Author: Hitesh katria
The Environment Agency Abu Dhabi (EAD) established a Facility-Level Measurement, Reporting and Verification (MRV) system for greenhouse gas (GHG) emissions in the Emirate of Abu Dhabi, in accordance with the applicable legal and regulatory framework.
This MRV system is implemented pursuant to Article (6) of Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects, which mandates the measurement reporting, and verification of GHG emissions by sources determined by the Ministry and the relevant Competent Authorities.
Abu Dhabi is increasingly translating its climate ambitions into measurable regulatory requirements.
The programme has now moved beyond policy development into implementation. During its first reporting cycle, approximately 90 million tonnes of CO₂ emissions from more than 250 companies were captured, covering around 80% of Abu Dhabi’s major emitting activities. This demonstrates the scale and strategic importance of the programme.
The current framework applies to facilities within key emissions-intensive sectors, including power, oil & gas, petrochemicals, iron and steel, aluminium and cement, with a threshold of 25,000 tonnes of CO₂e or more of direct emissions during the reporting period. Reporting is conducted at the facility level, with annual submissions covering the preceding calendar year.
The significance for companies is clear: carbon emissions are becoming not only an environmental metric, but increasingly a business-performance and risk metric.
The first reporting cycle has demonstrated that companies need more than a sustainability team collecting information once a year. EAD’s Technical Guidance places increasing emphasis on the consistency, accuracy, traceability and documentation of emissions data.
This requires organisations to establish a reliable chain from:
Source data → calculation methodology → internal controls → management review → regulatory submission → verification readiness
The March 2026 EAD MRV workshop highlighted an important transition point: third-party verification is voluntary until 2027, providing companies with an opportunity to strengthen their systems before verification requirements become more established.
For businesses, this creates a valuable window to move from reactive compliance to proactive readiness.
The strategic opportunity is to use MRV data not simply to produce an emissions report, but to identify where the business can become more efficient and resilient.
1. Establish a reliable carbon baseline: Companies should first develop a robust facility-level emissions baseline covering fuel consumption, process emissions, fugitive emissions, production volumes, emission factors and other relevant operational data. A reliable baseline enables companies to identify differences in emissions intensity between facilities, processes and production lines.
Business benefit: Better visibility can identify energy and operational inefficiencies, creating opportunities for cost reduction alongside emissions reduction.
2. Strengthen carbon data and internal controls: MRV data should be integrated with existing finance, operations, engineering, procurement, sustainability and internal audit processes rather than maintained as a standalone sustainability exercise.Clear ownership, documented methodologies, data-quality controls and evidence trails should be established.
Business benefit: Stronger data controls reduce reporting risk and rework while creating an information platform that can support wider sustainability disclosures, customer requirements, investor reporting and future regulatory requirements.
3. Use emissions data to drive operational efficiency: Once major emission sources are identified, companies should assess practical abatement opportunities such as energy efficiency, process optimisation, waste-heat recovery, electrification, renewable electricity, equipment upgrades and fugitive-emission reduction.Each initiative should be evaluated not only in tonnes of CO₂ avoided but also in terms of CAPEX, operating-cost savings, payback period and potential future carbon exposure.
Business benefit: Decarbonisation can become an operational improvement programme, with emissions reduction linked directly to lower energy and operating costs.
4. Prepare for potential carbon pricing: MRV is also important because reliable emissions data can provide the foundation for future carbon-pricing mechanisms. EAD has previously highlighted the role of carbon pricing in supporting the decarbonisation of emissions-intensive sectors.Companies should therefore begin by asking:
Business benefit: Early scenario analysis can improve capital allocation and reduce the risk of investing in assets that may become less competitive in a lower-carbon economy.
The business case extends beyond regulatory compliance.
Global customers, investors and financial institutions are increasingly seeking credible information on the carbon intensity of products and operations.
Companies that can demonstrate robust emissions data and credible reduction plans may be better positioned to respond to evolving customer and investor expectations.
For energy-intensive sectors such as aluminium, steel, cement and petrochemicals, this could become particularly important as international markets increasingly differentiate between higher- and lower-carbon products.
MRV can therefore provide the foundation for a broader strategic capability:
Measure → Report → Verify → Reduce → Optimise → Compete
The organisations that build this capability early may be better positioned to respond to future carbon costs, customer requirements, financing expectations and regulatory developments.
Companies falling within the MRV framework should consider a structured five-step approach:
The most important shift is from asking “Have we submitted our MRV report?” to asking:
Abu Dhabi’s MRV programme represents an important evolution in environmental governance, moving the market towards greater transparency, accountability and data-driven climate action.
The first reporting cycle demonstrates that the programme is already operating at significant scale. For companies within its scope, the next phase should not simply be about improving the annual emissions submission. It should be about using the underlying data to improve operational efficiency, investment decisions, risk management and long-term competitiveness.
The companies that act early can potentially achieve three outcomes simultaneously: regulatory readiness, operational value and strategic advantage.
The real value of MRV, therefore, is not the emissions report itself. It is the management information behind the report and how effectively companies use that information to build a more efficient, resilient and competitive business.
At BDO UAE, we support organisations across the sustainability transformation journey, including MRV readiness assessments, GHG accounting, monitoring-plan development, data governance, verification readiness and decarbonisation strategy.
Sources:
The Environment Agency Abu Dhabi (EAD) established a Facility-Level Measurement, Reporting and Verification (MRV) system for greenhouse gas (GHG) emissions in the Emirate of Abu Dhabi, in accordance with the applicable legal and regulatory framework.
This MRV system is implemented pursuant to Article (6) of Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects, which mandates the measurement reporting, and verification of GHG emissions by sources determined by the Ministry and the relevant Competent Authorities.
From climate ambition to measurable accountability
Abu Dhabi is increasingly translating its climate ambitions into measurable regulatory requirements.
The programme has now moved beyond policy development into implementation. During its first reporting cycle, approximately 90 million tonnes of CO₂ emissions from more than 250 companies were captured, covering around 80% of Abu Dhabi’s major emitting activities. This demonstrates the scale and strategic importance of the programme.
The current framework applies to facilities within key emissions-intensive sectors, including power, oil & gas, petrochemicals, iron and steel, aluminium and cement, with a threshold of 25,000 tonnes of CO₂e or more of direct emissions during the reporting period. Reporting is conducted at the facility level, with annual submissions covering the preceding calendar year.
The significance for companies is clear: carbon emissions are becoming not only an environmental metric, but increasingly a business-performance and risk metric.
MRV is no longer just a reporting exercise
The first reporting cycle has demonstrated that companies need more than a sustainability team collecting information once a year. EAD’s Technical Guidance places increasing emphasis on the consistency, accuracy, traceability and documentation of emissions data.This requires organisations to establish a reliable chain from:
Source data → calculation methodology → internal controls → management review → regulatory submission → verification readiness
The March 2026 EAD MRV workshop highlighted an important transition point: third-party verification is voluntary until 2027, providing companies with an opportunity to strengthen their systems before verification requirements become more established.
For businesses, this creates a valuable window to move from reactive compliance to proactive readiness.
Turning compliance into business value
The strategic opportunity is to use MRV data not simply to produce an emissions report, but to identify where the business can become more efficient and resilient.1. Establish a reliable carbon baseline: Companies should first develop a robust facility-level emissions baseline covering fuel consumption, process emissions, fugitive emissions, production volumes, emission factors and other relevant operational data. A reliable baseline enables companies to identify differences in emissions intensity between facilities, processes and production lines.
Business benefit: Better visibility can identify energy and operational inefficiencies, creating opportunities for cost reduction alongside emissions reduction.
2. Strengthen carbon data and internal controls: MRV data should be integrated with existing finance, operations, engineering, procurement, sustainability and internal audit processes rather than maintained as a standalone sustainability exercise.Clear ownership, documented methodologies, data-quality controls and evidence trails should be established.
Business benefit: Stronger data controls reduce reporting risk and rework while creating an information platform that can support wider sustainability disclosures, customer requirements, investor reporting and future regulatory requirements.
3. Use emissions data to drive operational efficiency: Once major emission sources are identified, companies should assess practical abatement opportunities such as energy efficiency, process optimisation, waste-heat recovery, electrification, renewable electricity, equipment upgrades and fugitive-emission reduction.Each initiative should be evaluated not only in tonnes of CO₂ avoided but also in terms of CAPEX, operating-cost savings, payback period and potential future carbon exposure.
Business benefit: Decarbonisation can become an operational improvement programme, with emissions reduction linked directly to lower energy and operating costs.
4. Prepare for potential carbon pricing: MRV is also important because reliable emissions data can provide the foundation for future carbon-pricing mechanisms. EAD has previously highlighted the role of carbon pricing in supporting the decarbonisation of emissions-intensive sectors.Companies should therefore begin by asking:
- What would our cost base look like under different carbon-price scenarios?
- Which facilities or products would be most exposed?
- Which investments could reduce that exposure?
- Are we making long-term investments that could create future carbon liabilities?
Business benefit: Early scenario analysis can improve capital allocation and reduce the risk of investing in assets that may become less competitive in a lower-carbon economy.
From carbon reporting to competitive advantage
The business case extends beyond regulatory compliance.Global customers, investors and financial institutions are increasingly seeking credible information on the carbon intensity of products and operations.
Companies that can demonstrate robust emissions data and credible reduction plans may be better positioned to respond to evolving customer and investor expectations.
For energy-intensive sectors such as aluminium, steel, cement and petrochemicals, this could become particularly important as international markets increasingly differentiate between higher- and lower-carbon products.
MRV can therefore provide the foundation for a broader strategic capability:
Measure → Report → Verify → Reduce → Optimise → Compete
The organisations that build this capability early may be better positioned to respond to future carbon costs, customer requirements, financing expectations and regulatory developments.
A practical roadmap for companies
Companies falling within the MRV framework should consider a structured five-step approach:
- Confirm applicability
Validate facility-level applicability, sector classification and the emissions threshold, and identify all relevant emission sources. - Assess readiness
Review existing monitoring systems, data quality, methodologies, controls and reporting processes against EAD requirements. - Build verification-ready systems
Establish clear data ownership, documentation, controls and evidence trails and conduct an internal or mock verification exercise. - Identify decarbonisation opportunities
Develop an emissions-abatement roadmap focused on the largest sources and prioritise initiatives based on financial and carbon impact. - Integrate carbon into business strategy
Introduce emissions-intensity KPIs, carbon-price scenarios and climate considerations into capital investment, operational and strategic decision-making.
The CEO and board perspective
The most important shift is from asking “Have we submitted our MRV report?” to asking:
- Do we know where our emissions come from?
- Can we defend the numbers we report?
- Which emissions sources represent operational inefficiencies?
- What would future carbon costs mean for our business?
- Are we investing today in assets and technologies that will remain competitive tomorrow?
Conclusion
Abu Dhabi’s MRV programme represents an important evolution in environmental governance, moving the market towards greater transparency, accountability and data-driven climate action.The first reporting cycle demonstrates that the programme is already operating at significant scale. For companies within its scope, the next phase should not simply be about improving the annual emissions submission. It should be about using the underlying data to improve operational efficiency, investment decisions, risk management and long-term competitiveness.
The companies that act early can potentially achieve three outcomes simultaneously: regulatory readiness, operational value and strategic advantage.
The real value of MRV, therefore, is not the emissions report itself. It is the management information behind the report and how effectively companies use that information to build a more efficient, resilient and competitive business.
At BDO UAE, we support organisations across the sustainability transformation journey, including MRV readiness assessments, GHG accounting, monitoring-plan development, data governance, verification readiness and decarbonisation strategy.
Sources:
- Environment Agency – Abu Dhabi (EAD), Facility-Level MRV Programme;
- EAD, Technical Guidance for Facility-Level GHG MRV – Version 8 (2026);
- EAD, MRV Workshop Presentation, March 2026; EAD, Abu Dhabi Climate Change Adaptation Plan for the Environment Sector 2025–2050;
- UAE Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects;
- Gulf News, Abu Dhabi tracks 90 million tonnes of CO₂ in first year of climate programme;