How to Build a UAE Climate Law GHG Inventory: Sources, Boundaries and Evidence

A spreadsheet containing tonnes of carbon dioxide equivalent is not yet a defensible GHG inventory. A reviewer must be able to see why each site and source is included or excluded, where each activity figure came from, which factor and GWP version was used, how estimates were approved, how totals reconcile and who reviewed the result.

The most important sequencing rule is to start with the regulated perimeter rather than with a generic Scope 1–3 template. GHG Protocol and IPCC methods can provide a strong accounting architecture where accepted, but they do not replace designation, facility thresholds, sector instructions, reporting forms or verification rules issued by the relevant UAE authority. One controlled evidence base may support several outputs; each output still needs its own boundary and compliance decision.

Figure 1. A defensible inventory connects the legal perimeter to calculations, controls, evidence and the authority output. London Reporting Academy learning visual.

The source register is the completeness control for the inventory. It should start from the organisation’s actual operating model: legal entities, permits, site maps, process-flow diagrams, utility accounts, fleet lists, fixed-asset registers, fuel purchase records, refrigerant equipment, leases, joint ventures and outsourced activities. The objective is to identify potential emission sources even where data are incomplete or the final classification is still under review.

A source should not disappear because its emissions are expected to be small. Record it, estimate its order of magnitude, assign a status and document the basis for exclusion or simplified treatment. This approach makes later authority changes manageable: the team can activate an existing source record rather than rediscovering the operation under deadline pressure.

The boundary memo should explain the legal perimeter and any external consolidation method separately. Its purpose is not to choose the most convenient number; it is to show how the reported population was identified and how differences from financial, operational or sustainability-reporting boundaries are reconciled.

Identify the Source, legal entity, permit holder, facility or group covered by the current instruction.

List included and excluded facilities, operations, vehicles, leased assets, joint ventures and contractors.

State whether operational control, financial control, equity share or a facility-specific rule is used for any supporting corporate inventory.

Explain cut-off treatment for acquisitions, disposals, temporary shutdowns, construction, commissioning and discontinued operations.

Identify intercompany data flows and controls that prevent duplicate consolidation.

Record unresolved questions and the exact confirmation requested from the competent authority.

Approve the memo through legal/compliance, operations, finance and the reporting owner before calculations are finalised.

Create one factor register with a unique factor ID; do not paste factor values independently into multiple sheets.

Record source, publication, year, geography, technology, fuel basis, unit, calorific-value basis and whether the factor is combustion-only or life-cycle.

Confirm whether the factor is expressed per mass, volume, energy, distance, production unit or another denominator.

Document gross versus net calorific value, standard-temperature assumptions, density and any oxidation or conversion factor.

Maintain a controlled GWP table with the assessment report or authority source and the inventory period to which it applies.

Lock formulas or use controlled calculation code; review all manual overrides and unit conversions.

When the factor or GWP changes, assess the impact on comparatives, base years, targets and other public reports before updating the current inventory.

Reconcile facility and account masters to the boundary list, including new, closed and dormant sites.

Compare current-year consumption, production and emissions with prior periods and operational explanations.

Reconcile fuel consumption to purchases and stock movements; electricity and cooling to all utility accounts; refrigerants to equipment and service records.

Test that each source has one calculation route and that no source is consolidated twice through entity and facility totals.

Search for blank units, zero factors, negative quantities, broken links, hidden rows, overwritten formulas and inconsistent GWP references.

Perform independent re-calculation of material sources and targeted testing of estimates and manual entries.

Reconcile the final authority output to the approved inventory, and retain the submission confirmation and any resubmission history.

A UAE industrial group operates a mainland manufacturing plant, a free-zone warehouse, a leased head office, a captive generator fleet and a minority joint venture. It initially prepares a group carbon footprint using operational control. During authority engagement, the team learns that the current reporting instruction is facility-based and applies only to the manufacturing installation; the joint venture and head office are outside that particular regulated submission, although they remain in the voluntary group inventory.

The team therefore preserves one source register but tags each record by output. The manufacturing facility inventory includes combustion, process and refrigerant sources under the approved method. The group inventory additionally includes purchased electricity and other operations under its corporate method. A reconciliation explains the difference. The controlled evidence repository stores invoices, flowmeter extracts, production records, refrigerant logs, factors, calculation files, reviews and the authority correspondence that supports the perimeter decision.