How to Choose a UAE GHG Verifier: Accreditation, Competence and Conflicts of Interest

Technical status. The Decree-Law has been in force since 30 May 2025. Article 6 obligations attach to Sources determined by the Ministry and the competent authority, and the law itself does not prescribe a universal external-verifier accreditation route for every corporate MRV filing. Cabinet Resolution No. 67 of 2024 is a separate carbon-register instrument with more explicit verification-agency requirements. Confirm the applicable programme, authority instruction, accreditation body and approved scope before award.

Educational material. It does not replace Federal Decree-Law No. 11 of 2024, implementing decisions, a competent-authority instruction, legal advice, engineering or scientific expertise, professional judgement or an assurance conclusion.

A verifier can only give a useful conclusion when the engagement has a clear subject matter, criteria, boundary, period, level of assurance, materiality approach and intended use. A technically capable organisation may still be the wrong provider if its accreditation does not cover the required programme or sector, its proposed team lacks relevant process knowledge, it cannot visit material sites, or it helped design the inventory it is being asked to verify.

The most common procurement error is to ask for a quotation for “UAE climate law verification” without defining what this means. The supplier may price a voluntary ISO 14064-3 verification, a limited assurance engagement over selected metrics, a carbon-project validation, or a readiness review. These are not interchangeable. The deliverable, evidence burden, liability, timetable and fee can differ substantially.

A defensible selection process begins with the legal and programme route, then tests the provider against that route.

Use a one-page engagement definition. It should identify the exact route:

Regulatory corporate MRV. Verification or review requested by MOCCAE, an emirate-level competent authority or another authorised body under the Decree-Law.

National Register for Carbon Credits. Verification of emissions reduction, a project or a carbon-credit claim under Cabinet Resolution No. 67 of 2024 and the relevant registry methodology.

Voluntary organisational inventory. Verification against an agreed inventory criterion such as ISO 14064-1 or the GHG Protocol, for management, customer or public-reporting purposes.

Financial or sustainability reporting assurance. An engagement under an assurance standard over climate disclosures or selected metrics; this may sit alongside, but is not automatically identical to, ISO GHG verification.

Readiness review. A non-opinion diagnostic performed before formal verification. It should not be presented as verification or assurance.

For each route, record the intended user, required statement wording, criteria, reporting period, organisational and operational boundary, gases and Scopes, sites, materiality, assurance level, regulator or registry submission date and required language.

Figure 1. Verification purpose must be fixed before accreditation, scope and deliverables can be tested. Original London Reporting Academy practitioner visual.

Accreditation is not a single yes/no field. Ask the bidder to provide:

the accreditation body’s name and whether it is recognised for validation and verification through the relevant international arrangement;

the current accreditation certificate and expiry or surveillance status;

the detailed schedule of accreditation, including sector categories and activities;

the standards and programmes covered;

the office or legal entity covered by the accreditation;

any suspension, restriction, transition or outstanding condition;

a sample statement showing how the accreditation mark will appear for the proposed scope.

ISO/IEC 17029 sets general principles for competent, consistent and impartial validation/verification bodies. ISO 14065 applies these principles to environmental information. ISO 14064-3 provides requirements and guidance for verifying and validating GHG statements, while ISO 14066 addresses the competence of teams and independent reviewers.

The certificate title is not enough. A body may be accredited for one environmental programme but not the required organisational GHG or project scope. It may have a global certificate but propose delivery from an office or branch not included in the accredited scope. EIAC’s requirements, for example, link accredited statements to the approved scope, sector and accredited office and require a process for impartiality risks and potential conflicts.

RFP control. Require the bidder to highlight, on its scope schedule, the exact lines that cover the engagement. The procurement team should independently verify the status in the accreditation body’s public directory.

Cabinet Resolution No. 67 of 2024 concerns the National Register for Carbon Credits. It includes explicit requirements for verification agencies, including ISO-related verification and approval of the verification scope. Those requirements are highly relevant when the subject matter is an emissions reduction or carbon-credit activity under that regime.

They should not, however, be copied automatically into every Article 6 corporate inventory RFP as though the Decree-Law itself had imposed the same external-verifier route. The correct test is:

What instrument or authority instruction applies?

What subject matter is being verified: organisational inventory, reduction project, product, registry record or public disclosure?

What criteria and statement are required?

Is programme-specific approval additional to ISO accreditation?

Where the answer remains unclear, state in the RFP that final award is conditional on written confirmation from the relevant authority or programme owner.

Ask for named people and role allocation. The team should collectively demonstrate:

organisational GHG inventory competence;

knowledge of the chosen inventory criteria and emission-factor hierarchy;

sector knowledge for material emission sources;

technical expertise in combustion, process emissions, refrigerants, waste, electricity or value-chain estimation as relevant;

data-system and internal-control competence;

experience with materiality, sampling and site visits;

Arabic and English capability where needed;

independent technical review and decision-making arrangements.

A verifier with extensive office-based service-sector experience may not be appropriate for cement, metals, oil and gas, quarrying, power, desalination or complex refrigerant systems. Ask the bidder to identify at least three comparable assignments, the source categories reviewed, the size and geography of the site population and the role of each proposed team member.

Key-person control. Make substitution of the lead verifier, sector expert or independent reviewer subject to client approval and equivalent competence evidence.

Independence is not satisfied by a sentence in the proposal. Require a completed conflict declaration covering the provider, its network, affiliates, subcontractors and proposed personnel.

At minimum, ask whether the provider has, during the relevant period:

designed the GHG methodology or organisational boundary;

calculated material parts of the inventory;

selected emission factors or built estimation models;

implemented or configured the emissions software;

prepared the reduction project or baseline being verified;

drafted the public claim or registry application;

provided management services or made decisions for the reporting entity;

received contingent fees linked to a successful opinion, credit issuance or reported reduction;

held a financial, commercial or close personal interest in the entity;

relied on a subcontractor that also advises the entity;

performed a readiness review and then proposed the same individuals for formal verification.

A prior advisory engagement does not always make the whole provider unusable, but the bidder must identify the threat, explain the applicable rule and show safeguards. Possible safeguards include separate legal entities or teams, personnel exclusion, independent review, cooling-off arrangements, restricted access, enhanced quality review or declining the engagement. A safeguard is only credible if it addresses the actual self-review, advocacy, familiarity or financial-interest threat.

Figure 2. A verifier award should combine technical scoring with a separate conflict and eligibility gate. Original London Reporting Academy practitioner visual.

The proposal should state:

which office controls and signs the engagement;

where the lead verifier and specialists are based;

which sites will be visited and why;

what can be performed remotely;

travel assumptions, visas and access requirements;

treatment of free-zone, multi-emirate and overseas data;

how remote techniques will be evaluated for reliability;

how material sites excluded from visits will be covered.

Remote work can be efficient, but it is not a default substitute for observing meters, production systems, fuel storage, refrigerant records, maintenance practices or local data controls. Ask for the risk basis for the site sample, not just the number of site days.

The RFP should require a written approach covering:

Required deliverables may include an engagement plan, information request, opening meeting, site plan, findings log, corrected-inventory reconciliation, management representation, verification report and statement, and a final list of unresolved limitations. A readiness review should produce a diagnostic report, not a verification statement.

Require a transparent fee schedule showing:

planning and risk assessment days;

lead verifier, specialist and independent reviewer days;

site visits and travel;

data population and site assumptions;

number of entities, source categories and reporting systems;

included correction cycles;

translation or local-language support;

out-of-scope rates and change-control triggers;

cancellation, delay and rescheduling terms;

validity period of the quotation.

A low bid can become expensive if the inventory is late, site access changes, Scope 3 is added, or the verifier excludes retesting. Ask bidders to price a defined base case and state unit rates for predictable changes.

Use eligibility gates first, then weighted scoring.

Do not average away a failed gate. A bidder with excellent experience but an unresolved conflict, expired accreditation or wrong scope should not win through a high total score.

Illustrative scenario - not a legal conclusion for a real entity. A UAE industrial group needs assurance over its 2026 organisational inventory for a lender and also plans to register a waste-heat recovery project for carbon credits.

The procurement team initially issues one RFP. During clarification, it separates the work into two lots. Lot 1 is verification of the organisational inventory against agreed corporate criteria. Lot 2 is programme-specific validation and verification for the carbon-credit activity. One bidder is accredited for organisational GHG statements but has no approved project scope. Another has project credentials but helped prepare the project baseline. The group awards the lots to different eligible providers and establishes a common data room with separated access.

Why the decision is stronger: the subject matters, criteria, accreditation scopes and conflicts are tested separately. The group avoids assuming that one verification statement can serve every purpose.

Buying a brand rather than an accredited scope. Correct by checking the certificate schedule and public directory.

Using one vague RFP for inventory, carbon credits and reporting assurance. Separate the subject matters and outputs.

Accepting a generic independence statement. Obtain a network-wide, engagement-specific conflict declaration.

Scoring the firm but not the named team. Assess CVs, authorisations and sector roles.

Treating remote verification as automatically sufficient. Require a risk-based site strategy.

Comparing only total price. Compare assumptions, person-days, correction cycles and exclusions.

Allowing the verifier to create missing evidence. Management must own the inventory, estimates and corrections.

Myth: “An ISO 14065 certificate means the provider can verify any UAE climate-law submission.”

Reality: accreditation is scope-specific, programme requirements can be additional, and the Decree-Law does not itself establish a single universal external-verifier route for every Article 6 filing. The buyer must confirm the purpose, applicable authority or programme, detailed accreditation scope, team competence and independence.

Federal Decree-Law No. 11 of 2024, especially Article 6

Cabinet Resolution No. 67 of 2024 on the National Register for Carbon Credits

ISO/IEC 17029:2019

ISO 14065:2020

ISO 14064-3:2019

ISO 14066:2023

EIAC accreditation requirements and public directory

IAF MD 6 for consistent application of ISO 14065 accreditation