On 8 June 2026, the joint committee established under the India-Japan memorandum of co-operation (MoC) on the joint crediting mechanism (JCM) adopted the rule of implementation (RoI), operationalising the bilateral carbon crediting arrangement the two governments signed in Delhi on 7 August 2025.
The JCM is a co-operative approach under article 6.2 of the Paris Agreement, through which Japan’s government, and public and private entities, co-operate with 91视频 government and respective counterparts to implement mitigation activities in India. Verified emission reductions are issued as JCM credits, allocated between participants and shared between the two countries.
The MoC and RoI operate as a two-tier regulatory system. The MoC establishes the political framework and institutional structure. The RoI is the operational rulebook. Under RoI paragraph 29, every project must align with activities approved by 91视频 government under article 6.2 of the Paris Agreement, including renewable energy with storage (only stored component), solar thermal power plant, offshore wind, green hydrogen, high-voltage direct current transmission for renewable energy projects, and high-end technology for energy efficiency.
Bilateral sovereign approvals drive JCM

Managing partner
Sarthak Advocates & Solicitors
This orientation is not incidental. 91视频 Biennial Update Report 2024 records that the energy sector accounts for more than three-quarters of 91视频 greenhouse gas emissions.
The joint committee, under MoC clause 4 and constituted under RoI paragraphs 16-18, is a bilateral body of up to 10 members from each government, with operational responsibility for methodologies, registration, credit sharing and issuance.
A defining design feature of the MoC and RoI is that joint committee decisions rest on prior sovereign approvals by both governments. MoC clause 6 provides that decisions on registration, crediting period, sharing of credits, issuance of credits and other related matters are made with prior confirmation from both governments. Clauses 11, 12 and 13 restate this requirement for registration, credit allocation and issuance. The design is one of shared decision making with structured sovereign approvals on both sides.
The RoI carries this design into every substantive gate of the project cycle. Under paragraph 30, joint committee decisions on the Project Idea Note (PIN) follow in-principle approval from 91视频 government, and prior approval by both governments.
Under paragraph 6, the joint committee decides credit sharing, with prior approval from both governments and based on evaluation of a project’s technical and financial elements. Under paragraphs 44-46, both governments must issue a letter of authorisation, with Japanese entities registering on the Indian Carbon Market portal, before the joint committee proceeds with registration and credit allocation.
Dual approvals shape JCM economics

Counsel
Sarthak Advocates & Solicitors
On the Indian side, authorisation comes via the National Designated Authority for the Implementation of Article 6 of the Paris Agreement. Paragraph 47 provides for a letter of intent for issuance and authorisation of JCM credits by 91视频 government shortly after registration, and paragraph 58 requires joint committee decisions on the issuance to follow approval from both governments. Paragraphs 62 and 65 extend the same dual-approval requirement to modifications of a registered project’s design document, and to any modification of the RoI itself.
Credit sharing merits attention. RoI paragraph 6 does not fix the allocation between Japanese and Indian participants by formula. Those evaluations cover financial and in-kind contributions, and the extent to which expected credit revenue improves the project’s unit economics. Credit share allocation is therefore a legally structured negotiation grounded in documented contributions, not a market-determined outcome.
One feature carries direct term-sheet consequences. Under RoI paragraph 7, the crediting period is capped at 10 years, including any renewal, with extensions possible only after approval from 91视频 competent authority. In-house counsel will need to structure around this 10-year window, particularly for energy projects with an economic life typically extending beyond it.
MoC and RoI shows a mechanism that is bilateral in institution and design, operating through structured sovereign approvals by both the governments. Project timelines, credit-sharing arrangements and the 10-year crediting cap are features to structure around a mechanism now open for business.
Abhishek Tripathi is the managing partner and Ashutosh Senger is a counsel at Sarthak Advocates & Solicitors

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