Greenhouse gas emissions
Requirement 3.4
This note provides step-by-step guidance to multi-stakeholder groups (MSGs) on how to disclose information related to greenhouse gas emissions.
Introduction
Reducing greenhouse gas emissions is essential to addressing climate change. The extractive industries contribute significantly to emissions, both directly from their operations and indirectly through end-use combustion of oil, gas and coal. Stakeholders can use data reported in line with EITI Requirement 3.4 to inform public debate on extractive sector emissions.
Emissions data is of strong public interest. It supports multi-stakeholder dialogue on a range of governance and transparency issues. For governments it can support the development of national climate commitments and reporting, management of economic risks and enforcement of regulatory measures. For companies and financial institutions, it can help to inform investment decisions. For civil society, it enables scrutiny of government and company commitments and emissions reduction efforts.
Expectations for emissions reporting are evolving rapidly. Companies are increasingly subject to mandatory reporting requirements, such as those from the European Union. Emissions disclosure also features in corporate reporting standards, including from the International Sustainability Standards Board, the Global Reporting Initiative and the Carbon Disclosure Project, among others.
Requirement 3.4 of the 2023 EITI Standard promotes transparency in this area. It encourages companies to disclose greenhouse gas emissions in alignment with existing leading disclosures standards and encourages multi-stakeholder groups (MSGs) to request disaggregated data where feasible. This guidance note emphasises leveraging company reporting for these purposes.
The guidance provides a resource for MSGs in implementing Requirement 3.4. It should be read alongside the EITI’s policy brief, Navigating the energy transition: Data and dialogue to strengthen extractive sector governance, and other guidance relevant to understanding extractive sector emissions, such as reserves and production disclosures, available on the EITI website.
Requirement 3.4: Greenhouse gas emissions
Companies are encouraged to disclose greenhouse gas (GHG) emissions in alignment with existing leading disclosure standards. Where feasible, the multi-stakeholder group is encouraged to request disaggregated disclosures.
Overview of steps
| Steps | Key considerations |
|---|---|
| Step 1: Agree objectives and approach |
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| Step 2: Build an understanding of existing disclosures |
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| Step 3: Collect data |
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| Step 4: Disclose data |
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| Step 5: Analyse disclosures |
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| Step 6: Inform public debate |
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Key concepts
This section provides an explanation of some of the key concepts relevant to the implementation of Requirement 3.4.
Greenhouse gas emissions
Greenhouse gas emissions refer to the release of gases such as carbon dioxide (CO₂) and methane (CH₄), among others, into the atmosphere. These gases trap heat and contribute to global warming. Human activities, including fossil fuel combustion and land use changes, are the main cause of the increase in greenhouse gases in the atmosphere in the last 150 years.
Greenhouse Gas Protocol
The Greenhouse Gas Protocol (GHG Protocol) is a globally recognised standard for measuring and managing greenhouse gas emissions from entities in both the private and public sectors. It categorises emissions by scope (see below) and provides guidelines to ensure consistency in emissions accounting and reporting.
Scope 1, 2 and 3 emissions
Greenhouse gas emissions from entities such as companies are categorised based on their source and the entity’s control over them:
- Scope 1: Direct emissions from sources owned or controlled by the entity, such as emissions from fossil fuel combustion in boilers, furnaces, vehicles and industrial processes.
- Scope 2: Indirect emissions from the generation of purchased electricity, steam, heating and cooling consumed by the entity.
- Scope 3: All other indirect emissions that occur in an entity’s value chain, including upstream and downstream emissions from purchased goods and services and the use of sold products by end-users.
Paris Agreement
The Paris Agreement is a legally binding international treaty adopted in 2015 to combat climate change. It has been signed by 194 states and the European Union, including all EITI implementing countries. The Paris Agreement aims to limit global temperature increases to well below 2°C above pre-industrial levels, with efforts to keep the increase below 1.5°C, by reducing greenhouse gas emissions. Countries must submit nationally determined contributions (NDCs), which describe plans and targets for reducing emissions and adapting to climate change impacts. Countries are required to regularly report emissions through National Inventory Reports.
How to implement Requirement 3.4
Step 1: Agree objectives and approach
The MSG should begin by collectively reviewing the text of Requirement 3.4 to align on its objectives and approach. It should consider the relevance of emissions disclosures to the national context and MSG priorities.
To achieve this, the MSG may wish to:
- Identify potential uses for emissions data. To inform the discussion of objectives, the MSG may wish to discuss potential uses for emissions data and determine how these align with stakeholder priorities. Potential data uses are listed in the box below.
| Benefits | Data uses | Data users |
|---|---|---|
Inform public debate on climate change and extractives
| The extractive industries often contribute significantly to a country’s greenhouse gas emissions. Emissions data enables governments and citizens to identify major emission sources, informing public debate on the linkages between the extractive sector and national climate goals. This can help to inform national energy transition policies. | Government Companies Civil society
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| Assess economic risks | Carbon pricing, import restrictions and investor policies have the potential to affect competitiveness in the extractive sector. Emissions data helps build an understanding of associated economic risks, including potential impacts on government revenues, jobs and local economies. | Government Companies Investors Civil society Communities |
Support national climate commitments and reporting
| EITI member countries submit NDCs to the United Nations Framework Convention on Climate Change (UNFCCC) as part of their Paris Agreement commitments (see “Key concepts” section). While governments often base their NDCs on projections, company data can improve the accuracy of reporting, strengthen the credibility of climate commitments, support monitoring and enhance access to climate finance. | Government Civil society |
| Ensure compliance with carbon pricing, market access and other regulatory requirements | Several EITI countries have carbon pricing mechanisms or carbon credit systems in place or under consideration. 1 Emissions data allows regulators to calculate company obligations, aiding revenue collection and compliance with market access requirements, such as carbon border adjustment mechanisms, where applicable. It also supports environmental impact assessments, monitoring and enforcement of environmental regulations, such as limits on venting and flaring. Emissions data can also enable citizen monitoring of environmental impacts. | Government Companies Civil society organisations Communities |
| Meet market demand | Emissions data allows companies to appeal to environmentally conscious markets and align with industry standards. 2 This may be particularly relevant in the minerals sector where downstream actors may seek information on emissions in their value chains. | Companies Investors End users |
| Prioritise methane abatement efforts | Several EITI countries are fossil fuel producers with potentially profitable opportunities to reduce methane emissions. 3 Emissions data helps governments and companies to prioritise reduction efforts and attract financing for methane abatement. | Government Companies |
- Discuss the level of disaggregation. Based on the identification of potential data uses, the MSG may consider what level of disaggregation best supports its objectives. This discussion should take into consideration the feasibility of companies disclosing data at the desired level of disaggregation. MSGs may want to consider a phased approach that is informed by feasibility considerations and aligned with leading disclosure standards. Options include:
- Global: companies may aggregate their emissions data into global totals.
- National: companies may disclose total emissions per country of operations.
- Project: companies may disclose emissions per project.
- Identify relevant stakeholders. The MSG may need to engage additional stakeholders to advance the remaining steps of this guidance. This could include company departments or government agencies not usually involved in the EITI process, including regulatory agencies tasked with monitoring extractive sector emissions. The MSG could also consider engaging potential data users early on. This could include government agencies handling UNFCCC submissions, regulators enforcing carbon pricing mechanisms or other applicable regulations, downstream actors and industry initiatives, and organisations specialising in local environmental data dissemination.
- Discuss capacity needs. The MSG should discuss whether there are any capacity gaps that could inhibit the implementation of Requirement 3.4. This should include consideration of the feasibility of reporting companies collecting and disclosing emissions data and whether government, companies and civil society have the capacity to interpret the data in a manner that can support accountability. Companies on the MSG that have more established processes for compiling and disclosing emissions data can guide and support the MSG with this step. The MSG is also encouraged to engage with the EITI International Secretariat and external partners to explore how to address capacity gaps.
Step 2: Build an understanding of existing disclosures
The MSG should assess the current status of emissions reporting within the country’s extractive sector. It may consider engaging with reporting companies to request information on their current approaches to compiling and reporting emissions data.
To guide this, the MSG can consider the following questions:
- Are emissions disclosures mandated by national laws and regulations? Many governments require companies to disclose emissions. Such mandates can support the EITI’s goal of promoting systematic disclosures at source and help to ensure stakeholders have accessible and current information.
- What data are companies compiling? While most major publicly listed companies compile and disclose emissions data, state-owned and smaller or privately held companies often have less established practices. The MSG may want to build an understanding of what, if any, emissions data companies currently compile, including which greenhouse gases and emission scopes they cover.
- What methods do companies use to compile and verify data? There are multiple recognised emissions accounting methodologies. Among other aspects, the MSG may want to build an understanding of whether emissions are measured or based on projections and whether data is subject to any internal or third-party verification.
- Which standards are companies aligning with? An overview of leading disclosure standards is provided in Annexe A.
- Where do companies disclose data? Companies typically disclose emissions data through corporate sustainability reports or dedicated climate change reports. Companies may also submit data to regulatory authorities to comply with national or regional requirements.
- What is the level of disaggregation of existing disclosures? While many companies report emissions at the corporate level, some provide data disaggregated by country or project.
Trinidad and Tobago: Pioneering EITI emissions reporting in the oil and gas sector
Trinidad and Tobago, a leading exporter of liquefied natural gas, has been at the forefront of emissions disclosure within the EITI framework. Through an environmental reporting pilot, companies were requested to disclose a range of environmental data, including greenhouse gas emissions, information on water and energy use, environmental permits, certificates and impact assessments, and fines and penalties.
In 2022, the National Gas Company of Trinidad and Tobago became the first company globally to disclose greenhouse gas emissions data through the EITI, reporting Scope 1 emissions along with emissions reduction efforts and various other environmental disclosures. By 2024, 10 companies were participating in the pilot. The government is now considering amendments to national environmental laws to make emissions disclosure mandatory for major emitters.
Source: Trinidad and Tobago EITI (2023). Trinidad and Tobago 2021 EITI Report.
Step 3: Collect data
While compiling emissions data is the responsibility of companies, the MSG may consider taking the following steps to advance data collection:
- Prioritise companies for engagement: The MSG may want to prioritise engagement with companies whose disclosures have the greatest relevance to meeting the objectives agreed in Step 1. Engaging companies with significant emissions could help to ensure the relevance of reporting. The MSG could also gauge the interest and capacity of companies to report. As seen in Trinidad and Tobago’s pilot (see above), it may be possible to start with a few committed companies and expand reporting over time.
- Encourage alignment with leading standards: Where applicable, company reporting should align with existing regulatory requirements. In countries where there are no regulatory requirements, the MSG could encourage companies to compile emissions data in alignment with leading international standards (see Annexe A). The MSG could also encourage companies to compile disaggregated data, where feasible. The MSG may consider convening a discussion with reporting companies to identify and resolve any methodological challenges.
Facilitate data collection: The MSG could provide a standard questionnaire or reporting template to companies (see Nigeria case study below). In countries with existing regulatory reporting requirements, the EITI could engage with relevant government agencies rather than companies to collect data.
Step 4: Disclose data
To ensure effective disclosures, the MSG is encouraged to:
- Focus on existing company reporting. Companies are encouraged to disclose data through public sustainability reports and online disclosures so that EITI reporting does not pose an additional burden. Companies are encouraged to include disaggregated data in their reporting where feasible (see South32 case study below).
- Disclose data through government platforms. In countries where governments maintain online environmental information platforms, these could be used to consolidate and disclose emissions data from companies.
- Consolidate and summarise data in EITI reporting. EITI reporting could summarise key company data, including:
- Scope 1 and 2 emissions (including disaggregated data, where feasible).
- Methodologies for calculating emissions, including whether disclosures align with specific regulatory requirements or international standards.
- Information on whether data has undergone third party verification
- Links to further company disclosures (e.g. websites, sustainability reports, regulatory filings)
Where there is interest and capacity from companies and stakeholder demand, additional disclosures to encourage might include emissions by source, emissions intensity, emissions reduction targets and approaches, and Scope 3 emissions where available and appropriate (noting that these are more difficult to measure and corporate reporting is generally less established for this scope).
South32: Project-level emissions disclosures through sustainability reporting
South32 is a global mining company and EITI supporter with operations in six countries, including Colombia and Mozambique. It is one of the world’s top producers of nickel and manganese and involved in mining several other commodities. The company discloses its greenhouse gas emissions in its annual sustainability reporting. These disclosures are disaggregated at the project level, showing Scope 1 and 2 emissions by operation and source, as well as the emissions intensity of different projects. Data can be downloaded in Excel format through the company’s Sustainability Databook.
Step 5: Analyse disclosures
The MSG should review the comprehensiveness and quality of company disclosures and consider:
- Are there any gaps in disclosures?
- Are disclosures aligned with regulatory requirements and leading standards (see Annexe A)?
- Have disclosures been subject to any verification processes?
- What is the level of disaggregation in disclosures?
- How does the data compare to other information sources (see Further resources section below)?
The MSG should also consider how the data supports the objectives set out in Step 1. Key questions might include:
- What are the linkages between the extractive sector and national climate goals?
- What are the implications of emissions for competitiveness in the extractive sector? What are the potential impacts of this for public finances, businesses, workers and communities?
- What government processes can the data support (e.g., enforcement of carbon pricing mechanisms, NDCs, National Inventory Reports)?
The MSG may want to engage partners or technical experts to facilitate data analysis and discussions on the findings.
Guinea: Carbon pricing in the mining industry
The World Bank is supporting Guinea in implementing a carbon pricing instrument (CPI) for the mining sector, a key part of the country’s strategy to meet its NDCs under the Paris Agreement. Launched in 2021 with the inclusion of the mining sector in Guinea’s NDC update, the project aims to standardise emissions reporting and establish a Monitoring, Reporting and Verification (MRV) system.
Developed in collaboration with the government and the mining industry, the CPI seeks to enhance the global competitiveness of the bauxite and iron ore industries. Revenues from the CPI will be directed towards initiatives to reduce greenhouse gas emissions in industrial and land use sectors.
Key components of the CPI include:
- Greenhouse gas accounting tool: Standardises emissions reporting among mining companies with varying data collection practices, facilitating national NDC implementation reporting in accordance with Paris Agreement commitments.
- MRV system: Modelled after those in Jordan and Sri Lanka, enabling government monitoring of emissions reductions and compliance with the CPI.
- Compliance options beyond internal mitigation: These options include a mitigation fund to support industry and Guinea’s participation in additional greenhouse gas emission reduction efforts and a domestic offsets programme to facilitate emissions trading within the country.
Designed as a model for other countries with significant extractive industries, this initiative aims to demonstrate how company emissions data can drive effective carbon pricing measures that support national policies and global climate goals.
Step 6: Inform public debate
Based on the findings from Step 5, the MSG can identify ways to inform public dialogue on emissions in the extractive sector. This may involve engaging climate stakeholders beyond the MSG.
Where applicable, the MSG should align with national Action for Climate Empowerment (ACE) measures under the UNFCCC and the Paris Agreement, which aim to involve citizens in climate action through education, awareness, participation, information access and international cooperation.
Measures could include:
- Disseminating information: In line with Requirement 7.1, the MSG should ensure that disclosures are understandable, comparable, widely promoted, publicly accessible and contribute to public debate. This may involve:
- Simplifying and summarising information (e.g. factsheets and infographics).
- Using a range of communication channels (e.g. social media, TV, radio, newspapers).
- Addressing linguistic or cultural barriers (e.g. translating information into local languages).
- Facilitating public debate: The MSG may want to engage stakeholders not usually involved in the EITI process (e.g. government agencies, parliamentarians, civil society organisations, journalists, communities) through bilateral meetings, workshops or conferences.
Targets for engagement could include:
- Government agencies leading UNFCCC engagement to ensure data informs NDC updates and national emissions reporting.
- Regulators to ensure data supports enforcement of carbon pricing mechanisms and emissions standards, where applicable.
- Oil and gas regulators and national oil companies to inform methane abatement discussions.
- International development actors involved in climate finance.
- Downstream actors and industry initiatives seeking data on their supply chains.
- Building stakeholder capacity: The MSG may want to partner with technical assistance providers to strengthen the capacity of relevant stakeholders to analyse emissions data and meaningfully engage in discussions that advance greater accountability.
Leveraging EITI requirements on reserves and production
Beyond Requirement 3.4, the 2023 EITI Standard can enhance understanding of the extractive sector’s greenhouse gas emissions through reserves and production disclosures. Implementing countries and companies are encouraged to disclose data on proven economic oil, gas or mineral reserves, where available (Requirement 3.1). This enables analysis of the volume of fossil fuels that could be extracted in the future. Combined with project-level production data (Requirement 3.2), this information can support the estimation of greenhouse gas emissions from fossil fuel combustion by end-users (such as through the Global Registry of Fossil Fuels) and can inform discussions about aligning ongoing or planned extraction activities with emissions reduction goals. Project-level production data can also help to calculate the emissions intensity of production at different projects.
Annexe A: Overview of existing leading disclosure standards
| Disclosure standard | Is data required at the extractives project level? | Summary |
|---|---|---|
| Regulatory standards | ||
| US SEC 33-11275 | No | A draft rule published by the US Securities and Exchange Commission (SEC) in early 2024 would require large companies in the US to report on emissions at the company level. |
| US EPA GHGRP | Yes | The US Environmental Protection Agency’s Greenhouse Gas Reporting Program (GHGRP) requires reporting of greenhouse gas data and other relevant information from large emission sources in the United States. |
| EU CSRD, CSDDD | No | The European Union’s Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), adopted in 2023 and 2024, mandate company-level greenhouse gas emissions reporting for EU-headquartered companies. CSRD requires product-level disclosure. |
| IFRS S2 | No | The International Financial Reporting Standards (IFRS) in 2024 introduced the S2 sustainability standards, requiring companies to report emissions across all three scopes of the GHG Protocol. These standards are implemented at the company level and have been adopted in over 14 countries. |
| EU Methane Regulation | From 2029 | A regulation passed in March 2024 mandates a multi-year period of annual reporting, culminating in Level 5 of the OGMP 2.0 standard for methane (see below), which requires site-specific methane measurements throughout the value chain. |
| EU CBAM | No | The EU introduced the Carbon Border Adjustment Mechanism (CBAM) in 2023 to equalise emissions costs for imported goods with those produced within the EU, aligning with the European Trading System (ETS) for carbon credits. Reporting is asset-level for covered industries. It does not currently cover fossil fuel and mineral upstream production. |
| Voluntary standards | ||
| CDP | No | The Carbon Disclosure Project (CDP), active since 2004, has over 23,000 companies reporting, covering two-thirds of global business capitalisation. Emissions reporting is broken down into upstream, midstream and downstream activities, covering all emissions scopes and sources (e.g. flaring, venting, etc). |
| GRI | Yes (for mining) | The Global Reporting Initiative (GRI), established in 1997, provides standards for reporting on various environmental, social and governance issues. Emissions reporting under GRI covers Scope 1, 2 and 3 emissions across the value chain, emissions intensity and GHG emissions reductions. The GRI 14: Mining Sector Standard recommends disclosure of project-level emissions data. |
| UNGC | No | The United Nations Global Compact (UNGC), founded in 2004, has over 20,000 corporate members. It encourages, but does not mandate, emissions reporting alongside other environmental and governance topics. |
| OGMP 2.0 | No | The Oil and Gas Methane Partnership (OGMP) 2.0 is a methane reporting standard covering companies responsible for around 40% of global oil and gas production. OGMP reporting spans five levels of granularity and empirical rigour. While companies provide project-specific data to the OGMP, the publicly disclosed figures are aggregated at the company level. |
| OGCI | No | The Oil and Gas Climate Initiative (OGCI), established in 2014, is an industry alliance comprising 12 major oil and gas companies representing 25% of global production in 2022, including bp, Eni, Equinor, ExxonMobil and Shell. Since 2021, the OGCI secretariat has aggregated and published some emissions data. |
| Oil and Gas Decarbonisation Charter | No | Announced at COP28, the Oil and Gas Decarbonisation Charter aims for zero Scope 1 and 2 emissions and “near zero” methane emissions by 2030. Signed by 50 companies, including over 30 national oil companies representing about 40% of global oil and gas production, it lacks formal emissions reporting requirements, relying on self-reporting for a collective emissions assessment. |
| Governments | ||
| UNFCCC | No | All parties to the Paris Agreement must report emissions, with 45 Annex 1 countries using a common format and Annex 2 countries facing looser requirements. Reporting can be projection-based and is categorised by economic sector. |
| Article 6 | Yes (future) | No common reporting standard has emerged for state-to-state carbon trading under the Paris Agreement’s Internationally Transferred Mitigation Outcomes, but emissions data must match the scope of whatever activity is being traded in mitigation of greenhouse gas emissions. |
Annexe B: How emissions data can be used in EITI countries
The schema below illustrates potential use cases for emissions data in EITI countries. Use cases are categorised by their national or international scope (vertical axis) and their alignment with market mechanisms or regulatory requirements (horizontal axis). Each dot represents an individual use case.
For example, “Informing NDC revision” (bottom right) is placed in the international regulatory space, reflecting its role in helping governments fulfil Paris Agreement obligations to revise their NDCs. “Emissions from transition minerals” is positioned near international markets as data can allow mining companies to respond to the demand from investors and consumers for low-carbon intensity production.
Numbers after each use case indicate the potential relevance across EITI countries at the time of writing. For instance, while all EITI countries revise their NDCs, 16 are key producers of transition minerals. Lines between dots suggest overlap across different quadrants. For example, “Methane abatement (21)” data could influence both national and international investments. The categories presented in this schema are indicative and not exhaustive.
Further details are available in the pilot presentation and a preliminary country by country analysis.
Further resources
Emissions data
- Several international organisations provide emissions data at no cost. The IEA Methane Tracker publishes estimates of the volume of energy industry methane emissions, classified by type, country and fossil fuel, together with an assessment of the economics of capturing these releases. Other resources include UNEP’s International Methane Emissions Observatory and Methane Alert and Response System and the World Bank’s Global Gas Flaring Tracker.
- Non-profit organisations are increasingly playing a role in making emissions data publicly available. The Global Registry of Fossil Fuels is an open-source database of volumes of fossil fuels and their estimated emissions at country and asset level across all greenhouse gas scopes maintained by Carbontracker. Other resources include RMI’s Oil Climate Index Plus Gas, Climate Trace and the Environmental Defense Fund’s MethaneSAT.
- Private-sector data providers, such as Rystad Energy and Wood Mackenzie, provide proprietary emissions databases, allowing paid users to analyse and benchmark emissions performance at project, company or portfolio level. Remote-sensing firms, such as Kayrros SAS or GHGSat, have developed satellite technologies that companies can use to obtain an independent measure of their emissions. Kayrros makes some of its data available online at no cost.
Other resources
- IPCC Chapter 2 (state of climate change): Provides the basis of emissions factors, which are used by default in most fossil fuel emissions reporting.
- UNFCCC Nationally Determined Contributions Registry: The official repository of plans submitted by national governments to the Paris Agreement process, detailing their estimate of emissions and plans to reduce them.
- World Bank Carbon Pricing Dashboard: A database maintained by the World Bank since 2020 of all carbon pricing measures globally, including trading and credit systems and direct taxation.
- NRGI’s Extracting Emissions: Why Resource-Rich Countries Should Cut Emissions from Extractive Operations: A briefing setting out why cutting extractive sector emissions matters for maintaining the competitiveness of oil, gas and mining operations.
- 1
As of January 2025, EITI carbon pricing mechanisms were in place or under consideration in Albania, Argentina, Colombia, Cote d’Ivoire, Gabon, Germany, Indonesia, Kazakhstan, Mauritania, Mexico, Netherlands, Nigeria, Norway, Philippines, Senegal, UK and Ukraine. Carbon crediting mechanisms were in place or under consideration in Colombia, Ecuador, Indonesia, Kazakhstan, Mexico and UK. See World Bank. State and Trends of Carbon Pricing Dashboard. Retrieved from https://carbonpricingdashboard.worldbank.org/.
- 2
See for example the Initiative for Responsible Mining Assurance’s Standard for Responsible Mining and Mineral Processing, the Copper Mark Standards, the forthcoming GRI Sector Standard for Mining and the Oil and Gas Methane Partnership 2.0 Gold Standard.
- 3
As of January 2025, this included Angola, Argentina, Chad, Colombia, Ecuador, Gabon, Germany, Ghana, Guyana, Indonesia, Iraq, Kazakhstan, Mozambique, Nigeria, Norway, Peru, Trinidad and Tobago and Ukraine. For more information see IEA’s Methane Tracker.
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