Measuring and reporting emissions to NEA: the two thresholds, the Monitoring Plan and the Emissions Report

Two tiers, not one

This is the most commonly misunderstood obligation in Singapore's climate regime, because people read about the carbon tax, see the 25,000 tonne figure, and conclude that smaller facilities have nothing to do. That is wrong.

If your facility sits between 2,000 and 25,000 tCO2e, you have a real, annual, legal reporting obligation even though you owe no tax.

The Monitoring Plan

The Monitoring Plan (MP) is the document that says, in advance, how a facility will measure its emissions. It comprises NEA's Monitoring Plan Template plus supporting documents, and it defines:

• the emission sources and streams at the facility
• the measurement or calculation approach used for each
• the measurement tiers applied
• the data management procedures behind the numbers

It must be submitted to NEA for approval through EDMA. Deadline: by 31 December of the year following the year in which the facility crossed the threshold.

The logic is worth understanding. Regulators approve the method first and check the output afterwards, because it is far cheaper to fix a flawed measurement approach before a year of data has been collected against it.

The Emissions Report

The Emissions Report (ER) is the annual filing. It is prepared in accordance with the approved Monitoring Plan and contains:

• activity data (how much fuel burned, how much material processed, and so on)
• the computation for each stream of direct greenhouse gas emissions
• total direct greenhouse gas emissions

Deadline: by 30 June of the year following the reporting period.

Taxable facilities must have the Emissions Report verified by an independent third party before submission.

EDMA

The Emissions Data Monitoring and Analysis (EDMA) system is the online channel for all of this. Procedures required under the Carbon Pricing Act are carried out through it.

EDMA is not only a carbon tax portal. It is also the submission channel for Energy Conservation Act obligations, for submissions under the Public Utilities (Water Supply) Regulations, and for sulphur dioxide submissions. For many industrial companies it is the single regulatory front door for energy, emissions and water reporting.

Note that the EDMA site itself sits behind a login and carries no public content, so the public-facing requirements and guidance documents live on NEA's website instead.

NEA's guidelines

NEA publishes Greenhouse Gas Emissions Measurement and Reporting Guidelines in parts:

• Part 1 - introduction and the requirements applying to reportable and taxable facilities (with separate versions for reporting years 2019 to 2023 and for 2024 onwards)
• Part 2 - the Monitoring Plan and its template
• Part 3 - the Emissions Report and verification

NEA also publishes a spreadsheet for estimating reckonable greenhouse gas emissions from combustion of common fuel types, along with default emission factors for fuel combustion and for industrial processes and product uses.

Why this is useful beyond compliance

A facility that has an NEA-approved Monitoring Plan and a verified Emissions Report already holds an audit-ready Scope 1 dataset. That is exactly what will be needed for ISSB-based climate disclosures under the SGX and ACRA regime, and for the external limited assurance that begins in FY2029. Companies that treat carbon tax reporting and climate disclosure as two unrelated projects end up paying for the same data twice.