Compliance Market — TerraNova

India CAFE 2027 — Fleet Efficiency & the OEM Credit Market

Targets, Super-Credits, Credit Trading & the Escalating BEE Buyout

India's Corporate Average Fuel Efficiency norms set a mass-based fleet CO₂ target for every passenger-vehicle manufacturer. The Ministry of Power's official CAFE 2027 draft — published 16 July 2026, effective 1 April 2027 — adds a codified escalating buyout, bilateral credit trading and a split 3 + 2 compliance block, turning fleet planning into a traded position.

Market Snapshot ● Draft — Objections Open
Effective From
1 Apr 2027
Buyout by FY32
₹4,500/g
Compliance Block
3 + 2 yrs
Vehicle Category
M1
Market Type Fleet-Average Credit & Debit
Designs the Scheme BEE (Ministry of Power)
Enforces MoRTH
Tests & Certifies ARAI
Legal Basis EC (Amendment) Act, 2022
CAFE-II Penalties Levied, FY23–25 ₹2,728 Cr — 9 OEMs
113 g
CAFE-II Baseline, to FY27
78.9 g
FY28–32 Reference Target
1,229 kg
Mass-Curve Pivot
3.0×
BEV Super-Credit
15
Passenger-Vehicle OEMs
Market Mechanics

How India CAFE Works

CAFE is not a cap-and-trade market. Each manufacturer is judged on the sales-weighted average CO₂ of everything it sells in a reporting year, against a target derived from the kerb mass of that same fleet. Sell heavier vehicles and the target loosens; sell lighter ones and it tightens. Beat the target and the manufacturer accrues credits, miss it and it accrues debits.

Three institutions split the work. BEE, under the Ministry of Power, designs the scheme and sets the target curve. MoRTH enforces it. ARAI tests and certifies the per-model CO₂ values that feed the fleet average. The legal foundation and the penalty schedule sit in the Energy Conservation (Amendment) Act, 2022.

What changed on 16 July 2026 is the market layer. The Ministry of Power's official draft notification, F. No. 10/3/2021-EC, replaced the consultation-stage figures that circulated through 2025 and early 2026 with a numbered document containing three genuinely new provisions: an escalating BEE buyout, bilateral credit trading in place of EU-style pooling, and a split 3 + 2 compliance block.

The draft was opened for objections for 21 days, so provisions may change before finalisation. The mass-based target formula and the year-by-year curve carry over unchanged from the earlier 25 September 2025 draft.

December 2022
Energy Conservation (Amendment) Act
Legal foundation for fuel-efficiency obligations and the Section 26 penalty schedule, read with Sections 27–28.
25 September 2025
BEE Consultation Draft
First CAFE 2027 draft — the mass-based target formula, the year-by-year c-value curve in L/100 km, and the Table 3 super-credit multipliers.
March 2026
Enforcement Lands — and AIS:175 Publishes
₹2,728 Cr in CAFE-II penalties levied on 9 OEMs for FY23–25, ending years of soft enforcement. ARAI publishes AIS:175, the WLTP test standard.
16 July 2026
Official CAFE 2027 Draft Notified
Ministry of Power publishes F. No. 10/3/2021-EC — escalating BEE buyout, bilateral credit trading, 3 + 2 block, and a formal 12-technology off-cycle menu. Open for objections for 21 days.
1 April 2027
CAFE 2027 Takes Effect — M1 Category
The new target curve applies to M1 passenger vehicles. Targets remain on the MIDC basis until MoRTH triggers the WLTP cycle for CAFE and MoP notifies the conversion factor.
FY28–30, then FY31–32
First 3-Year Block, Then a 2-Year Block
Credits and debits sit in a passbook and carry forward within the block. Penalty is assessed at block end on the entire block sales, after credits are settled. Anything unsettled at block-end lapses.
Targets & Scope

The Mass-Based Target Curve

Every manufacturer's target is a function of its sales-weighted kerb mass, pivoting on a reference mass. The official draft moved that pivot to 1,229 kg, with a reference target of about 78.9 g CO₂/km across FY28–FY32 — down from the CAFE-II baseline of roughly 113 g CO₂/km that runs through FY27.

Mass-Linked, Not Absolute

The target is set by the fleet's sales-weighted kerb mass against a 1,229 kg pivot. A heavier fleet earns a looser target, a lighter fleet a tighter one — which is why the mass-curve slope is the central fault-line between small-car and SUV-heavy manufacturers.

One Curve, Two Blocks

The reference target of about 78.9 g CO₂/km applies across FY28–FY32, but compliance is assessed in two blocks — three years to FY30, then two to FY32 — not year by year.

M1 Passenger Vehicles

The draft applies to the M1 category — passenger vehicles carrying up to eight people besides the driver. Small-volume manufacturers are exempt from the penalty provisions.

MIDC Now, WLTP Pending

Targets stay on the MIDC cycle. Dual MIDC and WLTP declaration began 1 April 2026, and ARAI published AIS:175 in March 2026 — but the CAFE-specific WLTP switch needs a MoRTH notification and a MoP conversion factor, neither of which has been issued.

Penalty on Block Sales

Penalty is computed after credits are settled, as total debit divided by block sales multiplied by the 23.7135 petrol-equivalent factor, under Section 26 read with 27–28. Proceeds split 90/10 between the States and the Centre.

Enforcement Is Now Real

In March 2026 the regulator levied ₹2,728 Cr in CAFE-II penalties across 9 OEMs for FY23–25. Climate Decode's five-year model brackets industry-wide CAFE 2027 exposure at roughly ₹8,000–15,000 Cr for FY28–32.

Market Design

The Credit Market, Priced Year by Year

The official draft turns CAFE from an annual filing exercise into a traded position. A surplus manufacturer's credit is a genuinely saleable asset; a debit has a known, rising price. Timing is now itself a cost.

The BEE Buyout — Codified & Escalating

A manufacturer can offset a debit by buying credits from BEE at a price that rises every year. A gram left unsettled costs 80% more in FY32 than in FY28 — the rising price deliberately rewards trading and banking early.

FY 2028 ₹2,500 / g
FY 2029 ₹3,000 / g
FY 2030 ₹3,500 / g
FY 2031 ₹4,000 / g
FY 2032 ₹4,500 / g

Super-Credits — Confirmed & Extended

Low-carbon powertrains count for more than one vehicle in the fleet average. Effective volume is Nᵢ = vᵢ × nᵢ, so the multiplier scales the whole sales line, not just the emissions figure.

BEV / REEV — Battery electric and range-extended electric vehicles. 3.0×
PHEV & flex-SHEV — Plug-in hybrids and flex-fuel strong hybrids. 2.5×
SHEV — Strong hybrids — cut back from 2.0× in the Sept 2025 draft. 1.6×
Flex-ethanol — Flex-fuel ethanol vehicles. 1.1×

Bilateral Trading, Not EU-Style Pooling

“Pooling” in the CAFE draft means the bilateral exchange or trade of credits on mutually agreed terms, with the result furnished to the designated agency. There is no joint fleet assessed as one manufacturer, no nominated pool manager and no cap on counterparties. The earlier up-to-three-OEM pool is gone.

Passbook Banking Within the Block

Credits and debits sit in a passbook and carry forward within the compliance block. Any credit left unsettled at block-end lapses — so surplus has a shelf life, and the block boundary is a hard planning date.

A Split 3 + 2 Block

Three years from FY2027-28 (FY28–30), then two from FY2030-31 (FY31–32). Penalty is assessed at the end of each block, on the entire block sales, after credits are settled — not annually.

Off-Cycle — 12-Technology Menu

Off-cycle technologies are capped at 9 g/km in total, now awarded through a formal 12-technology menu at 1 g each (Table 1.3) — replacing the open-ended cap with a defined list.

Carbon Neutrality Factor

Now explicit: 8% for E20-plus petrol including SHEV and PHEV, 22.3% for flex-fuel ethanol and flex-SHEV, 5% or the notified CBG share for CNG, and diesel per MoPNG.

Who Is Long, Who Is Short

Across the 15 passenger-vehicle OEMs, position is structural. Maruti, at roughly 1.87M units in FY26, carries the lightest fleet and therefore the tightest mass-curve target. Tata, at about 14% BEV, is positioned as a structural credit seller.

Covered by This Market?

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Where your fleet stands under India CAFE 2027, what the block costs, and which levers close the gap — mapped by the team.

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TerraNova for India CAFE

How Climate Decode Helps

TerraNova for CAFE, a joint solution with Meta Materials Circular Markets, turns the annual filing exercise into a live operating picture — built for the regulatory, product-planning, treasury and investor-relations desks.

1. Fleet Capture & Reporting

A variant-level fleet ledger that stays current, with CNF, cᵢ and vᵢ auto-computed from your last-reported iCAT sheet. Generates the AIS-137 Appendices in official format and establishes your position today — fed by VAHAN, SIAM and ARAI data.

2. Position & Gap Computation

Applies the mass-based target formula against your sales-weighted fleet, layering Table 3 super-credits, the off-cycle derogation and the Carbon Neutrality Factor — so the gap you plan against is the gap the regulator will compute.

3. MAC-Ranked Lever Sequencing

Every decarbonisation lever ranked by cost per gram closed — off-cycle technologies, mass reduction, powertrain shifts, strong hybrids and BEV ramp. Launch and switch scenarios in one click, and the ranking re-sorts when a draft provision moves.

4. Incentive Stack Modelling

Models the capex offset across PLI-Auto, PLI-ACC, PM E-DRIVE, state EV policies and GST alongside the CAFE super-credit value — so the per-BEV value stack is priced, not assumed.

5. Block Forecasting & Buyout Strategy

Five-year forecasting across the 3 + 2 block, BAU against with-plan, with the escalating buyout schedule and Section 26 penalty math built in. Answers bank, trade or buy out — and when, given a price that rises every year.

6. Market Watch & Counterparties

An in-house demand-and-supply model projects each of the 15 OEMs long or short, so you can identify trading counterparties and cover early. Trade tape, BEE price band and the policy news feed in one screen.

Draft Status — Read This First

CAFE 2027 figures on this page come from draft notification F. No. 10/3/2021-EC, dated 16 July 2026, which was open for objections for 21 days. Provisions may change before the rules are finalised. Where a value carries over from the earlier 25 September 2025 consultation draft — notably the mass-based formula and the year-by-year curve — that is noted. Exposure brackets attributed to Climate Decode are modelled, not regulatory figures.

Insights

India CAFE Insights & Analysis

A seven-part series on the CAFE regime — from first principles through the official 2027 draft to the credit market, modelled in full.

View Full India CAFE Series (7 Articles) →
Related compliance markets: India CCTS · Canada CFR · All 17 markets

Sources & References

Ministry of Power — Draft CAFE 2027 notification, F. No. 10/3/2021-EC (16 July 2026) BEE — Draft CAFE 2027 consultation document (25 September 2025) Bureau of Energy Efficiency ↗ Ministry of Road Transport & Highways ↗ ARAI — AIS:175 WLTP test standard (March 2026) ↗ Energy Conservation (Amendment) Act, 2022 — Sections 26, 27 and 28 Times of India (March 2026) — ₹2,728 Cr CAFE-II penalties on 9 OEMs Climate Decode CAFE Market Model (June 2026) — modelled exposure brackets
Frequently Asked Questions

India CAFE — Common Questions

Answers on scope, targets, the buyout, credit trading and what the 16 July 2026 draft actually changed.

What is India CAFE 2027?

CAFE 2027 is the third phase of India's Corporate Average Fuel Efficiency norms for M1 category passenger vehicles, drafted to take effect on 1 April 2027. It sets a fleet-average CO2 target for each manufacturer based on the kerb mass of the vehicles it sells. Manufacturers below their target earn credits; those above accrue debits that must be settled by trading, banking or a buyout paid to BEE.

When does CAFE 2027 take effect, and is it final?

The Ministry of Power published the official draft notification, F. No. 10/3/2021-EC, on 16 July 2026, with effect from 1 April 2027. It was opened for objections for 21 days, so provisions may still change before the rules are finalised. The mass-based target formula and year-by-year curve carry over from the earlier 25 September 2025 consultation draft.

How much does a gram of non-compliance cost?

The CAFE 2027 draft codifies an escalating BEE buyout, priced per gram of CO2 per km: 2,500 rupees in FY2028, rising through 3,000, 3,500 and 4,000 to 4,500 rupees by FY2032. A gram left unsettled in FY32 therefore costs 80 percent more than the same gram in FY28, which deliberately rewards trading and banking early over deferring to a late buyout.

Is CAFE pooling the same as EU-style pooling?

No. In the CAFE 2027 draft, pooling means the bilateral exchange or trade of credits between manufacturers on mutually agreed terms, with the result furnished to the designated agency. There is no joint fleet assessed as a single manufacturer, no nominated pool manager and no cap on counterparties. The earlier construct of up to three manufacturers per pool is gone.

Which super-credits and off-cycle credits are available?

Super-credits are confirmed and extended: 3.0 for battery and range-extended electric vehicles, 2.5 for plug-in hybrids and flex-fuel strong hybrids, 1.6 for strong hybrids and 1.1 for flex-fuel ethanol. Off-cycle technologies are capped at 9 g/km in total, awarded through a formal 12-technology menu at 1 g each. A Carbon Neutrality Factor applies on top, at 8 percent for E20-plus petrol and 22.3 percent for flex-fuel ethanol.

How does Climate Decode help with CAFE compliance?

TerraNova for CAFE turns the annual filing exercise into a live operating picture: a variant-level fleet ledger that generates the AIS-137 Appendices, MAC-ranked decarbonisation levers, a five-year forecast across the 3+2 block, and market intelligence on which manufacturers are long or short. Climate Decode also publishes a seven-part India CAFE series covering the regime end to end.

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