Introduction

There is a growing acknowledgement of the physical and transitional risks posed by climate change. Climate analysts in India estimate that the country will require approximately US$2.5 trillion by 2030 to meet its Nationally Determined Contributions (NDCs),^[1] and more than US$10 trillion to achieve net-zero emissions by 2070.^[2] According to NITI Aayog’s India Energy Security Scenarios 2047, the country will need nearly US$250 billion annually in energy transition investments through 2047; adaptation needs, particularly in vulnerable sectors such as agriculture, water resources, infrastructure, and ecosystems, could reach up to US$206 billion by 2030.^[3] Despite numerous climate-related commitments and pledges, actual financial flows remain insufficient. Additionally, vulnerable communities on the frontlines of climate change remain deeply exposed. Their ability to adapt remains constrained by limited fiscal space and uncertain access to predictable funding.

These challenges are also reshaping the context within which public finance and fiscal federalism operate in India. As the frequency and intensity of climate change-induced events rise, the need for a resilient and risk-responsive fiscal federal system becomes essential. India’s federal architecture, however, does not conform neatly to conventional models of federalism. Relative to those in classical federations such as the United States, fiscal and administrative authority in India remains more concentrated at the Centre. At the same time, India does not follow the tightly hierarchical model seen in countries such as Germany, where sub-national governments largely function as administrative extensions of the federal state.^[4] Instead, India’s hybrid federal arrangement creates a distinctive governance landscape in which states exercise autonomy in several sectors central to climate action, while the Centre retains substantial control over financial resources, institutional capacity, and regulatory authority across many climate-relevant domains.

Within this framework, climate change governance in India has by both design and necessity been fundamentally sub-national. State governments are the principal drivers of public expenditure on climate-related interventions and account for over 60 percent of total general government expenditure, nearly double the global average.^[5] They also bear primary responsibility for sectors that lie at the heart of climate vulnerability and resilience, including agriculture, water, health, and urban development.^[6] This centrality of states is only set to deepen, as State Action Plans on Climate Change (SAPCCs) are also expected to be financed almost entirely through state budgets.^[7]

These realities place India’s fiscal federal structure at the core of the country’s climate response. Within the broader framework of fiscal federalism, there is growing recognition of the need to embed climate objectives more systematically into intergovernmental fiscal transfer mechanisms.

As the 16^th Finance Commission embarks on releasing its recommendations this year, it faces a critical opportunity to strengthen the alignment between India’s climate commitments and its fiscal architecture. This paper examines the evolution of intergovernmental fiscal transfers in India through the lens of climate change and takes stock of available evidence, policy experience, and stakeholder perspectives, both domestic and international to inform expectations on how intergovernmental fiscal transfers can be designed to more effectively support climate action in India.

Public Money for Public Goods: The Evolution of Ecological Fiscal Transfers and Disaster Risk Financing in India

The devolution of more administrative, political and fiscal power to the sub-national governments has gained momentum in recent years, and intergovernmental fiscal transfers have become an important mechanism for distributing financial resources across different rungs of government to support public spending.^[8] As in many other federal systems, India’s state governments depend significantly on fiscal transfers from the central government to finance their development and climate-related expenditures, particularly those linked to adaptation.^[9] The institutional responsibility for designing and overseeing these transfers rests with the Finance Commission, an autonomous constitutional body mandated to recommend the sharing of tax revenues between the Union and the states (vertical devolution), as well as their distribution among individual states (horizontal devolution).^[10] These transfers comprise tax devolution and various grants, with tax devolution serving as the primary and most predictable source of unconditional fiscal support to the states.^[11]

In recent years, the Finance Commission has also acknowledged the growing importance of environmental sustainability in fiscal policy. Over the past four Finance Commissions (12^th (2005–10), 13^th (2010–15), 14^th (2015–20), and 15^th (2020–26)), forest cover has emerged as a key parameter in determining intergovernmental fiscal transfers.^[12] While earlier commissions relied primarily on grants-in-aid to support forest-rich states, the last two commissions marked a notable shift by integrating forest area as a formal criterion within the tax devolution formula which also includes indicators such as population, geographical area, and income distance.^[13] This evolving recognition of environmental and ecological considerations in fiscal policy sets the stage for a more structured approach for incentive-based conservation.

An ecological fiscal transfer system was established in India when the 14^th FC  added forest cover as one of the criteria to determine tax devolution to the states.^[14] A weightage of 7.5 percent of the divisible  central tax pool was given to the forest  cover criterion to the sub national  governments based on their share in states'  area of 'very dense' or 'moderately dense'  forest cover.^[15] This measure represented one of the largest intergovernmental fiscal transfers for ecological conservation in the world, underscoring India’s commitment to integrating environmental priorities into fiscal governance.^[16]

This criterion was subsequently retained under the 15^th FC, which increased its weightage to 10 percent  in the tax transfer formula to share the  divisible pool of taxes to the sub-national governments during the period 2021–25.^[17] By incorporating forest cover into the criteria for fiscal transfers, the Finance Commissions created incentives for states to preserve and expand forested areas. The idea was to provide additional revenue to compensate states for the opportunity costs of maintaining forests, costs that might otherwise discourage conservation.^[18] However, contentious questions remain regarding its effectiveness. There is a sustained dialogue whether this approach has led to more pro-forest policies, resulted in measurable increase in forest cover, or served as an incentive for states to further increase their forest resources in anticipation of higher fiscal allocations.

Figure 1: Framework for Intergovernmental Fiscal Transfers in India

Source: Authors’ own, adapted from ‘Resilience by Design: A climate risk lens on Fiscal Devolution,^[19]

Intergovernmental fiscal transfers in India are primarily allocated through tax devolution and Finance Commission grants. These grants are intended for states that require additional support and can be conditional or non-conditional, depending on their purpose. The evolution of these grants is especially relevant for India’s disaster finance framework, where Finance Commissions have moved from specific and tied grants to a more structured system for fund allocation. Disaster risk financing, originally introduced by the 2^nd Finance Commission, initially relied on FC grants but was later replaced by dedicated instruments such as the Calamity Relief Fund, the National Calamity Contingency Fund (NCCF), and subsequently the National Disaster Relief Fund (NDRF).^[20] The 13^th Finance Commission then streamlined disaster relief financing by bringing it under a separate, dedicated framework. The National Calamity Contingency Fund (NCCF) and the Calamity Relief Fund (CRF) were then merged into the broader National Disaster Response Fund (NDRF) and the State Disaster Response Fund (SDRF), respectively.^[21] This restructuring enabled a closer alignment between disaster risk finance and the Disaster Management Act, 2005, with the intention of making disaster response more efficient, better coordinated, and easier to deliver on the ground.

The 14^th Finance Commission then recommended that the allocations to the National Disaster Response Fund (NDRF) should be based on expenditure patterns, so that the funds can be allocated to the states in a more effective and efficient manner.^[22] The 15^th Finance Commission, however, moved away from this approach and introduced a more comprehensive way for allocating funds for disaster response and relief. The new approach is primarily based on the Disaster Risk Index measured by combining the likelihood of hazards such as floods, cyclones, landslides, and earthquakes with social vulnerability, especially the proportion of people living below the poverty line.^[23],[24]

Figure 2: Evolution of Ecological Fiscal Transfers and FC Grants

Source: Authors’ own

Limitations of Ecological Fiscal Transfers: The Narrow Scope of the Current Devolution Formula

Despite their potential to align fiscal federalism with environmental objectives, ecological fiscal transfers (EFTs) face challenges that limit their effectiveness as instruments for achieving the environmental and climate objectives. While some empirical studies have indicated a positive relationship between ecological fiscal transfers and an increase in forest conservation efforts^{[25],[26],[27],[28]}, whereas some studies indicate that an increase in forest conservation efforts or overall increase in forest cover might be due to other external factors and supporting programs and schemes like CAMPA that mandates industries to plant trees in exchange for forest land which got diverted for industrial use.^[29] A study released in 2020 also highlighted that although states increased their forestry budgets in absolute terms following the introduction of EFTs, forestry’s share within overall state budgets declined, and states receiving larger EFT allocations did not disproportionately increase their forestry spending.^[30] Taken together, this evidence indicates that the impact of EFTs on forest conservation remains limited and often confounded by parallel policy measures.

There are also challenges associated with the measurement framework of the EFTs. The previous FCs have chosen forest cover (‘very dense’ and ‘moderately dense’) as an indicator for rewarding states on their conservation efforts, however, several studies indicate that it is an inadequate proxy for ecological health and may not cover the actual costs of conservation borne by the states.^[31]   For example, dense forest cover does not differentiate between natural forests and monoculture plantations. It can be achieved through large-scale plantations, including those of exotic species, but such interventions do not address broader ecological objectives, such as biodiversity conservation and ecosystem resilience.^[32] Additionally, a static indicator like forest cover also fails to capture year-on-year changes in forest quality or density.^[33] Such an approach risks rewarding states merely for maintaining existing forest baselines rather than incentivising improvements through afforestation and reforestation activities, or sustainable management practices.

While previous Finance Commissions have acknowledged the limitations of the existing measurement framework for ecological fiscal transfers, there has been limited progress in refining the formula for devolution of funds to the states. This may be because of multiple factors, including the institutional inertia often associated with such long-standing frameworks. However, there remains a strong need and opportunity for including more representative indicators and proxies that better capture the multifaceted value of environment, ecology, and climate in future fiscal devolution models.

Exclusion of Emerging Climate Extremes and Rigid Funding Constraints in Disaster Finance

One of the most pressing challenges in India’s disaster finance framework under the Finance Commission is the exclusion of emerging climate-induced events such as heatwaves and unseasonal rains from the list of notified disasters eligible for full financial assistance under the State and National Disaster Response Funds (SDRF/NDRF).^[34] These two funds together account for approximately 80 percent of India’s total disaster management financing,^[35] however as of March 2025, neither heatwaves nor unseasonal rainfall qualify for direct central support.

India among the most severely affected to rising temperatures, as over a billion people are exposed to heatwaves each year. According to recent estimates, the country also witnessed daily temperatures rising above 40 degree Celsius in 2024, leading to 44,000 reported cases of heatstroke.^[36] A recent study also estimated that heat stress alone could cost India the equivalent of 35 million full-time jobs and reduce GDP by 4.5 percent by 2030.^[37] Despite this, heatwaves remain a largely under-recognised disaster, primarily due to challenges in measuring their impacts and assigning economic value.^[38] Unlike cyclones or floods, which cause visible destruction to infrastructure, heatwaves might lead to invisible or delayed harm to human health. It is therefore important to include heatwaves in the national list of eligible disasters to allow states to utilise funds for related relief measures. Recognising this gap, the Telangana government declared heatwaves as a ‘State-Specific Disaster’. It has also increased ex gratia compensation to INR4 lakh per heat-related death, setting an example for other states but still operating within a constrained financial framework.^[39]

Figure 3: Disaster Risk Financing in India

Source: Author’s own, using data from ‘Resilience by Design: A climate risk lens on Fiscal Devolution’^[40]

Similarly, unseasonal rains, often resulting from shifting monsoon patterns due to climate change, have become a growing threat to agriculture. In late 2024, Odisha witnessed widespread crop damage across 22,791 hectares, affecting approximately 6.66 lakh farmers. The state then declared unseasonal rains as a ‘State-Specific Disaster’ and provided INR291 crores in input subsidies.^[41] However, since unseasonal rains are not recognised as a centrally notified disaster, access to disaster funding remains partial and constrained.

Another issue is the rigid funding structure of the SDRF itself. States are allowed to use only 10 percent of their annual SDRF allocation for state-specific disasters, those not included in the nationally notified list.^[42],[43] Even though states taking proactive measures to include emerging climate hazards as nationally recognised disasters, their ability to fund relief measures is often restricted by this arbitrary ceiling, forcing them to divert funds from other development priorities and interventions.

These cases shed light on a broader structural challenge within India’s disaster finance framework which has not evolved with the ongoing climate crisis. Emerging and intensifying climate induced hazards like heatwaves and unseasonal rainfall are either absent from national policies and frameworks or inadequately funded, leaving states to bear the burden of financing relief measures. As climate extremes become more frequent and severe, this gap further delays timely response and affects vulnerable communities disproportionately.

Integrating Climate Risk, Vulnerability, and Resilience in India’s Federal System

The 2024-25 economic survey recognised India as the seventh most climate vulnerable country in the world as it faces increasing risks from both immediate climate induced events such as floods as well as slow onset events like rising temperatures.^[44],[45] These climate risks are also imposing significant social and economic costs, necessitating the need to shift from a response-based and reactive approach to a more systematic form of building resilience against these climatic shocks. This will not only require more investment in adaptation but also enabling institutions that recognise and respond to various climate risks spread across regions.

The integration of climate adaptation within the broader public finance management system becomes integral as state governments are given the responsibility for responding to climate induced disasters and building resilience against these events. They also bear the burden of financing the ex-ante preparedness and ex-post relief measures. As the state’s fiscal capacities vary, the Finance Commission can play an important role in transferring funds to the vulnerable states for these adaptive interventions. While the 14^th and 15^th  Finance Commissions have made strides toward incorporating an ecological parameter in their fund devolution formula, these inter-governmental fiscal transfers do not reflect a state’s unique exposures, sensitivities and adaptive capacity toward climate shocks.^[46]

In India, a substantial share of adaptation finance continues to be mobilised ex post, following climate-induced disasters, rather than ex ante to strengthen absorptive capacity and reduce future losses. This reactive bias reflects institutional arrangements in which disaster relief and post-event transfers are more clearly defined than mechanisms for anticipatory resilience investments. As most of the finance for adaptation is mobilised via public funding, this design also limits their ability to plan and implement long-term resilience strategies.^[47]

There is also a lack of comprehensive and standardised framework for climate risk and vulnerability assessment within fiscal decision-making. Although India has developed a common framework for assessing climate vulnerability at sub-national level,^[48] this framework does not integrate exposure to climate hazard, adaptive capacity, and fiscal constraints in a manner that can directly inform budgetary allocations. Additionally, lack of a systematic methodology to assess the climate sensitivity and resilience outcomes of public expenditure further constrains the alignment of public spending with climate risk reduction objectives.

Lack of Technical Capacity and Data Information and Management Systems

While forest cover is not a comprehensive proxy for ecological health, its selection as an indicator has been driven largely because of its practicality. It is one of the few ecological indicators for which consistent, comparable and updated data is available at the state level. Any effort to revise the existing devolution formula or to introduce a dedicated grant for climate-related interventions would need to be supported by a robust data base. This may include climate risk and vulnerability assessments, state-level greenhouse gas emissions inventories, and detailed ecological and environmental indicators.^[49] At present, however, such granular and harmonised data are either limited, uneven across states, or entirely unavailable, limiting the development of an evidence-based mechanism for allocating climate-related fiscal transfers.^[50]

Members of the Finance Commission have also highlighted a massive institutional gap in data management. Although each Finance Commission collates extensive data to inform its recommendations, there is currently no common platform to preserve, consolidate, or build upon the data already collected by previous Commissions.^[51] This institutional amnesia further limits continuity in analytical approaches and reduces the scope for progressively refining fiscal allocation frameworks over successive Finance Commission cycles.

Another challenge is the lack of mandatory reporting by states on climate-related public expenditure. The absence of disclosure requirements makes it difficult to track climate spending and align fiscal transfers with actual investment in climate-sensitive sectors.^[52] While India’s ongoing efforts to develop a national climate finance taxonomy may help improve classification and comparability of the expenditures, additional institutional reforms will be required to strengthen transparency, accountability, and the systematic integration of climate considerations into public finance management systems.^[53]

Expectations from the 16th Finance Commission

India’s climate policy framework would benefit from closer alignment with the Finance Commission’s intergovernmental fiscal transfer architecture. In a rapidly evolving climate regime, it is essential that national climate objectives are clearly defined and integrated within fiscal transfer mechanisms in ways that enable effective implementation and create sustained financial incentives for states. This section highlights expectations from the 16^th Finance Commission on strengthening the role of fiscal federalism for climate change in India.

Expanding the Scope of Ecological Fiscal Transfers for Forest Ecosystems Health

The 16^th Finance Commission has an opportunity to rethink how Ecological Fiscal Transfers can be designed to better capture parameters of ecological health. At present, EFTs rely solely on static measures such as forest cover that do not capture the overall health or richness of forest ecosystems. There is growing recognition that inter-governmental fiscal transfers should also include indicators that better reflect the functioning of these ecosystems. These indicators could include measures of biodiversity richness such as species diversity as well as the provision of ecosystem services, including carbon sequestration, water regulation, and soil conservation. Using a broader ecological health index would ensure that states conserving diverse and critical ecosystems are rewarded more meaningfully. Such an approach would not only make fiscal incentives fairer but also encourage states to invest in long-term ecological stewardship rather than focusing only on maintaining forest area.

Case Study: Chennai’s Biodiversity Index

Chennai released its first ever City Biodiversity Index in August 2025 to evaluate their natural wealth, set conservation priorities, and integrate ecosystem health into their broader urban resilience framework.^[54] The index is built on 23 biodiversity related indicators and includes components like native biodiversity in the city (natural areas, native species, invasive species, protected areas, etc.), ecosystem services provided by biodiversity (e.g., water regulation, climate regulation, and parks) and governance and management of biodiversity (e.g., budget, policies, and institutional capacities).^[55]  This index is expected to support a more efficient allocation of public resources towards the protection of existing ecosystems as well as the restoration of degraded natural areas.^[56] Additionally, Chennai’s CBI provides a replicable benchmark that demonstrates how biodiversity and ecosystem services can be measured and integrated into financing decisions, thereby offering a useful reference point for the Finance Commission as it considers more nuanced ecological indicators within the fiscal frameworks.

Case Study: Brazil’s ICMS-E and Ecological Fiscal Transfers

Brazil also offers a relevant example of how intergovernmental fiscal transfers can be designed to incentivise environmental outcomes. States in Brazil levy the Imposto sobre Circulação de Mercadorias e Serviços (ICMS), a value-added tax on goods and services that constitutes the main source of state tax revenue.^[57] Under the 1988 Constitution, 25 percent of ICMS revenues must be transferred to municipalities, with states granted discretion over the allocation criteria for one-quarter of this transfer.^[58]

This flexibility has enabled several states to introduce ecological fiscal transfers, known as the ICMS Ecológico (ICMS-E). By 2020, 18 of Brazil’s 27 states had adopted ecological indicators in their transfer formulas. These indicators go beyond forest cover and include protected areas, indigenous lands, sanitation services, deforestation reduction, fire control, and ecosystem impact of infrastructure.^[59]

Structural Changes in the Allocation of Disaster Risk Funding

The 16th Finance Commission is also expected to reassess the structure of disaster risk financing in light of emerging climate risks. A key expectation is the formal inclusion of heatwaves and other climate-induced hazards, such as unseasonal rainfall, within the list of state-notified disasters eligible for support under the State Disaster Response Fund (SDRF). Recognising these hazards would facilitate more timely access to resources for early warning systems, preparedness measures, and relief efforts.

There is also an expectation that the Commission may review the existing 10 percent cap on the use of SDRF resources for state-specific disasters. Expanding this cap, particularly for climate-induced hazards, could provide states with greater flexibility and autonomy to respond to region-specific climate risks and vulnerabilities.

Performance-Based Transfers for Climate Resilience 

There is also a clear need to view fiscal devolution through the lens of climate resilience. Building adaptive capacity in the form of early warning systems, climate resilient infrastructure, risk assessments and mobilising appropriate financial instruments will largely determine the severity of the fiscal and economic losses when the climate-induced hazards occur.^[60] Therefore, another expectation from the 16^th Finance Commission is the introduction of performance-linked fiscal instruments to support climate resilience. This could be in the form of a dedicated grant for climate resilience, with allocations based on sub-national climate risk and vulnerability assessments. Such an approach would enable more targeted support for adaptation investments in high-risk regions such as Bay of Bengal where impacts of sea-level rise and cyclones are already causing significant and recurring damage. It will also incentivise states to integrate climate risk considerations into sectoral planning and public expenditure decisions.

Case Study: South Africa’s Climate-Responsive Sub-national Planning and Adaptation Finance 

South Africa provides a relevant global example of how climate considerations can be integrated within sub-national policies and financing frameworks. Under the National Climate Change Adaptation Strategy (NCCAS), provincial and municipal governments are required to integrate disaster risk reduction and climate adaptation measures into their Integrated Development Plans.^[61] This institutional requirement ensures that climate risks are considered in development priorities, infrastructure planning, and public expenditure decisions.

Building on this framework, the South African government announced the establishment of a Climate Change Response Fund in 2024, designed to channel funds toward climate adaptation, with a particular focus on regions and sectors facing high levels of vulnerability.^[62]

Data Systems and Technical Capacity for Climate Risk Assessment

Strengthening data infrastructure 

The effectiveness of climate-responsive fiscal transfers will depend on the availability of robust data and analytical capacity. The 16^th Finance Commission is therefore expected to place greater emphasis on strengthening climate and ecological data infrastructure. This includes the development of systems for transparent reporting and regular updating of ecological and climate-related data at multiple rungs of governance such as state, district, city, and gram panchayat.

The Commission could also support the creation of a common, interoperable platform for sharing ecological, social, economic data and projections. Such a platform would enhance consistency across assessments and improve access to information for policymakers, researchers, and implementing agencies. 

Enhancing Transparency and Accountability in Climate-Related Public Expenditure 

Improving the tracking and effectiveness of climate- related expenditure should be a central concern for the 16^th Finance Commission. The Commission should introduce mechanisms to enhance disclosures and reporting of climate finance and adaptation outcomes. This mandatory and standardised report could further improve transparency, accountability and strengthen the link between fiscal transfers and climate objectives. 

Building Collaborative Capacity for Climate-Smart Fiscal Planning 

Finally, the 16^th Finance Commission should also strengthen institutional capacity at the sub-national level, particularly through State Finance Commissions (SFCs). This could involve introducing collaborative capacity-building frameworks that involve intermediaries such as universities, think tanks, and civil society organisations. These intermediaries can support SFCs by translating complex climate jargon, data and assessments into actionable insights, thereby enhancing the ability of sub-national institutions to integrate climate considerations into fiscal planning and decision-making.

Conclusion

Climate change has now evolved into a systemic risk that is reshaping economic systems, governance structures, and the landscape within which India’s fiscal federalism operates.^[63] As climate impacts intensify, the existing foundation of inter-governmental fiscal transfers is being put to test. While previous Finance Commissions have taken important steps by recognising ecological and environmental impacts and streamlining disaster risk finance, these efforts remain insufficiently aligned with the scale and nature of emerging climate risks.^[64]

This analysis highlights three persistent gaps. First, ecological fiscal transfers rely on narrow and static proxies that fail to reflect the overall health of forest ecosystems. Second, disaster financing remains largely reactive, with slow-onset and emerging risks such as heatwaves and unseasonal rainfall not recognised as state notified disasters. Third, inter-governmental fiscal transfers do not reflect differences in climate exposure, vulnerability, and adaptive capacity across states, limiting their role as instruments of risk sharing and resilience building.

The 16^th Finance Commission therefore faces a critical opportunity. By integrating climate risk, resilience, and ecological value more explicitly into the tax devolution formula and grant design, it can help reorient India’s fiscal federal system and make the broader public finance management system more climate responsive. Finance Commission transfers have the ability to do more than simply balance fiscal capacities across states. If designed well, they can also act as powerful policy tools by shaping incentives for climate-resilient growth and encouraging states to pursue sustainable development pathways.

Public finance alone, however, will not be sufficient. Climate-responsive fiscal design must also play a catalytic role in mobilising private finance by reducing risk, improving project bankability, and crowding capital into climate resilience and green infrastructure. Predictable transfers, credible incentives, and robust institutions are essential for signalling long-term commitment and unlocking private investment at scale.^[65]

India’s growth story and its system of fiscal equalisation can no longer be separated from the realities of climate risk. If climate considerations remain at the margins of fiscal transfers, the consequences will be predictable. Regional inequalities will widen, public finances will come under greater strain, and long-term growth will weaken. Climate-responsive fiscal federalism, therefore, is not a specialised environmental reform. It is a necessary condition for economic stability and for advancing India’s development ambitions in a warming world.

Gopalika Arora is Deputy Director, Centre for Economy and Growth, Observer Research Foundation.

Nilanjan Ghosh is Vice President, Development Studies, Observer Research Foundation.

All views expressed in this publication are solely those of the authors, and do not represent the Observer Research Foundation, either in its entirety or its officials and personnel.

Endnotes

• Indian Economy
• Economics and Finance
• Developing and Emerging Economies
• India
• 16th Finance Commission
• climate adaptation funding
• climate finance India
• energy transition investment
• fiscal federalism India
• intergovernmental fiscal transfers
• NDCs
• net-zero 2070
• SAPCCs
• sub-national climate governance

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