Disclosure focus
The practical focus is therefore on coverage and consistency: the data should be gathered across relevant operations, activities and entities so that the reported picture is not distorted by partial sampling. Where there are differences between sites or parts of the business, the organisation should make sure the reporting approach captures them in a coherent way.
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.
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Submission file format
Reporting operations / data managementCapture the exact file type or delivery format used for the data return, so the submission can be prepared in the form the reporting process expects.
Evidence Submission template, portal instructions, or technical upload specification showing the accepted format.
Watch for The file is prepared in a format that does not match the receiving system’s required upload type.
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National report inclusion
Reporting lead / statutory reportingRecord whether this data point is being folded into the national report or kept outside it, using a clear yes/no decision that matches the reporting pack.
Evidence Final report index, sign-off pack, or inclusion checklist showing the item is marked in or out.
Watch for The yes/no flag is set differently from the final report pack, so the item is wrongly included or omitted.
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Reporting period
Reporting lead / finance controlCapture the reporting cycle that applies to this disclosure, so the datapoint is tied to the correct reporting window.
Evidence Reporting calendar, period schedule, or filing instructions showing the cycle to use.
Watch for The period is captured for the wrong cycle, so the datapoint is reported for the wrong reporting window.
Before you start
- Have you fixed the reporting period this data will cover, so the figures line up with the right cycle?
- Will these figures be taken from a source you can trace and evidence, rather than from an unverified summary?
- Are you clear on the format you will use to hand over the data, so it matches the receiving process?
- Does this set of figures need to be flagged as part of the national submission, or kept outside it?
- Have you agreed which internal definition or calculation basis will be used, so everyone is working from the same numbers?
How to prepare it
Request the data
Request the climate-reporting pack from Legal / Company Secretariat
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which reporting cycle, submission format, and national-report status should we use for this climate-reporting disclosure?
Use your organisation’s own names for the report pack, filing route, and reporting cycle first, then map them to the fields below. This is a possible LRA training template; adapt it to your organisation and check the official source before sign-off.
Weak request
Please provide the disclosure wording for UAE-LAW-11-2024:Art.7(3)(b)-3 and confirm compliance.
Why it fails: This asks for framework wording rather than the underlying business information. It does not tell the owner what internal records to pull, which period to cover, or what evidence fields are needed for review.
Better request
Please send the current climate-reporting pack for [period], using your team’s own labels. We need the reporting cycle name, the submission format, and whether the item was included in the national report, together with the source reference, version, and confirmer.
Formal email template
Subject: Request for climate-reporting details for [period]\n\nDear [name/team],\n\nPlease share the current details for the climate-reporting pack for [period]. We need the following for our internal disclosure record:\n- the reporting cycle name used internally\n- the format used to submit the information\n- whether this item was included in the national report\n\nPlease also include the source document or system reference, the version/date, and the internal owner who can confirm the information.\n\nThis is a possible LRA training template; please adapt it to your organisation’s own terms and check the official source before sign-off.\n\nKind regards,\n[preparer name]\n[role]
Short Teams / Slack version
Hi [name/team] — could you send the latest climate-reporting details for [period]? We need the internal cycle name, the submission format, and whether it went into the national report, plus the source reference/version. Please use your team’s own terms if different. Thanks.
Industry examples
Energy / Utilities
Context. A sustainability reporting team needs the filing details from the corporate affairs or regulatory reporting owner.
Adapted request. Please share the latest filing details for [period] from the regulatory reporting tracker: the cycle name we use, the format used to submit the climate information, and whether this item was included in the national report. Include the tracker reference, version, and the person who confirmed it.
Example response. Cycle name: Annual regulatory cycle. Submission format: Portal upload plus PDF annex. Included in national report: Yes. Source reference: REG-CLM-2025-01. Version: v2. Confirmed by: Regulatory reporting manager.
Manufacturing
Context. An operations-led sustainability lead needs the evidence from the compliance or EHS reporting coordinator.
Adapted request. Please send the climate-reporting record for [period] from your reporting log. We need the internal cycle label, the submission format used, and whether the record was folded into the national report, plus the log reference and latest approved version.
Example response. Cycle label: Year-end reporting run. Submission format: Spreadsheet upload. Included in national report: No. Source reference: EHS-CLM-LOG-44. Version: Approved v1. Confirmed by: EHS reporting coordinator.
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
Define each field in plain terms before drafting the disclosure: explain what counts as the submission format, how the yes/no inclusion flag is applied, and how the reporting cycle is determined from the source records.
Context note
Use the figures to show how the information is organised for filing, whether each item is carried into the national report, and which reporting period each record belongs to.
Fluctuation statement
If the pattern changes across cycles, note whether the shift comes from a different submission format, a change in inclusion decisions, or a move to a new reporting period.
Content index entry
Art.7(3)(b)-3 Data for international climate reporting — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for Art.7(3)(b)-3 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We can show how the figure was built from source records, including the file type or upload method used to send the data onward.
Risk An assurer may question whether the submission route was consistent, complete, and suitable for the underlying records, or whether format changes could have altered the figures.
Evidence to check Submission logs, exported files, templates used, system screenshots, and any instructions or correspondence showing the chosen file type or transfer method.
We have a clear record of whether this item was folded into the wider national filing or kept separate.
Risk An assurer may probe whether the inclusion decision was made correctly and whether the reported status matches the actual filing package.
Evidence to check Final filing pack, cover note, submission receipt, internal sign-off papers, and a traceable decision record showing the inclusion status.
We can point to the reporting period used for this data and explain why that cycle was selected.
Risk An assurer may test whether the period is the right one, whether it was applied consistently, and whether any cut-off issues affected the result.
Evidence to check Reporting calendar, period-end instructions, source-system date filters, management review notes, and any reconciliation between source dates and the stated cycle.
We held the working papers and source evidence needed to support the disclosed information before it went out.
Risk An assurer may ask whether the evidence trail is sufficient, retained, and traceable back to the published figure or statement.
Evidence to check Source documents, working papers, audit trail extracts, version history, approvals, and retention records linking the published disclosure to underlying evidence.
We carried out checks before publication to confirm the numbers, labels, and submission details were internally consistent.
Risk An assurer may look for weak review controls, unresolved mismatches, or errors introduced during consolidation or final editing.
Evidence to check Review checklists, reconciliation sheets, exception logs, sign-off emails, and evidence of corrections made before release.
Evidence pack to prepare
Common reporting gaps
- The information is presented without a date or as-at point.
- The scope or boundary of the statement is left undefined.
- Key terms are used inconsistently across the report.
- Material changes since the previous period are not disclosed.
- Assertions are made without supporting detail or a source record.
- Boilerplate is used that does not actually answer what is asked.
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 ownerChasing the policy team or sustainability lead for the data can miss the operational team that actually sends the filing and tracks the reporting cycle.
- Framework languageAsking for the information in law-style terms can confuse colleagues, so they return a generic answer instead of the organisation's own filing format, cycle and yes/no status.
- No boundary setIf you do not define which business units, sites or subsidiaries are in scope, different teams may collect different populations and the final dataset will not line up.
- Wrong period basisPulling figures from a different reporting cycle or an ad hoc date range can make the submission format and the yes/no status refer to different periods.
- Mixed counting basisCombining one-off submissions with recurring cycle data, or mixing draft and final records, can produce a dataset that does not match a single reporting basis.
- Source labels lostCopying values into a spreadsheet without keeping the original file names, system tags or source notes makes it hard to trace where the reporting cycle and status came from.
- Merged populationsPutting together data for separate legal entities or separate filing streams can hide which record belongs to the national report and which does not.
- Missing evidence trailCollecting the answer without the supporting file, date stamp and approver name leaves no clear sign-off trail for later review.
Judgement needed
- Set the reporting perimeter after a buy-in or saleIf a business unit has been added or removed during the cycle, state the cut-off date and explain whether the submission covers the full period, only the time in scope, or a restated view, so the basis is clear.
- Handle country-by-country definitions with one chosen ruleWhere local reporting labels or calculation methods differ, pick one consistent approach for the submission, describe the rule used, and note any country-level exceptions that were translated into the same reporting basis.
- Decide how to treat borderline operations and shared activitiesFor sites, teams, or assets that sit partly inside and partly outside the reporting boundary, explain the inclusion test used and whether partial activity was counted, excluded, or rolled up into a broader operational group.
- Choose the timing basis and keep it consistentState whether the figures follow the period when activity happened, when it was recorded, or another internal cut-off, and disclose any timing mismatch that could affect how the cycle is read.
- Separate measured figures from estimatesIf some inputs were directly captured and others were modelled or approximated, identify which parts were estimated, the method used to fill gaps, and any material assumptions that shaped the final submission.
- Round numbers without obscuring the underlying totalUse a rounding approach that does not change the overall picture, and if rounded figures are shown, explain the convention so readers can understand any small differences in totals.
- Aggregate sensitive data before sharing itWhen privacy or confidentiality means individual records cannot be shown, combine them to a level that protects people or counterparties, and disclose the aggregation level used so the submission remains interpretable.
- Align the reporting cycle with the source recordsIf internal records run on a different timetable from the climate submission cycle, explain how the source data were mapped to the chosen period and whether any bridging adjustments were made.
- Explain any restatement after boundary or method changesWhen a prior-period figure is updated because the organisation changed its scope, timing basis, or calculation method, say what changed and why the revised number is the one used for the submission.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We would send our annual climate file in the regulator’s required digital template, and that package would be folded into the country-level return. For this reporting year, our group would submit once, covering the 12-month period from 1 January to 31 December. - Delivery route: the prescribed electronic template - National return: yes, our submission would be included - Cycle: annual reporting
This example shows how a company might describe the filing route, whether its data feeds the national return, and the reporting rhythm, without naming the organisation.
Our group would provide the information through the official online submission channel, and it would be counted in the national compilation. We would report on a yearly basis, using the same 12-month cycle as our wider sustainability filing. - Delivery route: online submission channel - National return: yes, included - Cycle: yearly
This example uses a different sector and a different way of describing the same three datapoints, while staying fully synthetic and first-person.
Quality ladder
- Basic
I submitted the climate data in spreadsheet form, and it was included in the national report.
- Better
I submitted the climate data as a spreadsheet for the 2024 reporting cycle, and it was included in the national report.
- Best
I submitted the climate data as a spreadsheet for the 2024 reporting cycle, it was included in the national report, and the format stayed the same because our reporting process did not change.
Check your understanding
Scenarios to work through
A sustainability team is preparing a climate data pack for a ministry submission. They have the figures ready, but the file could be sent as a spreadsheet, a PDF extract, or loaded into a portal, depending on the receiving channel.
A group reporting team has prepared climate information for an overseas filing and is unsure whether the same dataset will also feed the country-level climate return. One draft says “for internal use only”, while another version is marked for inclusion in the national filing.
A reporting manager is compiling climate data for a cross-border disclosure and has figures from two different periods: one set covers the latest calendar year, while another follows the organisation’s own financial year. The receiving authority has asked for the reporting cycle to be stated alongside the data.
A preparer is reviewing a climate reporting file before sign-off. The file includes the figures and a note that the data will be used in an international submission, but the team has not yet documented the exact submission format or the reporting cycle in the working papers.
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.
DEWA (Dubai Electricity & Water Authority)
TAQA (Abu Dhabi National Energy Company)
First Abu Dhabi Bank (FAB)
| Field | DEWA (Dubai Electricity & Water Authority) | TAQA (Abu Dhabi National Energy Company) | First Abu Dhabi Bank (FAB) |
|---|---|---|---|
| Submission file format | Not found | Not found | Not found |
| National report inclusion | Not found | Not found | Not found |
| Reporting period | Not found | Not found | Not found |
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Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant UAE requirements and related disclosures
UAE
Art.7(3)(b)-3
within UAE Federal Decree-Law 11/2024: Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects
Related & explore
More in UAE Federal Decree-Law 11/2024 →Browse full catalogue →Search all disclosures →
FAQ
Questions this page answers
The page says to prepare three datapoints up front: the submission file format, whether the national report is included, and the reporting period. It also has a step-by-step preparation section you can use to turn those inputs into a draft.
Use it as a working guide to move from the basic datapoints into a draft disclosure. The page is designed to help you prepare the disclosure, collect the right data, and get to a usable output rather than just read the topic in theory.
The page includes an evidence pack with five items to support assurance readiness, plus five assurance claims to verify using a claim/risk/evidence approach. Use those together to build a file that shows what was checked, what could go wrong, and what supports the final disclosure.
The page provides five claims to verify, each paired with a risk and evidence prompt. They are there to help you test the disclosure before sign-off and to make the evidence trail clearer for reviewers.
It includes a list of common reporting gaps and mistakes so you can check for missing or weak inputs before drafting. Use that list as a pre-submission quality check, especially if you are coordinating between ESG, HR, finance, or another data owner.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. The page positions it as a practical tool for preparing the disclosure, organising evidence, and working towards an assurance-ready draft.
The Download Centre also provides a printable Library Card in PDF format. It is meant as a quick reference alongside the workbook and the page content when you are preparing the disclosure or checking your evidence pack.
Yes, as a drafting aid only. The page includes synthetic illustrative example disclosures, including a quantitative table, to show how the disclosure can be turned into a draft without treating the example as a real company report.
The draft-output section gives visualisation ideas, narrative starters, and a content-index line. Use those to shape the final wording and presentation once your data and evidence are in place.
It has a 'From company reports' table that links to real published reports at the pages where the topic is disclosed. That is useful for seeing how others present similar information, but you still need to adapt the approach to your own data and reporting context.
The page says the closest ESRS correspondence is ESRS E1 (Climate Change). You can use that as a cross-check and reuse data where it fits your reporting process, but the page does not say the requirements are identical.
More questions this page can help with