Audit Guidance for Reporting Direct Emissions of Purchased Clean Fuels

As companies use clean fuels certificates to report on their efforts to lower direct emissions, those claims are increasingly subject to external assurance. The credibility of these claims depends on their underlying evidence and whether they’re evaluated against criteria that are suitable for assurance.

This guidance gives reporting entities and assurance providers a consistent basis for evaluating whether contractual instruments (and the market-based direct emissions calculations that rely on them) are supportable. It applies audit criteria to the nine quality criteria established in CEAP’s Market-Based Accounting for Clean Fuels: conveyance, aggregation, market boundaries, vintage, equivalency, attribute allocation, input instrument retirement, default attributes, and tracking and retirement. Each criterion includes criteria for evaluation, illustrative evidence, and consequences of nonconformance.

The guidance also sets out a data hierarchy for calculation inputs, conditions for relying on attestations and prior program assurance, and proposed procedures for dual reporting of physical and market-based direct emissions.

As emissions and climate target-setting programs evolve, this guidance provides an actionable pathway for near-term action and informs hard questions as new rules continue to be defined. The guidance is intended for reporting entities that purchase or use clean fuels, auditors and assurance providers, registry operators and program administrators, and stakeholders interpreting related disclosures.

This guidance was developed through CEAP’s Clean Fuels Series in collaboration with Founding Partner Unilever and the CFS Council.