If your organisation measures or reports greenhouse gas emissions, a common question is whether that information needs to be independently verified.

The answer depends on why the GHG information has been prepared, which reporting requirements apply, and how the information will be used.

In South Africa, greenhouse gas information may be prepared for regulatory reporting, Carbon Tax, corporate or group reporting, customer requirements, voluntary climate disclosures, transactions or other stakeholder requirements.

Not every GHG inventory automatically requires independent verification. However, where verification is required — or where an organisation wants greater confidence in the credibility of its reported information — an independent GHG validation and verification body can assess the information against defined criteria.

What is independent GHG verification?

GHG verification is an independent, evidence-based assessment of a greenhouse gas statement.

For an organisational GHG inventory or carbon footprint, this can include assessing matters such as:

  • organisational and reporting boundaries;
  • material emission sources;
  • activity data;
  • emission factors;
  • calculation methodologies;
  • assumptions and estimates;
  • supporting evidence;
  • data-management systems and controls; and
  • the resulting GHG statement.

The purpose is not for the verifier to calculate the organisation's emissions on its behalf.

The verifier independently evaluates the GHG information and supporting evidence against agreed criteria in order to reach a verification conclusion.

This separation is important. A validation and verification body must protect its impartiality and should not prepare the GHG information that it is subsequently appointed to independently assess.

When might GHG verification be required?

There is no single answer that applies to every organisation.

The requirement for verification depends on the framework under which the GHG information is being reported or used.

South African regulatory GHG reporting

South Africa has a mandatory greenhouse gas reporting framework under the National Greenhouse Gas Emission Reporting Regulations.

The regulations apply to data providers that meet the applicable activities, categories and thresholds. They also provide for the verification of information submitted to the competent authority.

DFFE's technical verification framework describes processes for competent-authority review and independent verification of GHG information submitted under the national reporting system.

Organisations subject to the reporting framework should therefore determine the current verification requirements applicable to their reporting period and circumstances.

Carbon Tax

South Africa's Carbon Tax and national GHG reporting systems are closely connected.

Carbon Tax is administered by the South African Revenue Service (SARS), while national greenhouse gas emissions reporting is administered through the environmental regulatory framework.

The emissions used for Carbon Tax purposes can be determined using approved environmental reporting methodologies or the formulas prescribed under the Carbon Tax legislation.

For organisations within the Carbon Tax system, the quality and consistency of underlying GHG information can therefore have significance beyond environmental reporting alone.

The precise verification requirement should nevertheless be assessed against the current regulatory and tax requirements applicable to the organisation.

Corporate and voluntary GHG reporting

Independent verification may also be commissioned where there is no direct regulatory requirement.

Organisations increasingly use GHG information in:

  • sustainability and climate reporting;
  • corporate or group reporting;
  • customer and supply-chain disclosures;
  • investor or lender information;
  • emissions-reduction targets;
  • procurement requirements;
  • voluntary climate programmes; and
  • other public or stakeholder claims.

In these circumstances, independent verification can provide additional confidence that reported GHG information has been subjected to an objective assessment.

Does a carbon footprint need to be verified?

Not every organisational carbon footprint is legally required to undergo independent verification.

An organisation may prepare a GHG inventory for internal management purposes without requiring an independent opinion.

The need for verification becomes more important where the information is being relied upon externally, where a programme or regulatory framework requires verification, or where stakeholders require independent assurance.

The appropriate question is therefore not simply:

"Do we have a carbon footprint?"

It is:

"What will this GHG information be used for, and what level of independent assurance is required?"

What standards apply to organisational GHG verification?

The ISO 14064 family provides an internationally recognised framework for greenhouse gas quantification, reporting, validation and verification.

ISO 14064-1 addresses the quantification and reporting of greenhouse gas emissions and removals at organisational level.

ISO 14064-3 provides requirements and guidance for the validation and verification of GHG statements.

These standards perform different but complementary functions.

An organisation may, for example, prepare its GHG inventory using ISO 14064-1 as an applicable criterion, while an independent validation and verification body performs the verification using the requirements relevant to the verification process.

The precise criteria used in an engagement depend on the purpose of the GHG statement and the applicable programme or reporting requirements.

What does SANAS accreditation mean?

The South African National Accreditation System (SANAS) is South Africa's national accreditation body.

Accreditation provides formal recognition that a validation and verification body has demonstrated competence to perform specified activities within an approved scope.

For a prospective client, however, an important distinction needs to be understood:

An organisation being accredited does not mean that every service it performs is automatically an accredited activity.

The particular engagement must fall within the validation and verification body's current accredited scope.

A competent validation and verification body should therefore review the proposed engagement, applicable criteria and required technical competence before confirming whether the work can be undertaken within its accredited scope.

What should we prepare before approaching a verifier?

You do not necessarily need a perfect GHG inventory before speaking to a validation and verification body.

However, the organisation should normally understand:

  • what GHG information is being reported;
  • the reporting period;
  • the organisational and operational boundaries;
  • the applicable reporting or programme criteria;
  • why verification is required;
  • who will use the verification outcome; and
  • what supporting data and evidence are available.

Depending on the engagement, the verifier may require the GHG inventory or emissions report, calculation files, activity data, emission factors, methodologies, assumptions, source documentation and evidence of relevant controls.

Discussing the intended verification requirement early can also help clarify what evidence will ultimately need to be available — without the verifier becoming responsible for preparing the inventory itself.

What is the outcome of independent GHG verification?

GHG verification should not automatically be understood as conventional certification.

The principal outcome is normally a verification opinion or statement communicating the validation and verification body's conclusion regarding the GHG statement assessed, subject to the applicable criteria, scope and level of assurance.

The exact form of the output depends on the programme, regulatory framework and engagement requirements.

So, does your organisation need independent GHG verification?

Start with three questions:

1. Why is the GHG information being prepared?

Is it for regulatory reporting, Carbon Tax, corporate reporting, a customer, an investor, a voluntary programme or another purpose?

2. Who will rely on the information?

Will it remain internal, or will regulators, customers, shareholders, lenders or other stakeholders rely on it?

3. What requirements apply?

Does the applicable legislation, programme, reporting standard, contract or stakeholder requirement call for independent verification?

Those answers determine whether verification is mandatory, voluntarily commissioned or unnecessary for the intended purpose.

Where there is uncertainty, the appropriate starting point is to establish the intended use of the GHG information and the applicable verification criteria before deciding on the engagement.

Discuss a GHG verification requirement with CoZero

CoZero is a South African GHG Validation and Verification Body providing independent assessment of organisational GHG inventories, projects and other climate-related information.

CoZero reviews each enquiry to establish the applicable criteria, scope, level of assurance, technical competence, impartiality requirements and whether the requested activity falls within its current accredited scope.

If your organisation is preparing a GHG inventory, carbon footprint or regulatory emissions submission and needs to establish whether independent verification is appropriate, contact CoZero to discuss the requirement.