Introduction

Some of the earliest greenhouse gas monitoring and reporting has been done by companies and corporations – whether public or private. These companies voluntarily piloted initial quantification and reporting at the corporate level to assess the contribution of their activities to climate change. In the 2000s, with the implementation of emission trading schemes and carbon taxes, the focus shifted to site-level, without necessarily an aggregation at corporate level. To date, little to no full, mandatory, MRV systems have been put into place for corporate reporting – particularly in terms of verification. However, the coexistence of multiple mandatory and voluntary frameworks that companies participate in has implications for the efficiency of the quantification conducted as well as the use of the information in the entities’ internal “climate governance.”

This chapter first briefly presents three of the main reporting frameworks to which multiple French companies participate in or are subject to. France is a particularly interesting example as it is among the few countries – with the United Kingdom – to have made GHG monitoring and reporting mandatory at the corporate level. The second half of this chapter analyzes the impacts of this coexistence of frameworks on efficiencies and internal governance as well as the implications for a growing type of users of emissions performance data: investors.

French entities may be subject to up to four major mandatory or voluntary GHG emissions monitoring and reporting frameworks

In addition to the EU ETS (described in Chapter 5) which covers more than 1,300 French installations, French companies today participate in multiple GHG emission reporting systems. One of the earliest systems is the voluntary CDP Sustainability, formerly known as the Carbon Disclosure Project. In addition, GHG measurement and reporting has been included in statutory sustainable-development reporting requirements (including the Corporate Social and Environmental Responsibility and the mandatory development of Climate Action Plans).

This chapter brings together all the previous ones. Based on the detailed presentation and analysis of the MRV requirements of so many different carbon pricing and management mechanisms – hereafter “carbon pricing mechanisms,” it synthesizes and compares how they answered to the five cross-cutting questions identified in the general introduction to the book:

1. • What are the MRV requirements?

2. • What are the costs for entities to meet these requirements?

3. • Is a flexible trade-off between requirements and costs allowed?

4. • Is requirements stringency adapted to the amount of emissions at stake (materiality)?

5. • What is the balance between comparability and information relevance?

MRV requirements across schemes

The first cross-cutting question – what are the MRV requirements? – is too large to be answered in a synthetic way. This section thus focuses on two components of this question that have a major impact on MRV costs: requirements pertaining to third-party verification and those pertaining to monitoring uncertainty.

Verification requirements are broadly similar across the board

Most carbon pricing mechanisms impose a verification of the reports by an independent third party. Verification requirements are broadly similar across carbon pricing mechanisms:

1. • the third party must be accredited by a regulator for GHG emissions audits and this accreditation tends to be sector-specific;

2. • the third party must assess whether the methods used and the reporting format comply with the relevant guidelines;

3. • the third party must assess the accuracy, i.e., the absence of bias, of the reported figures;

4. • the regulator is allowed to question the opinion of the auditor, but seldom does so;• the third party tends to be paid directly by the verified entity. Although this creates a potential conflict of interest, the risk of losing the accreditation is a much stronger incentive and keeps auditors from being complacent with their client (Cormier and Bellassen, 2013).