# Abu Dhabi Facility MRV: The 25,000 Tonne Threshold and the 2027 Verification Deadline

> Abu Dhabi runs its own facility-level GHG MRV system under EAD. Who is in scope, the 25,000 tCO2e threshold, the 31 March deadline, and when verification becomes mandatory.

**Source:** https://www.esgweise.com/insights/abu-dhabi-facility-mrv-ghg-reporting/
**Author:** Sumit Agarwal
**Published:** 2026-09-26
**Frameworks:** GHG Protocol, ISO 14064
**Countries:** UAE

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## Key points

- Abu Dhabi runs its own facility-level MRV system under Article 6 of Federal Decree-Law No. 11 of 2024. EAD is the Competent Authority and the sole point of contact, so Abu Dhabi facilities do not report separately to MOCCAE.
- Four sectors are covered: Industry, Power (electricity and water), Oil and Gas, and road or rail Transport. Aviation, marine and standalone service businesses are excluded.
- The threshold is 25,000 tCO2e of annual Scope 1 emissions. Only CO2 and methane are captured. Scope 2 and Scope 3 sit outside the system.
- Facilities in covered sectors that fall below the threshold still have to file. They must submit at least one complete year of data on EAD's template to demonstrate that they are below it.
- Registration and reporting are both due by 31 March each year, and registration has to be renewed annually.
- Third-party verification is voluntary today and becomes mandatory from 2027, starting with Reporting Year 2026. The verifier must be accredited with EAD and must conduct a site visit.

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## Introduction

Most commentary on UAE emissions reporting points at the federal picture: [Federal Decree-Law No. 11 of 2024](/insights/uae-federal-decree-law-11-2024/) and the [national MRV platform](/insights/uae-mrv-platform-moccae-ieqt-ghg-reporting/). For a facility physically located in Abu Dhabi, that is the wrong address.

Abu Dhabi operates its own **facility-level MRV system**, run by the **Environment Agency, Abu Dhabi (EAD)**, with its own register, its own template, its own threshold and its own deadline. And the part that should be on a board agenda rather than a compliance checklist: **independent verification is voluntary today and becomes mandatory from 2027, starting with Reporting Year 2026.** The numbers being measured right now are the first that will have to survive a verifier.

## Where the obligation comes from

The system implements **Article 6 of Federal Decree-Law No. 11 of 2024** on the Reduction of Climate Change Effects, which requires sources determined by the Ministry and the relevant competent authorities to measure their emissions and submit periodic reports against approved standards.

Under that framework **EAD is the designated Competent Authority** for the Emirate of Abu Dhabi. EAD establishes and manages the facility register, issues the binding technical guidance, oversees compliance, and manages the list of accredited verifiers.

EAD's own guidance is explicit that all MRV requirements, communications and instructions for facilities in the Emirate are issued by EAD, and that facilities should treat EAD as their **sole point of contact** for measurement, reporting and verification. Abu Dhabi facilities do not report separately to MOCCAE. If your compliance calendar has you filing into the federal platform for an Abu Dhabi site, it is pointed at the wrong regulator.

The system was established in 2024. The first reporting cycle ran in 2025 and the second is running now.

## Who is in scope

Four sectors, and EAD defines them tightly enough that the edges matter.

| Sector | What it covers |
|---|---|
| **Industry** | Physical or chemical transformation of materials into products, including associated on-site combustion. Petrochemicals, iron and steel, aluminium, cement and manufacturing |
| **Power (Electricity and Water)** | Generation of electricity, or production and distribution of desalinated water and associated utilities |
| **Oil and Gas** | Exploration, extraction, processing, refining, storage or transmission of crude oil, natural gas and associated petroleum products |
| **Transport** | Entities operating a **road or rail** fleet from a fixed base of operations in the Emirate |

Two exclusions are worth reading carefully, because both have a second half.

**Aviation and marine transport are excluded** from the transport sector. Fleet means road or rail.

**Standalone service businesses are excluded**, including financial, IT, telecommunications, retail and professional services. But that exclusion applies to standalone facilities only. Where service activities are carried out in direct support of, or as auxiliary functions to, operations within a covered sector, **the facility as a whole remains subject to the applicability conditions**. An administrative building inside an industrial complex is not automatically out.

## The threshold, and the duty that applies below it

The threshold is **25,000 tonnes of CO2 equivalent** of annual Scope 1 emissions. Above it, full MRV applies.

This is the point where most summaries of the scheme stop, and it is the point where they become misleading.

Facilities operating in covered sectors with annual Scope 1 emissions **below** 25,000 tCO2e must still **submit at least one complete year of emissions data using the official EAD reporting template**, in order to confirm their applicability status. Third-party verification is not required for a submission made solely to show you are under the line. The submission itself is.

So "we are a small site, this does not apply to us" is not a conclusion you are entitled to reach privately. It is a filing.

Facilities that fall outside the applicability conditions altogether may still take part voluntarily, subject to EAD approval.

## What the system actually asks for

Narrower than a corporate footprint, and that difference catches people out.

The system covers **Scope 1 only**, and the reporting template captures **carbon dioxide and methane**. Scope 2 and Scope 3 are outside it. A group that already publishes a full inventory cannot lift its existing number into EAD's template, because the boundary is a single facility, the scope is direct emissions only, and the gas coverage is narrower than a full GHG Protocol inventory. The reconciliation between the two is work, and it is work that a verifier will eventually ask to see.

Methodology is **calculation-based, measurement-based or mass balance**.

EAD draws a useful distinction between two documents that come off the same template:

- The **monitoring plan** is the reporting template with the variable data not yet populated. It describes what happens at the facility, how emissions are estimated, what inputs feed the calculation, and what quality assurance is in place.
- The **emissions report** is the same template fully populated for the year.

The monitoring plan is where verification is won or lost. By the time the annual number exists, the methodology that produced it has already been fixed.

## The dates

- **Register by 31 March of the reporting period.** Registration is renewed annually. Holders of an Environmental Permit are treated as registered automatically.
- **Submit the emissions report by 31 March each year**, covering total Scope 1 emissions by source, the methodology used, and any deviations.
- **One template per reporting year, one submission per facility.** An operator running several facilities submits separately for each. There is no group return.
- **Errors are corrected within 30 days** of discovery.
- A **grace period exists for new facilities** in their first year of operation, on conditions, and EAD reserves the right to withdraw it.

Responsibility sits with the **Operator**: whoever operates or controls the facility as owner, as lessee, or through delegated operational control, where control means the authority to make legal, financial and operational decisions. On leased sites and sites run under management contracts, that definition, rather than the title deed, decides who files.

## Verification, and why 2026 is the year that matters

Independent third-party verification is **not mandatory at this stage**. It becomes **mandatory from 2027 onwards, starting with Reporting Year 2026**, under EAD's phased implementation.

Read that sequence twice. The first reporting year that will require verification is the year currently in progress. Verification is retrospective: it tests the monitoring plan, the activity data, the emission factors and the controls that were in place during the year being reported. A decision taken in 2026 about how to meter a fuel stream, or a gap in the data that nobody closed, does not become a verification problem in 2027. It already is one.

The verifier must be **registered and accredited with EAD**, against requirements covering technical competence, independence and the preparation of verification reports, and **must conduct a site visit**.

The same disciplines that make a GHG inventory assurable anywhere else apply here: a documented and current monitoring plan, traceability from the meter or invoice through to the reported figure, defensible emission factors, evidence for every estimate, and a clear record of deviations and corrections. If you have been through [ISO 14064-3 or ISAE 3000 assurance](/insights/iso-14064-3-vs-isae-3000-vs-issa-5000/) before, none of this will be unfamiliar. If you have not, the gap is usually evidence rather than arithmetic.

## What to do now

For a facility in a covered sector, in order.

1. **Settle whether you are in scope**, on EAD's sector definitions rather than on your own description of the business. Test the service exclusion carefully if you sit inside a larger industrial site.
2. **Calculate Scope 1 against the threshold**, on a single-facility boundary, CO2 and methane. If you are below it, plan the submission that demonstrates so.
3. **Register, and diarise the annual renewal.** Registration is not a one-off.
4. **Write the monitoring plan properly**, because it is the artefact verification will test.
5. **Close the data gaps in the 2026 year while it is still running.** Metering, invoices, fuel analyses and the evidence trail are far cheaper to fix now than to reconstruct in 2027.
6. **Reconcile against your group inventory**, if you publish one. Two different numbers for the same site, produced on different boundaries, is a question worth being able to answer before someone else asks it.

## How ESGweise helps

ESGweise supports facilities on greenhouse gas quantification and verification readiness, including [GHG inventory work under the GHG Protocol and ISO 14064](/insights/iso-14064-ghg-quantification-verification/), monitoring plan design, data quality and evidence trails, and independent [assurance and verification](/services/assurance/) under ISAE 3000 and ISO 14064-3. See also our work on [sustainability and emissions reporting](/services/reporting/).

## References and sources

- [EAD Facility-Level MRV Reporting portal](https://facilitymrv.ead.ae/), including the Technical Guidance Document and the official reporting template
- Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects, Article 6
- [Environment Agency, Abu Dhabi establishes framework to verify greenhouse gas emissions](https://www.mediaoffice.abudhabi/en/environment/environment-agency-abu-dhabi-ead-establishes-framework-to-verify-greenhouse-gas-emissions-across-emirate/), Abu Dhabi Media Office, September 2026

## Conclusion

Abu Dhabi's MRV system is not a softer local version of the federal regime. It is the regime, for facilities in the Emirate, with a named regulator, a published threshold, a fixed annual date and a verification requirement arriving on a known schedule.

The threshold gets the attention. The two things that will actually cost people are quieter: that being below 25,000 tonnes is a filing rather than an exemption, and that the year whose data must first survive independent verification is the one already underway.

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## Frequently asked questions

### Does my Abu Dhabi facility report to EAD or to MOCCAE?

To EAD. Under Article 6 of Federal Decree-Law No. 11 of 2024, EAD is the designated Competent Authority for facilities in the Emirate of Abu Dhabi, and EAD's guidance states that facilities should treat it as their sole point of contact for all measurement, reporting and verification matters. Abu Dhabi facilities do not file separately into the federal platform.

### What is the emissions threshold for Abu Dhabi's MRV system?

25,000 tonnes of CO2 equivalent of annual Scope 1 emissions. Facilities at or above that level must complete the full MRV process, including third-party verification once verification becomes mandatory.

### We are below 25,000 tonnes. Do we have to do anything?

Yes, if you operate in a covered sector. EAD requires facilities in covered sectors that fall below the threshold to submit at least one complete year of emissions data on the official reporting template in order to confirm their applicability status. Third-party verification is not required for a submission made solely to demonstrate that you are below the threshold, but the filing itself is not optional.

### When does third-party verification become mandatory in Abu Dhabi?

From 2027 onwards, starting with Reporting Year 2026, under EAD's phased implementation approach. Verification is not mandatory at this stage. That means the emissions you are measuring during 2026 are the first year that will have to withstand independent verification, so the data quality decisions being made now are the ones a verifier will test later.

### Which greenhouse gases and which scope does the system cover?

Direct, Scope 1 emissions only, and the reporting template captures carbon dioxide and methane. Scope 2 and Scope 3 are outside the current system. That is narrower than a full corporate inventory under the GHG Protocol, so a facility that already reports a group-level footprint cannot simply submit the same number.

### Who is responsible for reporting, the owner or the operator?

The Operator, meaning whoever operates or controls the facility, whether as owner, as lessee, or through delegated operational control. Control here means the authority to make legal, financial and operational decisions about the facility. Where a site is leased or run under a management contract, that definition decides who files.


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Published by ESGweise Global LLC, Dubai. https://www.esgweise.com