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London Reporting Academy UAE Federal Decree-Law 11/2024 · Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects · Disclosure Art.6(1)(a)-2

Comprehensive emissions inventory

Art.6(1)(a)-2 · mandatory · metrics + narrative

This asks an organisation to report a full emissions inventory, rather than a partial or selective picture. In practice, that means identifying and quantifying the greenhouse gas emissions that arise from the organisation’s activities and sources, so the report reflects the organisation’s overall emissions profile in a consistent way.

Disclosure focus

The practical focus is coverage: the inventory should be broad enough to capture emissions across the organisation’s operations, not just a few flagship sites or the easiest-to-measure locations. The aim is to give users a complete basis for understanding where emissions come from and how material parts of the business are represented in the reporting.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official MOCCAE source.

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Base year total

    Sustainability reporting team with finance or environmental data owners

    The emissions figure chosen as the starting comparison point for the reporting baseline, expressed in tonnes of carbon dioxide equivalent.

    Evidence Baseline inventory file, calculation workbook, and the approval note showing which year was set as the reference point.

    Watch for Base year and current-year figures get mixed up, so the baseline does not reconcile to the approved inventory for the chosen reference year.

  • Emissions by gas

    Environmental data team or emissions inventory owner

    A breakdown of emissions by each relevant greenhouse gas, with each gas identified separately rather than combined into one line.

    Evidence Source calculation schedule or emissions model showing the gas-by-gas split and the emission factors used.

    Watch for Gas categories are collapsed or mislabelled, so the split does not reconcile to the underlying calculation by gas.

  • Emissions by source

    Operations team with environmental reporting lead

    A breakdown of emissions by the place or activity where they arise, such as a site, facility, or process, using the organisation’s chosen source structure consistently.

    Evidence Site or process emissions register, operational logs, and the mapping that links each source to the reported category.

    Watch for Source categories are mixed between facility and process views, so the breakdown does not reconcile to the source register.

  • Total emissions

    Sustainability reporting team

    The overall emissions amount for the reporting period, stated in tonnes of carbon dioxide equivalent and built from the same scope and methods used in the detailed breakdowns.

    Evidence Consolidated emissions workbook, roll-up summary, and final sign-off pack showing the arithmetic from component lines to the total.

    Watch for The total is taken from a different scope or period than the component data, so it does not reconcile to the consolidated emissions calculation.

Before you start

  • Have you fixed which sites, activities, and emission sources you are counting, so the inventory covers the right parts of the business?
  • Have you chosen the reporting period and the base-year basis for the figures, so the totals are built on one consistent timing approach?
  • Can every number be traced back to a source record, calculation file, or other evidence you can show later?
  • Have you agreed which greenhouse gases you will separate out in the working, rather than only giving one combined figure?
  • Have you decided whether each source should be grouped by site, plant, or process step, so the breakdown matches how operations are run?
+ Show Art.6(1)(a)-2 sub-elements (LRA working checklist)

How to prepare it

Set the reporting boundary first: decide which operations, sites, and activities are included in the calculation, so the figures relate to the same scope throughout.
Define the emissions categories you will use in plain business terms, covering the overall total, the starting-year amount, the gases included, and the sources or processes that generate them.
Gather the underlying records that support each figure or explanation, such as activity data, calculation files, source logs, and any other working papers used to build the numbers.
Calculate and compile the reported outputs in a consistent format, making sure the total emissions figure, the base-year amount, and the breakdowns by gas and by source can be traced back to the same evidence set.
Record any exclusions, estimation choices, boundary changes, or restatements clearly, so a reviewer can see what was left out, what changed, and why the reported numbers differ from earlier periods if they do.
Check the final disclosure against the official source before submission, confirming that the scope, definitions, evidence, and reported figures still match the legal requirement and have not drifted during drafting.

Request the data

Request the emissions inventory data from EHS / Operations

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What are the organisation’s emissions totals, split by gas and by source, for the chosen base year and reporting boundary?

Use your organisation’s own terms first, then map them to the reporting fields. For example, if your teams talk about sites, plants, lines, utilities, refrigerants, or process vents, use those labels in the request and only translate them into the reporting categories when you compile the response.

Weak request

Please provide the comprehensive emissions inventory in line with the disclosure.

Why it fails: This uses framework language that many operational owners will not recognise, so it is easy to answer with the wrong level of detail or miss the internal source data needed to build the inventory. It also does not say which systems, sites, gases, or source categories to pull from.

Better request

Please send the emissions inventory from your normal EHS / site tracking records for [base year / reporting period], showing the total tCO2e, the split by gas, and the split by site or process, together with the boundary, source system, calculation basis, and any restatements or exclusions.

Formal email template
Subject: Request for emissions inventory data for [base year / reporting period]

Dear [name / team],

We are preparing the organisation’s emissions disclosure and need your help with the underlying inventory data for [base year / reporting period].

Please send a copy of the latest emissions inventory, or a table that shows:
- the total emissions figure for the base year, in tCO2e;
- the split by gas used in the inventory, such as carbon dioxide, methane, nitrous oxide, and any others you track;
- the split by source, using your normal site or process labels;
- the boundary covered by the data;
- the source system or workbook used;
- the calculation basis, including any estimates or emission factors;
- any restatements, exclusions, or changes since the last version.

If it is easier, please return the information in the response form below. Please adapt this to your organisation’s own language and check the official source before sign-off.

Many thanks,
[preparer name]
[team]
[contact details]
Short Teams / Slack version
Hi [name] — could you send over the emissions inventory for [base year / reporting period]? We need the total tCO2e, the split by gas, the split by site/process, plus the boundary, source system, and any notes on estimates or restatements. Please use your usual internal labels. If helpful, I can send the response form. Thanks.

Industry examples

Manufacturing

Context. A multi-site producer tracks boilers, furnaces, refrigerant leaks, and backup generators in separate plant logs.

Adapted request. Please pull the emissions data from the plant logs and EHS tracker for [base year / reporting period], showing each site, each process source, the gas split, and the total tCO2e, plus the boundary and calculation notes.

Example response. Abu Dhabi plant: furnace, boiler, and refrigerant sources listed separately; Dubai plant: generator and process vent sources listed separately; gases shown as CO2, CH4, and N2O; total emissions 12,450 tCO2e; base year 12,450 tCO2e; boundary and method notes attached.

Real estate / property operations

Context. A property team manages landlord-controlled utilities, tenant areas, and common services through a facilities platform.

Adapted request. Please send the emissions inventory from the facilities platform for [base year / reporting period], using your usual building and utility labels, with the total tCO2e, gas split, source split by building service, and notes on the boundary and any estimates.

Example response. Tower A common services, Tower B plant room, and car park ventilation shown as separate sources; electricity-related and fuel-related emissions split by gas where tracked; total emissions 3,280 tCO2e; base year 3,280 tCO2e; utility invoices and estimation notes referenced.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State which year is being used as the starting point, explain how the gases and sources were grouped, and note the basis used to calculate the totals.

Context note

Explain what the overall figure means by linking it to the chosen baseline, the gas mix, and the main facilities or processes driving the result.

Fluctuation statement

If the total has moved materially, point to the main operational, source-level or gas-level changes that drove the difference from the earlier period.

Content index entry

Art.6(1)(a)-2 Comprehensive emissions inventory — [location / page] / [notes]

Download Centre

Preparation tools & forms

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Free · Email access

Check

For each claim, check the evidence

  • We used a fixed comparison year and kept the calculation trail that supports the figure.

    Risk The assurer may ask whether the comparison year was chosen consistently, whether the same basis was used throughout, and whether the working papers show how the number was derived.

    Evidence to check ['Board or management approval of the chosen comparison year', 'Calculation workbook showing the comparison-year figure and formulae', 'Source records used to build the number', 'Version history or change log for any later adjustments']

  • We split the inventory by gas so the totals can be traced back to each gas type.

    Risk The assurer may probe whether each gas was identified separately, whether conversion factors were applied correctly, and whether the sum of the parts matches the reported total.

    Evidence to check ['Gas-level schedule or emissions register', 'Method note showing how each gas was measured or estimated', 'Conversion factors and calculation sheets', 'Reconciliation from gas-level amounts to the disclosed total']

  • We organised the data by source area so the reported amount can be traced to the relevant site or activity.

    Risk The assurer may test whether the boundary was applied consistently, whether all relevant sources were included, and whether any site or process was omitted or double-counted.

    Evidence to check ['Source-by-source inventory listing sites, processes or activities', 'Boundary memo explaining what was included and excluded', 'Supporting operational records for each source', 'Reconciliation showing no gaps or overlaps across sources']

  • We checked the period total against the underlying records before publishing it.

    Risk The assurer may ask whether the reporting period was correct, whether the total is complete, and whether the published number agrees with the source data and calculations.

    Evidence to check ['Period-end inventory summary', 'Underlying activity data and emission calculations', 'Review sign-off or control checklist before release', 'Reconciliation between source records and the published total']

Evidence pack to prepare

Common reporting gaps

  • Figures are stated without the supporting narrative, or narrative without figures.
  • Scope is inconsistent between the text and the numbers.
  • The reporting boundary is left undefined.
  • Material changes since the previous period are not disclosed.
  • Estimates and measured values are not distinguished.
  • Source records for the figures are not identified.

Where drafts go wrong

Mistakes to avoid and where judgement is needed

The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.

Mistakes to avoid

  • Wrong ownerThe request goes to the sustainability team by default, even though the numbers sit with operations, facilities, or the emissions analyst who actually holds the source records.
  • Framework language onlyThe data ask uses reporting jargon instead of the business’s own labels, so teams cannot tell whether you mean a plant, a line, a site, or a process step.
  • Boundary left vagueNo one states which sites, activities, or business units are in scope, so different teams collect different slices of the footprint and the totals do not line up.
  • Wrong period basisOne team pulls a calendar-year set while another uses the organisation’s reporting cut-off, which makes the inventory cover different time windows.
+ Show 4 more

Judgement needed

  • Acquisitions, disposals, and other boundary shiftsUse a clear cut-off for when new sites or sold operations enter or leave the inventory, and explain any restatement or non-restatement of prior figures so readers can see why the totals changed.
  • Different country rules for the same sourceWhere local reporting labels or calculation rules differ, map them to one group-wide method, note the main differences, and explain any country-specific exceptions you kept in the figures.
  • Sites and activities near the inclusion lineSet out the rule you used for borderline locations, joint operations, leased assets, contractors, or other shared activities, and disclose why they were counted or left out.
  • Choosing the timing basis for the numbersState whether you used the period when emissions happened, when data became available, or another consistent timing basis, and explain any one-off timing adjustments that affect comparability.
+ Show 4 more

Examples

How it reads on the page

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Manufacturing

We set out our starting-year emissions and the latest total for our operations, using a simple split by greenhouse gas and by main site/process so the figures can be traced through our records.
- Base year: 2022, with 48,000 tCO2e in that reference year.
- Latest year total: 2024, with 45,600 tCO2e overall; by gas this was 41,040 tCO2e of carbon dioxide, 3,648 tCO2e of methane, and 912 tCO2e of nitrous oxide.
- By source, the total was made up of 28,500 tCO2e from our main production line, 9,600 tCO2e from the heat and power plant, and 7,500 tCO2e from logistics and warehousing.

This example shows a plain-language way to present the reference-year figure, the latest total, and a breakdown that can be followed both by gas and by operational source. The numbers are internally consistent and illustrative only.

Illustrative (synthetic) example — Retail and distribution

We report our reference-year emissions alongside the current total, then break the current figure down by gas and by the main parts of our network so the source of the emissions is clear.
- Base year: 2021, with 12,400 tCO2e in that year.
- Latest year total: 2024, with 11,860 tCO2e overall; by gas this was 10,674 tCO2e of carbon dioxide, 948 tCO2e of methane, and 238 tCO2e of nitrous oxide.
- By source, the total was made up of 6,900 tCO2e from stores, 3,200 tCO2e from distribution centres, and 1,760 tCO2e from delivery vehicles.

This example uses a different sector and a different set of figures, while still showing the reference-year amount, the latest total, and a complete split by gas and by source. The figures are synthetic and add up consistently.

Quality ladder

  • Basic

    I report total emissions of 12,000 tCO2e.

  • Better

    I report 12,000 tCO2e in total, split by gas as 10,500 tCO2e from carbon dioxide, 1,200 tCO2e from methane and 300 tCO2e from nitrous oxide, and by source across our main plant and process lines.

  • Best

    I report 12,000 tCO2e for the year ended 31 December 2025, with 10,500 tCO2e from carbon dioxide, 1,200 tCO2e from methane and 300 tCO2e from nitrous oxide, split across our main plant and process lines, and the year-on-year rise mainly reflects higher output at the plant.

Check your understanding

Scenarios to work through

A manufacturing site has one main boiler, a backup generator, and a small solvent line. The preparer has the annual total in tCO2e, but the source file only groups everything together and does not separate the gases or the individual source areas.

QShould the inventory be split so the team can show the total, the gases involved, and where the emissions came from?
Reveal model answer →

A group has two production sites. Site A is fully measured, but Site B is still being estimated from utility bills and production records. The preparer is unsure whether to wait until every estimate is refined before drafting the disclosure.

QCan the preparer include the current inventory now, provided the total and breakdowns are supported by the best available evidence?
Reveal model answer →

A services company has only one office and one fleet of vehicles. The preparer plans to report a single total emissions figure and says the gas split is unnecessary because the business is small and the emissions come from only one place.

QIs a single total enough, or does the preparer still need to show the gases and the source of the emissions?
Reveal model answer →

A preparer has last year’s base-year figure, this year’s total, and a note saying the emissions are mainly from the factory and the delivery fleet. However, the gas split was copied from an old spreadsheet and no one can trace it back to source records.

QCan the gas breakdown be used as-is, or does it need to be checked against evidence before the disclosure is finalised?
Reveal model answer →

Real reports

How 3 companies report it

Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.

Real published reports

TAQA (Abu Dhabi National Energy Company)

Related

None · United Arab Emirates · 2024 · p.237 ↗

TAQA’s 2024 Integrated Report provides a breakdown of greenhouse gas emissions by type, noting that about 99% of emissions are CO2, with the remainder comprising CH4, SF6, and N2O (p.99). The report also quantifies total Scope 1 and Scope 2 emissions as 48.90 million tonnes of CO2e and 0.28 million tonnes of CO2e respectively (p.272). However, the report does not provide data on base year emissions or emissions by source facility or process.

Aldar Properties

Related

None · United Arab Emirates · 2024 · p.86 ↗

Aldar Properties' Sustainability Report 2024 provides a total annual greenhouse gas emissions figure of 1,708,482 tCO2e, noting an increase in emissions (p.23). The report also details GHG emissions by source and business segment, including emissions from waste and embodied carbon exceeding certain thresholds (pp.87-89). However, the report does not present specific data on base year emissions, emissions by individual gases, or emissions by specific facilities or processes.

Abu Dhabi Commercial Bank (ADCB)

Related

None · United Arab Emirates · 2024 · p.33 ↗

Abu Dhabi Commercial Bank’s 2024 ESG Report provides a covered datapoint for base year greenhouse gas emissions, reporting 13.25 million tCO2e on page 30, with the methodology based on the Greenhouse Gas Protocol. The report includes some related context on total emissions per output scaling factor on page 121, but this is unclear as a direct total emissions disclosure. Notably, the report does not provide emissions broken down by gas type or by source facility or process.
FieldTAQA (Abu Dhabi National Energy Company)Aldar PropertiesAbu Dhabi Commercial Bank (ADCB)
Base year totalNot foundNot foundNot found
Emissions by gasNot foundNot foundNot found
Emissions by sourceNot foundNot foundNot found
Total emissionsNot foundNot foundPartial

Full evidence map with quotes and page numbers →

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Framework references

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UAE

Art.6(1)(a)-2

within UAE Federal Decree-Law 11/2024: Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects

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