UAE Climate Law Scope 1 Emissions: Fuel, Fleet, Processes and Refrigerants

Direct emissions are often underestimated because teams begin with fuel invoices and stop there. Fuel purchases may miss stock movements, landlord or contractor arrangements, off-road equipment and unbilled consumption. They also say nothing about process chemistry, vents, flares or fluorinated-gas losses. A complete inventory therefore starts with physical sources and process maps, not with one expenditure account.

The same physical activity can be classified differently across regulated, corporate and voluntary outputs. A leased generator may be within an authority-defined facility perimeter even if the parent’s corporate inventory treats the contract differently. A contractor-operated asset may remain relevant where the facility controls operating policies or where the authority includes the source. Preserve the facts, the legal perimeter and the external Scope classification as separate fields.

Figure 1. Direct-emissions completeness requires four source families plus evidence and reconciliation controls. London Reporting Academy learning visual.

Under the GHG Protocol Corporate Standard, direct emissions arise from sources that the organisation owns or controls. The principal activity types are stationary combustion, mobile combustion, process emissions and fugitive emissions. This is a practical source taxonomy for a UAE inventory where the competent authority accepts it.

Federal Decree-Law No. (11) of 2024 instead works through the Source concept and Article 6 determination by MOCCAE and the competent authority. The authority may define a facility, installation, sector or reporting population that is not identical to the parent company’s voluntary operational-control boundary. The reporting file should therefore contain both an “authority inclusion” field and a separate “corporate Scope 1 classification” field.

Stationary combustion is commonly calculated by multiplying fuel consumed by gas-specific emission factors and, where applicable, oxidation or conversion factors. The activity-data challenge is to establish consumption, not simply purchases. For bulk fuels, a basic reconciliation is opening stock plus receipts minus closing stock, transfers, returns and documented non-combustion use. For piped gas, meter completeness, standard conditions, calorific value and billing estimates require review.

Emergency and standby equipment must be present in the source register even if operating hours are low. Generator test runs, fire-pump engines, temporary units and rented boilers are easy to miss because they are maintained by facilities or contractors rather than the main production team.

Start from the vehicle and mobile-equipment master, then map fuel and activity records to each asset. The population may include road fleet, forklifts, mobile cranes, loaders, quarry vehicles, marine craft and other non-road equipment. A finance lease, operating lease, short-term rental or outsourced driver arrangement does not by itself answer whether the emissions sit inside the regulated perimeter.

Reconcile active assets to registration, insurance, fleet, fixed-asset, lease and rental records.

Map fuel-card and depot transactions to vehicle ID, fuel type, date and reporting period.

Investigate cards assigned to inactive vehicles, duplicate transactions, cash fuel and out-of-country use.

Where distance or engine hours are used, document efficiency assumptions and compare with fuel-based data where available.

Separate electric-vehicle electricity from direct fuel combustion; map it to the purchased-energy dataset.

Document personal use, employee-owned vehicles, taxis and logistics contractors separately rather than silently including or excluding them.

Review off-road and temporary construction equipment with operations and project teams, not fleet alone.

Air-conditioning and refrigeration are material in many UAE operations because of climate, building intensity and extensive cooling equipment. The source population should include central chillers, split and packaged units, cold rooms, process refrigeration, vehicles, fire-suppression systems and specialist equipment. Record gas type and charge capacity; similar equipment may contain gases with very different GWPs.

A preferred mass-balance approach uses the gas added to equipment, changes in stored inventory, gas recovered, sent for destruction or transferred, adjusted for equipment acquisitions and disposals. Service invoices that merely state “gas top-up” are not sufficient unless they identify the equipment, gas and quantity. Where a simplified leakage factor is permitted, document why primary movement data are unavailable and how the estimate will be improved.

Map pressure-relief devices, tank vents, pneumatic equipment, compressor seals, valves and other potential release points in oil, gas and industrial systems.

Distinguish routine venting, unplanned release, flare combustion and flare slip; do not use one factor for all pathways without engineering support.

Use leak-detection and repair records, measurements, component counts, throughput, gas composition and accepted factors as the method requires.

For SF6 or other insulating gases, reconcile equipment capacity, additions, recovery, maintenance and disposal.

Capture material incidents and abnormal operations separately and assess whether the normal method remains representative.

Align maintenance and environmental incident systems so that the emissions inventory does not rely only on annual questionnaires.

Use the factor or method required or accepted by the competent authority; record approval where needed.

Select factors representative of fuel, technology, geography and reporting year, and distinguish combustion factors from life-cycle factors.

Calculate CO2, CH4 and N2O separately where required rather than applying one undifferentiated CO2e factor without understanding its content.

Record oxidation factors, carbon content, density, calorific value, standard conditions and all conversions.

For process and fugitive sources, use sector-specific methods and engineering review rather than a generic spend factor.

Version GWPs centrally and assess comparative or base-year impacts before changing them.

Prevent manual factor overwrites in calculation sheets and log all approved exceptions.

A quarry and mineral-processing facility initially calculates direct emissions from purchased diesel and natural gas. The source walk identifies five additional source groups: diesel held in tanks at year end, two rented mobile crushers, emergency generators, process CO2 from a production stage and HFC losses from central cooling and mobile equipment. The contractor operating one crusher follows the facility’s production plan and uses fuel supplied by the facility.

The team expands the source register, reconciles fuel purchases to stocks and issues, obtains engine-hour records for the rented crushers, develops an engineering method for process emissions and creates a refrigerant equipment register. It documents the contractor and lease facts in the boundary memo and asks the competent authority to confirm treatment. The final inventory shows the calculation by source family and retains a reconciliation to the initial fuel-purchase estimate, explaining why the controlled total is higher.