. The problem is compounded by the absence of standardised aggregation practices. Where a multitude of agencies produce granular and unregulated data, the systemic machinery is bound to stagger. While long-term solutions lie in securing funding, skilled personnel, and centralised systems, the immediate priority is access and aggregation. This demands a fundamental rewiring: building stronger pathways for institutional coordination, standardising reporting norms for data collection and submission, and ensuring that raw, source, and processed data are publicly accessible.

The next steps are clear. India’s limited alignment with the world’s new transparency era has prompted a closer scrutiny of the underlying structural constraints. To address these gaps, it has launched major capacity-building initiatives with external support. The project “Capacity-building for Establishing an Integrated and Enhanced Transparency Framework for Climate Actions and Support Measures”, led by the Global Environment Facility (GEF) and the United Nations Development Programme (UNDP), is expected to conclude in 2026. In parallel, the same institutions are backing the preparation of India’s first Biennial Transparency Report (BTR), also projected for 2026. Together, these initiatives have secured  US$ 3.8 million and US$ 2.1 million in funding, partly drawn from the Paris Agreement’s Capacity Building Initiative for Transparency (CBIT). They propose institutional mechanisms such as strengthened Monitoring, Reporting, and Verification (MRV) systems, a National Climate Registry, and two digital platforms: the National Institutional Coordination System (NICS) and the National Inventory Management System (NIMS), both formally announced in India’s Fourth Biennial Update Report.

India’s limited alignment with the world’s new transparency era has prompted a closer scrutiny of the underlying structural constraints.

NIMS, in particular, is envisioned as a centralised digital inventory supporting reporting under the Enhanced Transparency Framework, with trackable, verifiable data on greenhouse gas emissions to improve accuracy and consistency. On the other hand, the NICS initiative is meant to be an imperative system to ensure timely, accurate and verifiable data collation. Details on the designs, integration, real-time capacity, and public accessibility remain limited. For NIMS to be more than a passive repository, it must deliver granular, sector-wise data on emissions, mitigation methods, and timelines. This is critical for tracking progress toward India’s Nationally Determined Contributions (NDCs). NICS is placed to address the problems caused by the current disaggregated approach that fuels roadblocks like red tape, bureaucracy and data errors. For India to be equipped with a national aggregated digital repository of information, smooth communication and coordination is paramount in ensuring complete transparency,i.e., transparency, not simply in data, but also in source.

If effectively implemented, these systems could transform India’s transparency architecture from a compliance tool into a strategic asset. Establishing such a robust framework is not merely procedural; it is essential for India’s participation in global carbon markets, for attracting climate finance at scale, and for ensuring that domestic climate action is both measurable and meaningful. In fact, transparency frameworks influence India’s larger position in global climate discourse. Placed in the largely multilateral scenario of climate discourse, transparent data reporting fuels global cooperation and trust. Considering this, India’s position as a leader in climate action within the Global South must establish transparency in climate reporting as a non-negotiable part of its climate journey.

Diya Shah is a Research Assistant with the Centre for Economy and Growth at the Observer Research Foundation.

• Climate Change
• India
• biennial transparency report
• biennial transparency report india
• climate transparency
• climate transparency india
• india BUR4
• Paris Agreement

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