Disclosure focus
This provision is about making sure emissions information is dependable enough to be checked and trusted. In practice, an organisation should report emissions data in a way that is accurate, traceable and capable of being verified, rather than relying on rough estimates or selectively presented figures. The emphasis is on the quality of the data itself and the ability to support it with evidence.
The practical focus is therefore on coverage and consistency across the organisation’s relevant activities, not just a few prominent sites or operations. An organisation should think about whether its reporting captures the full scope it is meant to cover, uses a consistent approach across locations and business units, and can be backed up if reviewed or challenged.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official MOCCAE source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show Art.6(3) sub-elements (LRA working checklist)
Identify who carried out the assurance work.
Describe the process used to check the data.
State whether the check was done internally or by an outside party.
How to prepare it
1Set the reporting boundary first: decide which parts of the business, sites, activities and data sources are in scope for this disclosure, and keep that scope consistent for the period you are reporting.
2Define the items you will treat as reportable for each required point, using a clear internal rule for what counts as the assurance provider, the validation process, and the verification status you will state.
3Gather the supporting records that show how each figure or statement was checked, including working papers, sign-offs, review notes, system outputs or other source material that supports the reported information.
4Prepare the final disclosure content in a usable form, whether that is a short narrative or a set of figures, and make sure it matches the evidence you have assembled.
5Record any exclusions, restatements or methodology changes that affect the numbers or wording, so a reviewer can see what was left out and why the current version differs from earlier information.
6Before submission, compare the draft against the official source and confirm that the wording, scope and evidence trail still align with the legal requirement and your internal records.
Request the data
Request emissions data checks and verification evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How were the emissions figures checked, who reviewed them, and what evidence shows whether they were reviewed internally or by an outside party?
Use your organisation’s own names for the emissions dataset, checking steps, review sign-off and assurance arrangements first, then map them to this request. Keep the wording in your internal language rather than using framework terms unless that is how your team already speaks.
Weak request
Please provide the emissions data verification evidence for the disclosure.
Why it fails: This uses framework language only and does not tell the owner which file, checks, reviewer, period, or boundary to pull. It is too vague to trace the figures back to the source records or to show how the data was checked.
Better request
Please send the [period] emissions dataset for [site / business unit], the checks performed on it, the reviewer or approver, and whether the figures were reviewed in-house or by an outside party. Include the file name, source system, review notes, and any corrections or exceptions so we can trace the numbers back to source records. This is a possible LRA training template only; please adapt it to your organisation and check the official source before sign-off.
Industry examples
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
Set out the basis used to prepare the figures, including who reviewed them and what checks were applied before the draft was assembled.
Context note
Explain what the review and validation details tell the reader about the reliability of the reported information and how far it has been tested.
Fluctuation statement
If the checking approach changed from one period to the next, note whether that was due to a different reviewer, a revised validation process, or a shift between internal and external review.
Content index entry
Art.6(3) Accuracy and verifiability of emissions data — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
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.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
Chasing the wrong team for the emissions file means the person who knows the numbers, checks, or review route never gets asked.
Framework language instead of site terms
Asking for the data using disclosure labels rather than the organisation’s own process names leaves staff unsure which report, tracker, or control sheet you mean.
No boundary set
Starting collection without saying which sites, activities, or business units are in scope leads to a mixed dataset that cannot be traced back cleanly.
Wrong period basis
Pulling figures for the wrong month, quarter, or year creates a mismatch between the numbers gathered and the reporting window being used.
Mixed counting basis
Combining figures built on different counting methods, such as one team’s operational totals and another team’s adjusted totals, makes the dataset internally inconsistent.
Source labels lost
Copying values into a new file without keeping the original file name, system tag, or record label breaks the link to where the figure came from.
Separate groups merged
Putting together populations that should stay apart, such as different sites or different data streams, hides differences that matter for later checking.
No evidence trail
Collecting numbers without saving the supporting notes, screenshots, or file history leaves no clear trail for later review or challenge.
No sign-off record
Finishing the collection step without a named reviewer and date-stamped approval means nobody can show who checked the data before it moved on.
Where judgement is often needed
Acquisition or disposal during the reporting period
Set a clear cut-off for when sites or activities enter or leave the emissions boundary, then explain the date used and how the change affected the figures.
Different country rules for the same activity
Where local definitions or measurement practices vary, use one organisation-wide approach for reporting and note any country-level differences that were translated into that approach.
Operations close to the boundary
Decide in advance how to treat shared services, leased assets, contractors, or other borderline activities, and disclose the rule used to include or exclude them.
Choosing the reporting basis
If more than one reasonable timing or consolidation basis is available, pick one consistently for the period and explain why it gives the clearest picture of the emissions data.
Measured figures versus estimates
Use direct readings where available, rely on estimates only where needed, and state which parts of the dataset were estimated and what method was used to fill the gaps.
Rounding and presentation
Apply one rounding approach across the dataset so totals still reconcile, and note the rounding rule if it could affect small differences in the published numbers.
Protecting sensitive location or people data
Aggregate or mask detail where needed to avoid exposing personal or commercially sensitive information, while still keeping the emissions figures traceable and explain the level of aggregation used.
Validation checks and review trail
Describe the checks used to test the numbers, who reviewed them, and whether the figures were reviewed internally or by an outside party.
Assurance provider selection
If an external reviewer was used, identify the provider and explain the scope of their work; if not, state that the review was internal and describe the control steps applied.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
We completed an external review of our reported climate figures for the year, using an independent assurance provider to test the underlying records and calculations. - Our data checks combined automated validation, manual review of source files, and follow-up queries where figures did not reconcile on first pass. - The final status was external verification, with the reviewer confirming the dataset was suitable for publication after resolving the exceptions we identified.
Illustrates how a company can describe who reviewed the information, how the numbers were checked, and whether the review was done internally or by an outside party. The wording is intentionally generic and synthetic.
Illustrative (synthetic) example — Financial services
We carried out an internal verification cycle for our sustainability metrics before release, with our own control team acting as the assurance provider for this round. - The validation process included cross-checking ledger extracts against source systems, sampling supporting documents, and escalating mismatches for correction before sign-off. - The verification outcome was internal, meaning the company relied on its in-house review rather than an external reviewer for this reporting cycle.
Illustrates the same three datapoints from a different sector, using an in-house review rather than an outside one. The example is fictional and designed only for training.
How companies report Art.6(3) in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Abu Dhabi Commercial Bank (ADCB)
None · United Arab Emirates · 2024
Abu Dhabi Commercial Bank’s 2024 ESG Report includes evidence of external assurance for its Greenhouse Gas (GHG) metrics, with Deloitte providing assurance on the preparation of these metrics as detailed on page 3. The report also references limited assurance of financed emissions measurement (p.34) and details on Scope 1, 2, and 3 GHG emissions assurance (p.103). However, the report does not clearly disclose its data validation process (p.3) nor specify whether the verification status is internal or external, as no explicit statement was found.
First Abu Dhabi Bank (FAB)
None · United Arab Emirates · 2024
First Abu Dhabi Bank’s ESG Report 2024 provides detailed data on greenhouse gas (GHG) emissions, including gross location-based Scope 2 emissions (p.61) and GHG emissions intensity ratios covering Scope 1, 2, and 3 (p.62). The report references assurance over GHG emissions across multiple scopes and categories (p.80), and discusses ongoing efforts to refine data collection and GHG accounting methodologies (p.20). However, the report does not clearly disclose the assurance provider (not found) or explicitly detail the data validation process and verification status, with only unclear references to internal and external reporting processes (p.77).
Aldar Properties
None · United Arab Emirates · 2024
Aldar Properties’ Sustainability Report 2024 provides detailed data on its greenhouse gas (GHG) emissions inventory, consolidating emissions across all subsidiaries (p.73) and breaking down emissions by source and business segment for 2023 and 2024 (p.89). The report also references the use of historical data, surveys, and certifications to estimate scope 1 and scope 2 emissions (p.82), and highlights a 73.1% reduction in scope 3 GHG emissions per m2 for new buildings (p.12). However, the report does not include any information on the assurance provider, data validation process, or verification status, leaving these aspects unclear.
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Scenarios to work through
A group finance team has compiled the year-end emissions figures from three sites. One site used a spreadsheet check by the local sustainability lead, while the other two were reviewed by an outside verifier; the draft note only says the numbers were 'checked'.
QWhat should the preparer do before sign-off so the reader can tell how the figures were checked and by whom?
Reveal model answer →Hide answer ↑The note should spell out the checking method in plain terms and distinguish between checks done inside the business and checks done by an outside party. It should also identify the assurance provider where one was used, so the evidence trail is clear and the status of review is not left vague.
Why this matters · Use a clear, traceable description of how the emissions figures were tested and whether the review was internal or external.
A manufacturing business has emissions data from meters, invoices and estimates. The team has a reconciliation file, but one plant’s estimate was not linked back to source records, and the draft disclosure still presents all figures as fully verified.
QShould the preparer present the whole dataset as equally reliable, or separate the parts that have stronger support from those that do not?
Reveal model answer →Hide answer ↑The preparer should not flatten different levels of support into one blanket statement. The disclosure should reflect the actual validation work done, showing where the data has been checked against source records and where it relies on a weaker method, so the reader can judge the strength of the evidence.
Why this matters · Describe the real level of checking behind each figure, rather than implying every number has the same strength of support.
A logistics company has had its emissions figures reviewed by an external specialist, but the draft report only names the specialist and gives no explanation of what was tested. The internal team also ran a data-quality review, but that is not mentioned.
QWhat information should be included so the disclosure shows both the review route and the process used to test the data?
Reveal model answer →Hide answer ↑The preparer should include both the review route and the validation process in a way that a reader can follow. That means stating who carried out the external review, what kind of checks were performed, and whether any internal validation also took place, so the emissions data can be traced and understood.
Why this matters · A usable disclosure shows both the checker and the checking method, not just a name.
A retail group has updated its emissions figures after finding an error in one store’s activity data. The revised numbers are correct, but the draft note does not explain that the figures were reworked after validation and still does not say whether the final set was internally reviewed or externally checked.
QHow should the preparer handle the final disclosure so it is clear the data can be trusted and the review status is not ambiguous?
Reveal model answer →Hide answer ↑The preparer should explain that the figures were revised after the error was found, then describe the validation steps used on the final set and state whether the final review was internal or external. If an outside verifier was involved, that should be identified as well, so the reader can see how the corrected data was supported.
Why this matters · When data changes, the final disclosure should show the correction, the validation steps, and the review status together.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
UAE
Art.6(3)
within UAE Federal Decree-Law 11/2024: Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects
Open official source →Related & explore
Regular GHG emissions measurement and disclosure → Guide ✓Comprehensive emissions inventory → Guide ✓Emission reduction measures → Guide ✓Disclosure of activity and reduction data → Guide ✓Expected outcomes of emission reduction initiatives → Guide ✓Emissions data retention and accessibility →Show all 15 related disclosures →
FAQ
Questions this page answers
For Art.6(3) under Federal Decree-Law No. (11) of 2024, what data do I need to gather before I start the disclosure?+−
The page says to prepare three datapoints: the assurance provider, the validation checks, and the verification status. Use the step-by-step preparation section to organise those inputs before drafting.
How do I use the Art.6(3) step-by-step preparation section to build a first draft?+−
The page includes a step-by-step 'how to prepare' section plus draft-output support such as narrative starters, visualisation ideas and a content-index line. Use those pieces to turn collected data into a draft disclosure.
What should I include in the evidence pack for Art.6(3) assurance readiness?+−
The page provides an evidence pack with five items to support assurance readiness. It is meant to help you assemble the backing material before review, rather than leaving evidence scattered across teams.
What are the six assurance claims I need to verify for Art.6(3), and how do I use them?+−
The page says there are six assurance claims to verify, each framed around claim, risk and evidence. Use them as a checklist to test whether the disclosure is supportable and whether the evidence pack is complete.
What are the common reporting gaps or mistakes on the Art.6(3) page, and how do I avoid them?+−
The page lists common reporting gaps and mistakes to help you spot weak points before submission. Use that section alongside the evidence pack and validation checks to reduce avoidable errors.
How should I assign ownership for the Art.6(3) disclosure between ESG, HR and data owners?+−
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should be set around who can supply and validate each datapoint. In practice, assign the assurance provider, validation checks and verification status to the people who can evidence them.
What does the Art.6(3) workbook in the Download Centre help me do?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf. The workbook is there to help you organise preparation and assurance inputs in a working format.
How can I use the printable Library Card for Art.6(3) in a reporting workflow?+−
The printable Library Card is part of the Download Centre and is intended as a quick reference alongside the workbook. It can help teams keep the disclosure requirements, evidence and draft-output prompts in view during preparation.
What kind of draft output does the Art.6(3) page help me produce?+−
The page includes draft-output support in the form of visualisation ideas, narrative starters and a content-index line. That makes it easier to move from source data to a report-ready draft.
Can I use the Art.6(3) page to check whether my disclosure is assurance-ready before review?+−
Yes. The page is built around assurance readiness, with six claims to verify, an evidence pack, validation checks and common mistakes to avoid. It is meant to help you test the draft before it goes to review.
How does the Art.6(3) page relate to ESRS E1, and can I reuse the same data?+−
The page notes ESRS E1 (Climate Change) as the closest correspondence. You can treat that as a useful cross-reference and reuse data where it fits, but the page does not say the requirements are identical.
More questions this page can help with
Art.6(3) Federal Decree-Law No. (11) of 2024 disclosure checklist for assurance provider, validation checks and verification statusArt.6(3) evidence pack items for assurance readiness and how to organise themArt.6(3) common reporting mistakes and gaps to avoid in a draft disclosureArt.6(3) Prep & Assurance workbook download how to use the xlsx fileArt.6(3) printable Library Card pdf what is it forArt.6(3) synthetic example disclosure table how to read itArt.6(3) narrative starters and content-index line examplesArt.6(3) step-by-step how to prepare guidance for ESG managersArt.6(3) who should own the disclosure data in HR or ESG teamsArt.6(3) assurance claims claim risk evidence reviewArt.6(3) ESRS E1 climate change data reuse cross-referenceArt.6(3) from company reports table where to find published examples
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