What Malaysian Companies Need to Prepare Before a GHG Audit

Takeaways

  • Malaysia’s National Sustainability Reporting Framework (NSRF) is accelerating expectations for credible and verifiable greenhouse gas (GHG) disclosures
  • Organisations reporting under IFRS S2 must strengthen carbon data management, governance, and internal controls
  • ISO 14064 provides an internationally recognised framework for GHG accounting and verification readiness
  • GHG audits increasingly require traceable data, documented methodologies, and cross-functional governance structures
  • Digitalising carbon data collection systems can significantly improve audit readiness, data accuracy, and verification efficiency
  • Early preparation reduces assurance risks, improves reporting quality, and strengthens stakeholder confidence

As Malaysia accelerates the adoption of the National Sustainability Reporting Framework (NSRF), greenhouse gas (GHG) emissions reporting is becoming a key area of focus for organisations across industries.

Companies are increasingly expected to disclose reliable climate-related information aligned with IFRS S2 Climate-related Disclosures. This includes Scope 1, Scope 2, and in many cases, Scope 3 emissions.

However, reporting carbon emissions is no longer only about publishing numbers in a sustainability report. Investors, regulators, customers, and financial institutions are placing greater emphasis on the credibility and assurance of sustainability data.

This means organisations must prepare for GHG audits and verification processes with the same level of rigour traditionally applied to financial reporting.

Table of Contents

The Growing Importance of GHG Assurance Under NSRF and IFRS S2

Malaysia’s NSRF is aligned with the standards developed by the International Sustainability Standards Board (ISSB), particularly IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures.

Under IFRS S2, organisations are expected to disclose:

  • Gross Scope 1 emissions
  • Gross Scope 2 emissions
  • Relevant Scope 3 emissions
  • Climate-related risks and opportunities
  • Climate targets and transition plans
  • Metrics used to monitor climate performance

As disclosure expectations evolve, assurance over sustainability and carbon-related information is expected to become increasingly important within the reporting ecosystem.

This means organisations must be able to demonstrate that their carbon emissions data is:

  • Accurate
  • Complete
  • Consistent
  • Traceable
  • Supported by documented evidence

In practice, this requires organisations to move beyond fragmented spreadsheets and ad hoc calculations towards more structured carbon data management systems supported by governance and internal controls.

What Is a GHG Audit?

A GHG audit, commonly referred to as GHG verification or carbon verification, is an independent assessment of an organisation’s greenhouse gas emissions inventory and reporting processes.

The objective of the audit is to evaluate whether the reported emissions data fairly represents the organisation’s actual emissions and whether the methodologies used comply with recognised standards and reporting principles.

A GHG audit typically reviews:

  • Organisational and operational boundaries
  • Emissions calculation methodologies
  • Activity data sources
  • Emission factors applied
  • Data collection systems
  • Internal controls and governance
  • Supporting documentation and evidence
  • Reporting consistency and transparency

The verification process is essential in strengthening the credibility of sustainability disclosures and improving confidence among investors, customers, regulators, and other stakeholders.

The Role of ISO 14064 in GHG Audit Preparation

One of the most widely recognised frameworks for greenhouse gas accounting and verification is ISO 14064.

ISO 14064 provides guidance for organisations to quantify, monitor, report, and verify greenhouse gas emissions consistently and transparently. It is widely used to strengthen the credibility of emissions disclosures and support third-party verification processes.

For Malaysian organisations preparing for NSRF and IFRS S2 reporting, ISO 14064 provides a structured approach to:

  • Establishing organisational GHG inventories
  • Defining operational and reporting boundaries
  • Managing emissions calculations and methodologies
  • Improving documentation and traceability
  • Supporting verification and assurance readiness

The importance of ISO 14064 is expected to increase further as sustainability assurance requirements continue to mature in Malaysia’s reporting ecosystem. Recent developments within the global carbon reporting landscape are also moving towards greater harmonisation between ISO standards and the GHG Protocol to improve consistency in emissions reporting and verification practices.

Organisations that align early with recognised carbon accounting frameworks are generally better positioned to manage future regulatory expectations and assurance requirements.

What Malaysian Companies Should Prepare Before a GHG Audit

1. Define Organisational and Operational Boundaries Clearly

One of the most common issues during GHG verification is inconsistent boundary setting.

Organisations must clearly determine:

  • Which subsidiaries and operations are included in reporting
  • Whether the reporting approach follows operational control or financial control principles
  • How joint ventures and leased assets are treated
  • Which facilities and business activities fall within the reporting boundary

Without clearly established boundaries, organisations risk double counting, omissions, and inconsistencies across reporting periods.

2. Strengthen Carbon Data Collection Systems

Reliable GHG reporting depends heavily on the quality, consistency, and traceability of activity data collected across operations.

Many organisations continue to rely on decentralised spreadsheets, manual calculations, and disconnected reporting processes. While this may be manageable at an early stage, it often creates significant challenges during GHG audits and verification exercises, particularly when organisations need to consolidate data across multiple facilities, departments, or subsidiaries.

Before undergoing a GHG audit, organisations should assess whether their carbon data management systems are:

  • Standardised across departments
  • Consistent across reporting periods
  • Traceable to source documentation
  • Subject to internal review and approval processes
  • Properly documented and archived

Examples of supporting evidence commonly reviewed during verification include:

  • Electricity and utility bills
  • Fuel consumption records
  • Refrigerant top-up logs
  • Production and operational data
  • Transport and logistics records
  • Waste disposal records
  • Supplier and procurement information

As assurance expectations under NSRF and IFRS S2 continue to increase, organisations should also consider digitalising their carbon data collection and management processes through dedicated ESG or carbon management software solutions.

Digitalised systems can help organisations:

  • Improve data accuracy and consistency
  • Reduce manual calculation errors
  • Enhance data traceability and audit readiness
  • Streamline multi-site data consolidation
  • Monitor emissions performance more efficiently
  • Strengthen internal governance and reporting controls

More importantly, digitalisation allows organisations to respond more efficiently to verification requests by ensuring supporting evidence and calculations are centrally managed and readily accessible.

Weak data traceability and fragmented documentation remain among the leading causes of delays and findings during GHG verification exercises. Organisations that invest early in structured and digitalised carbon data systems are generally better positioned to manage assurance requirements confidently and efficiently.

3. Improve Documentation and Methodology Governance

A common misconception is that accurate calculations alone are sufficient for audit readiness.

In reality, GHG verification also focuses heavily on the transparency and consistency of methodologies and assumptions used.

Organisations should maintain documented records for:

  • Emission factors applied
  • Calculation methodologies
  • Data assumptions and estimations
  • Changes in reporting methodologies
  • Internal reviews and approvals
  • Version control and reporting adjustments

Strong documentation practices improve transparency and reduce the likelihood of audit disputes or restatements.

4. Assess Scope 3 Emissions Readiness

Scope 3 emissions are becoming increasingly important under IFRS S2 and global supply chain expectations.

Unlike Scope 1 and Scope 2 emissions, Scope 3 emissions often involve complex value chain data that may require collaboration with suppliers, logistics providers, contractors, and customers.

Companies should begin by identifying material Scope 3 categories such as:

  • Purchased goods and services
  • Transportation and distribution
  • Employee commuting
  • Business travel
  • Waste generated in operations
  • Capital goods
  • Use of sold products

Although many organisations are still at an early stage in Scope 3 reporting, early preparation allows businesses to gradually improve data quality and supplier engagement over time.

5. Establish Strong Internal Governance and Accountability

Carbon reporting is no longer solely a sustainability function. It increasingly requires integration across finance, operations, procurement, risk management, and internal audit functions.

Organisations preparing for GHG audits should establish:

  • Clear roles and responsibilities
  • Internal approval and review procedures
  • Data ownership accountability
  • Escalation processes for reporting issues
  • Periodic internal verification checks

This governance structure is essential in supporting the reliability and consistency of climate-related disclosures under NSRF and IFRS S2.

6. Conduct a Pre-Assurance Gap Assessment

One of the most effective ways to prepare for a GHG audit is to conduct a structured pre-assurance review or gap assessment.

This helps organisations identify weaknesses before external verification begins, including:

  • Data gaps and inconsistencies
  • Weak internal controls
  • Missing documentation
  • Methodology issues
  • Scope boundary concerns
  • Assurance readiness risks

A proactive assessment significantly reduces the risk of delays, qualification findings, and reporting challenges during formal verification processes.

Common Challenges During GHG Verification

Many organisations underestimate the level of coordination required to support credible GHG reporting.

Some of the most common challenges during verification include:

  • Incomplete supporting documentation
  • Inconsistent reporting methodologies
  • Poor data ownership and accountability
  • Manual calculation errors
  • Fragmented reporting systems
  • Limited Scope 3 visibility

These challenges often become more significant as sustainability reporting requirements expand.

Conducting pre-assurance reviews and strengthening internal controls early can help organisations reduce verification risks and avoid delays during formal audits.

Why Early Preparation Matters

The demand for credible climate-related disclosures is increasing rapidly across Malaysia and global markets.

Robust GHG reporting not only supports compliance readiness but also helps organisations improve operational visibility, strengthen stakeholder trust, support sustainable financing, and prepare for long-term decarbonisation strategies.

Companies that invest early in governance, digital systems, and verification readiness are generally more capable of adapting to evolving sustainability reporting expectations.

Organisations looking to strengthen internal capabilities in carbon accounting and verification can also explore Building Expertise in Carbon Accounting and Verification for Organisations, which covers ISO 14064, GHG accounting methodologies, verification processes, and IFRS S2-related disclosures.

Strengthen Your GHG Audit Readiness with Bernard Business Consulting

At Bernard Business Consulting, we support organisations in strengthening GHG audit readiness aligned with NSRF, IFRS S1 and S2, and ISO 14064 requirements. By improving carbon data quality, governance, and documentation, organisations can better prepare for growing sustainability assurance expectations.

For organisations with readily available and well-managed data, the GHG verification process can typically be completed within approximately two months with our system and support. Early preparation helps strengthen disclosure credibility, improve stakeholder confidence, and accelerate sustainability reporting readiness.

Contact us to strengthen your GHG audit readiness and accelerate your path towards carbon verification and sustainability assurance.

Author
Ru Yi Teh
Ru Yi Teh

ESG and Sustainability Consultant
+603 - 8081 9069

Contact
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