Every UAE entity in scope of UAE Federal Decree-Law 11/2024 must file an annual greenhouse gas (GHG) inventory with the Ministry of Climate Change and Environment (MOCCAE). The filing is submitted via the National MRV portal at mrv.ae in the prescribed IEQT workbook format. The first filing was due 30 May 2026; subsequent filings are due each year on the same date.
This guide walks the procedure step by step. It reflects the workflow we ship inside SuperESG, which has produced MOCCAE-format submissions for tenants across retail, hospitality, manufacturing, free-zone services, and family conglomerates.
Step 1: Define the organisational and operational boundary
Article 4 of ISO 14064-1:2018 requires the entity to declare both an organisational boundary (which legal entities are included) and an operational boundary (which emissions sources are included). The GHG Protocol Corporate Standard recognises two methods:
- Equity share approach. Account for emissions in proportion to ownership share. Common for joint ventures and minority-held subsidiaries.
- Operational control approach. Account for 100% of emissions from operations the entity controls. Most common for UAE conglomerates and the default for the MOCCAE filing.
Document the chosen approach in the IEQT workbook's Methodology sheet. The choice is sticky; once declared, it should remain consistent across reporting years to enable year-over-year comparison.
Step 2: List every facility, property and asset in scope
Produce a master list of every location, asset and equipment within the operational boundary. For a typical UAE conglomerate this includes:
- Each outlet, store, restaurant, branch, warehouse, factory, office or hotel property
- Owned-and-operated fleet vehicles
- Leased space where the entity controls the utility account
- On-site generation assets (diesel generators, on-site solar, gas turbines)
- Refrigeration and HVAC equipment that received refrigerant top-ups during the year
Each facility needs a unique code (e.g. DUB-MAIN, AUH-001), a city, an emirate, a UAE utility-region tag (DEWA, AADC, EWEC, FEWA), and the activity period it was operational during the reporting year.
Step 3: Collect Scope 1 activity data
Scope 1 covers direct emissions from sources the entity owns or controls. For most UAE entities the principal categories are:
| Category | Activity data | Factor source |
|---|---|---|
| Stationary fuel combustion | Litres of diesel, kg of LPG, m3 of natural gas used in boilers, generators, kitchens | DEFRA 2024 |
| Mobile fuel combustion | Litres of petrol or diesel used by owned fleet | DEFRA 2024 |
| Refrigerant emissions | kg of refrigerant top-up by gas type (R-410A, R-32, R-134a, R-404A) | IPCC AR6 GWP100 |
| Process emissions | Specific industrial processes, where applicable | IPCC sector guidance |
Refrigerant emissions are the most commonly underestimated Scope 1 category in UAE hospitality and QSR. A single chiller top-up of 10 kg of R-410A is equivalent to 20.8 tCO2e, more than a year of electricity at a small office.
Step 4: Collect Scope 2 electricity consumption
Pull twelve months of electricity bills for every facility in the inventory. For UAE entities served by DEWA, AADC, EWEC or FEWA, the bill includes the kWh consumed and the AED amount billed. The kWh figure is the primary input; the AED figure is useful for intensity ratios but not used in the emissions calculation.
Where a property is served by a non-utility supply (an on-site PPA with REC certificates, for example), document the supply structure separately. RECs allow Scope 2 to be reported on a market-based basis at zero kgCO2e/kWh, but the documentation must be retained.
Step 5: Apply the correct sub-region emission factor
The UAE grid is not homogeneous. Apply the published sub-region factor that matches the property's utility:
| Utility | Coverage | kgCO2e / kWh (2024 vintage) |
|---|---|---|
| DEWA | Dubai | 0.420 |
| AADC | Abu Dhabi central distribution | 0.355 |
| EWEC | Abu Dhabi western region and bulk supply | 0.480 |
| FEWA | Ras Al Khaimah, Ajman, Umm Al Quwain, Fujairah | 0.500 |
Each factor must be cited in the IEQT workbook's Methodology sheet with its source and vintage year. SuperESG ships these factors in its published factor library, refreshed annually.
Step 6: Compute kgCO2e per row and aggregate by scope
For each row of activity data, multiply the quantity by the applicable emission factor to produce kgCO2e. Convert to tonnes (divide by 1,000) for the headline figures. Aggregate to:
- Total Scope 1 emissions (tCO2e)
- Total Scope 2 emissions on a location-based basis (tCO2e)
- Total Scope 2 emissions on a market-based basis, where applicable (tCO2e)
- Total combined Scope 1 + Scope 2 (tCO2e)
Retain the row-level calculation. The IEQT workbook requires totals, but in a MOCCAE inspection the inspector may ask for the underlying calculation. Do not aggregate-and-discard.
Step 7: Populate the MOCCAE IEQT workbook
The IEQT workbook is a prescribed XLSX with the following sheets:
- Cover: entity name, trade licence number, reporting period, signatory.
- Inventory boundary: organisational and operational boundary declaration.
- Facility list: every property, with code, location, utility region.
- Scope 1 activity data: row per fuel category per facility.
- Scope 2 electricity: row per facility per month, with utility tag.
- Emission factors applied: every factor used, with source citation and vintage.
- Totals and aggregates: Scope 1, Scope 2 (location and market), total.
- Methodology: standards cited (ISO 14064-1, GHG Protocol), boundary approach, estimation methods used.
Cells are validated server-side at mrv.ae. A submission with the right numbers in the wrong cells is rejected. Generating the workbook from a structured ledger eliminates this class of error.
Step 8: Attach supporting evidence and submit
The mrv.ae submission accepts the IEQT workbook plus an evidence pack (PDF or ZIP) that includes:
- A sample of utility bills covering the Scope 2 reporting period
- Refrigerant top-up service records
- Methodology document confirming standards applied
- Signatory authorisation letter
- Verification statement, where ISO 14064-3 verification was performed
Submit before 23:59 UAE time on 30 May. Late submissions are accepted but trigger a separate violation under Cabinet Resolution 67/2024 Article 12. Submission generates an acknowledgement reference that should be retained.
Step 9: Archive the audit trail for five years
Article 6 of Federal Decree-Law 11/2024 requires five-year retention of every supporting document. This includes:
- Every utility bill in the reporting period
- Meter reading logs, where direct readings were used
- Refrigerant service records
- Emission factor source documents (PDFs from IEA, DEFRA, IPCC publications)
- The IEQT workbook as submitted
- The mrv.ae submission acknowledgement
- Any post-submission correspondence with MOCCAE
Archive these in a structure that allows retrieval by reporting year. SuperESG enforces five-year retention automatically and surfaces every supporting document inside the auditor workspace, so a MOCCAE inspector or external assurance firm can trace any tonne back to its source bill in one click.
Five common mistakes to avoid
From the MOCCAE filings we have walked through with tenants, these are the five mistakes that turn up most often.
- Using a single national emission factor instead of the sub-region utility factor. An FEWA-served property in Ras Al Khaimah using the national average understates the actual emissions by around 16%.
- Forgetting refrigerant top-ups. A 10 kg R-410A top-up is 20.8 tCO2e. For UAE hospitality and QSR, refrigerants can represent 5 to 15% of total Scope 1.
- Filing without a documented boundary. The Methodology sheet must state operational-control or equity-share. Missing this triggers a request for revision.
- Using kWh figures from a slide deck instead of utility bills. The IEQT workbook submitted figures must be reproducible from primary source documents.
- Treating Scope 3 categories as Scope 2. Purchased goods, business travel and employee commute are Scope 3. Reporting them as Scope 2 inflates Scope 2 and breaks comparability with peers.
How SuperESG handles the procedure
SuperESG turns the nine-step workflow above into a guided platform sequence:
- Onboarding declares the boundary and the facility list.
- Bills are uploaded (forwarded by email, dragged into the bill OCR, or pushed via API). AI extracts kWh and AED.
- The right sub-region factor is applied automatically based on the property's emirate and utility tag.
- Every kgCO2e value is computed and stored as a ledger row with factor source, evidence URL, and timestamps.
- The IEQT workbook generates in one click from the ledger.
- The submission and acknowledgement are archived inside the platform alongside every supporting document.
- The audit trail is preserved for five years; auditors are invited via read-only scoped tokens.
Open a free tenant to run this on your own data. The first five properties are free, forever, under our MOCCAE Essentials tier.
Frequently asked questions
What is the MOCCAE GHG inventory?
The MOCCAE GHG inventory is an annual greenhouse gas emissions disclosure that every UAE entity must submit to the Ministry of Climate Change and Environment under Federal Decree-Law 11/2024. It quantifies Scope 1 (direct) and Scope 2 (purchased electricity) emissions for the reporting year in accordance with ISO 14064-1:2018 and the GHG Protocol Corporate Standard, and is submitted via the National MRV portal at mrv.ae.
What format does MOCCAE require?
MOCCAE prescribes the IEQT (Inventory, Emissions, Quantities, Targets) workbook format, hosted on the National MRV portal at mrv.ae. It is a multi-sheet XLSX with mandatory cells for organisational boundary, facility list, Scope 1 activity data, Scope 2 electricity by utility, applied emission factors, total kgCO2e and tCO2e per scope, methodology citations, and verification status. Submissions in any other format are rejected.
Which emission factors should I use?
For UAE-purchased electricity, use the published sub-region factor: DEWA 0.420 kgCO2e/kWh (Dubai), AADC 0.355 (Abu Dhabi central), EWEC 0.480 (Abu Dhabi west and bulk supply), FEWA 0.500 (Northern Emirates). For fuels, apply DEFRA 2024 combustion factors. For refrigerants, apply IPCC AR6 100-year Global Warming Potential. For water, apply UAE-specific factors that account for seawater desalination. Every factor used in the submission must be citable to a published source with a vintage year.
How long does a MOCCAE filing take?
End to end, a first-time filing for a small to medium UAE entity typically takes between 30 and 90 days when done manually. The variable is data collection: pulling twelve months of utility bills, identifying refrigerant top-ups, and assembling the boundary list. Once activity data is in a structured ledger, the conversion to the IEQT workbook and submission via mrv.ae takes hours, not weeks. SuperESG generates the IEQT workbook in one click from your ledger.
Do I need to file Scope 3 in the first cycle?
No. Scope 3 (value-chain emissions including purchased goods, business travel, employee commute, and use of sold products) is encouraged but not mandatory in the first MOCCAE filing cycle. ADX-listed entities and entities with IFRS S2 obligations have additional Scope 3 expectations starting in FY26. For the MOCCAE floor obligation, Scope 1 and Scope 2 are required.
What if I am missing utility bills?
Reasonable estimation is permitted under ISO 14064-1, but the estimation method must be documented and the missing data flagged. Common estimation methods include using the average of available months, extrapolating from prior-year consumption, or using utility-provided aggregated annual data. Estimated figures must be disclosed as estimates in the IEQT workbook so that MOCCAE inspectors can assess data quality. Do not file fabricated figures.
Can a consultant file on my behalf?
Yes, but the legal obligation remains with the entity. If a consultant prepares the inventory and the inventory turns out to be materially misstated, the entity is the party penalised under Cabinet Resolution 67/2024, not the consultant. This is why it is critical that the entity retain the source documents and the working ledger in-house, not on the consultant's laptop.
Primary sources
- UAE Federal Decree-Law 11/2024, Articles 4 to 8 — UAE Legislation Portal
- Cabinet Resolution 67/2024 — penalty schedule
- National MRV system — mrv.ae IEQT workbook specification
- Ministry of Climate Change and Environment — moccae.gov.ae
- ISO 14064-1:2018 — Quantification and reporting of GHG emissions and removals at the organisation level
- GHG Protocol Corporate Standard — World Resources Institute and World Business Council for Sustainable Development
- DEFRA 2024 Greenhouse Gas Conversion Factors
- IPCC AR6 — 100-year Global Warming Potential values for refrigerants
- IEA 2024 — UAE national and sub-region grid emission intensity
Updated 31 May 2026 to reflect the IEQT workbook structure as of the 2025 to 2026 reporting cycle. Material changes to the workbook structure published by MOCCAE will be reflected in future revisions of this guide.