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What are green debt securities? SEBI's 13 categories

By Flock Research · Filings research desk

Green debt securities are ordinary listed bonds with one condition attached: the money has to go somewhere specific. In India the test is not a label or a marketing claim but a closed list. Regulation 2(1)(q) of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021 names thirteen categories of project, and a debt security only counts as green if its proceeds fund one of them. This guide covers what those categories are, what the issuer has to disclose before and after listing, and what changed on 27 February 2026. It is not investment advice.

Definition

A green debt security

is a debt security whose proceeds are raised to fund projects or assets falling within the thirteen categories listed at Regulation 2(1)(q) of the SEBI NCS Regulations, 2021. The list covers renewable energy, clean transportation, climate adaptation, waste, land use, biodiversity, pollution control, circular economy, blue bonds, yellow bonds and transition bonds. Source: SEBI.

What are the categories of green debt securities?

The current definition was substituted with effect from 2 February 2023, and the substitution widened the list from nine categories to thirteen. Those categories are renewable and sustainable energy including wind and bioenergy; clean transportation including mass and public transportation; climate change adaptation, including infrastructure resilience and climate observation and early warning systems; energy efficiency including efficient and green buildings; sustainable waste management; sustainable land use including forestry, agriculture and afforestation; biodiversity conservation; pollution prevention and control, which expressly picks up sectors under the India Cooling Action Plan; circular economy adapted products and eco-efficient products; blue bonds; yellow bonds; transition bonds; and any other category SEBI specifies later.

Three of those are worth naming as their own instruments, because the market usually treats them that way. Blue bonds raise funds for sustainable water management and the sustainable maritime sector, which the regulation spells out as sustainable shipping, sustainable fishing, fully traceable sustainable seafood, ocean energy and ocean mapping. Yellow bonds raise funds for solar energy generation and its upstream and downstream industries. Transition bonds raise funds for moving to a more sustainable form of operations in line with India's Intended Nationally Determined Contributions, and carry extra requirements of their own, covered in what is a transition bond.

What changed in the 2023 definition?

This is where a reader working from an older summary goes wrong. The pre-2023 list is still printed in the consolidated regulations, in a footnote directly beneath the current clause, and it reads as plausibly current. Two differences matter. Sustainable water management was a standalone category in the old list, at clause (iii); it now sits inside the blue bonds category. And the old clause (i) read "renewable and sustainable energy including wind, solar, bioenergy"; the current clause (i) drops the word solar, which moved into the yellow bonds category.

13

Project categories that qualify a bond as a green debt security in India, up from nine before the 2023 substitution

Source: SEBI NCS Regulations, 2021, Regulation 2(1)(q), substituted with effect from 2 February 2023

What does an issuer have to disclose up front?

Chapter IX of SEBI's Master Circular for issue and listing of non-convertible securities, securitised debt instruments, security receipts, municipal debt securities and commercial paper, dated 15 October 2025, sets the initial disclosures for the offer document, on both public issues and private placements.

The issuer states the environmental sustainability objectives of the issue. It describes the decision-making process for deciding which projects are eligible, including the criteria used and any Indian or global taxonomies, green standards or certifications it referenced. It describes the system for tracking where the proceeds actually go. It identifies the projects or areas the money will fund, including any refinancing of existing green projects, with an indicative split between financing and refinancing. It states how unallocated proceeds will be parked in the meantime. And it discloses the perceived social and environmental risks of those projects along with a mitigation plan.

What does an issuer have to disclose after listing?

The continuous disclosures go with the annual report and the financial results. Utilisation of proceeds is reported as tracked, and has to be verified by an external auditor's report covering both the internal tracking method and the allocation of funds. Unutilised proceeds are reported for each ISIN separately, which is the level at which this data becomes usable; the identifier itself is explained in what is an ISIN.

The annual report adds the list of projects funded with amounts disbursed, qualitative performance indicators and, where feasible, quantitative measures of environmental impact, the methods and key assumptions behind those metrics, and how the mitigation plan was deployed. Impact reporting is required project by project. On top of that, Annexure IX-A requires major elements of Business Responsibility and Sustainability Reporting, which means energy consumption and intensity, water withdrawal and discharge, air emissions, Scope 1 and Scope 2 greenhouse gas emissions, waste by category, operations near ecologically sensitive areas and environmental law compliance. The wider framework those tables come from is set out in what is BRSR.

Chapter IX came into force for all issues of green debt securities launched on or after 1 April 2023.

Who checks the claim?

Until early 2026 the third-party review requirement sat on a comply-or-explain footing. That changed on 27 February 2026, when SEBI deleted paragraph 1.8 of Chapter IX and inserted a new paragraph 5 in its place, with immediate effect. The issuer now appoints an independent third-party reviewer or certifier to ascertain that the issuance accords with the Regulation 2(1)(q) definition, including review of the project evaluation and selection criteria. The reviewer must be independent of the issuer, its directors, senior management and key managerial personnel, must be remunerated in a way that prevents conflicts of interest, and must have expertise in assessing ESG debt securities. The review may take the form of a second party opinion, verification, certification, or a scoring or rating. An ESG rating provider registered with SEBI may also be appointed.

The reason SEBI wrote the rule that way is set out in its own greenwashing chapter, covered in how to spot greenwashing in green bonds.

Green debt securities are a disclosure regime before they are anything else: a closed category list, a tracked use of proceeds, an audited utilisation report and a named external reviewer. Where the instrument sits in the wider debt market is covered in what is an NCD and NCD vs bond. Flock reports public regulatory filings with every claim sourced and dated. What any of it means for your money is your call to make.

Frequently asked questions

What qualifies as a green debt security in India?

Only a debt security whose proceeds fund projects in one of the categories listed at Regulation 2(1)(q) of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021. The list runs to thirteen entries, including renewable energy, clean transportation, climate change adaptation, biodiversity conservation, circular economy products, blue bonds, yellow bonds and transition bonds. Source: SEBI.

Are blue bonds and yellow bonds green debt securities?

Yes. Both are sub-categories inside the definition, not separate instruments. Regulation 2(1)(q)(x) covers blue bonds, for sustainable water management and the sustainable maritime sector. Regulation 2(1)(q)(xi) covers yellow bonds, for solar energy generation and its upstream and downstream industries. Both were added when the definition was substituted with effect from 2 February 2023. Source: SEBI.

What must a green debt security issuer disclose after listing?

Utilisation of proceeds verified by an external auditor's report, details of unutilised proceeds for each ISIN, the list of projects funded with amounts disbursed, qualitative and where feasible quantitative environmental impact measures, project-by-project impact reporting, and major elements of Business Responsibility and Sustainability Reporting. These go with the annual report and financial results. Source: SEBI NCS Master Circular, 15 October 2025, Chapter IX.

Does a green bond issuer need an independent reviewer?

Yes, since 27 February 2026. A SEBI circular of that date deleted paragraph 1.8 of Chapter IX and inserted a new paragraph 5 requiring the issuer to appoint an independent third-party reviewer or certifier, with effect immediately. The reviewer must be independent of the issuer and remunerated so as to prevent conflicts of interest. Source: SEBI.

Flock tracks these filings, sourced, dated, and linked back to the original. See what smart-money entities disclosed, without the guesswork about what it means.

Disclosures shown are public regulatory filings. Data may be delayed or incomplete. Smart-money entities may no longer hold positions shown. Not investment advice.

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