CCTS Phase 1 (FY2025–27) was calibrated to be achievable establishing MRV infrastructure and market mechanics without significant financial pain. Phase 2, expected from FY2027–28, will align with India’s 2035 NDC intensity trajectory, and for each of the nine covered sectors the compliance cost step-change will be material. Phase 1 was the handshake. Phase 2 is the contract. Companies that have not begun capital allocation for abatement by FY2026 will face the next gazette notification already behind.