Statute Details
- Title: Carbon Pricing (Measurement, Reporting and Verification) Regulations 2018
- Act/Instrument Code: CPA2018-RG1
- Type: Subsidiary legislation (regulations made under the Carbon Pricing Act 2018)
- Authorising Act: Carbon Pricing Act 2018 (Section 76)
- Current version: Current version as at 26 Mar 2026
- Revised edition: 2024 Revised Edition (18 December 2024)
- Commencement (as reflected in timeline): 1 January 2019 (SL 857/2018)
- Key Parts: Part 1 (Preliminary); Part 2 (Emissions Reports and Monitoring Plans); Part 3 (Verification of Emissions Reports); Part 4 (Accreditation and Independence); Part 5 (Enforcement)
- Key Provisions (by heading): Emissions report submission; monitoring plan submission and revision; verification planning and execution; verification reporting and approval; accreditation of external auditors; independence requirements; Agency surveillance
- Schedule: Complex sectors (and related classification)
What Is This Legislation About?
The Carbon Pricing (Measurement, Reporting and Verification) Regulations 2018 (“MRV Regulations”) set out the operational rules for how taxable facilities in Singapore must measure greenhouse gas (GHG) emissions, report those emissions to the relevant authority, and have the reports independently verified. In plain terms, the Regulations translate the Carbon Pricing framework into a practical compliance system: they tell regulated entities what to measure, how to document their approach, how to submit reports, and how to obtain assurance from accredited external auditors.
The Regulations sit alongside the Carbon Pricing Act 2018 and related subsidiary legislation. While the Act establishes the overall carbon pricing regime, the MRV Regulations focus on the “measurement, reporting and verification” mechanics. This includes requirements for monitoring plans (the methodology a facility will use), emissions reports (the quantified results), and the verification process (the independent checks that support the credibility of the reported emissions).
Because carbon pricing depends on accurate emissions accounting, the MRV Regulations are designed to reduce errors, ensure methodological consistency, and create auditability. They also regulate the external verification ecosystem by setting accreditation criteria, independence requirements, and procedural steps for verification engagements.
What Are the Key Provisions?
1) Emissions reports and monitoring plans (Part 2)
Part 2 establishes the reporting backbone. Under Division 1, the Regulations require the submission of emissions reports (regulation 3) and specify the content that must be included (regulation 4). Although the excerpt provided does not include the full text of these provisions, the structure indicates that emissions reporting is not merely a narrative obligation; it is a defined deliverable with prescribed elements, likely including quantified GHG emissions, supporting data, and compliance with the approved monitoring methodology.
Under Division 2, the Regulations require submission of monitoring plans (regulation 5) and set out what those plans must contain (regulation 6). A monitoring plan is essentially the facility’s “method statement” for emissions accounting—how activity data will be collected, how conversion factors will be applied, how calculations will be performed, and how quality assurance/quality control will be implemented. The Regulations also provide for revision of monitoring plans (regulation 7), which is crucial where operational changes occur or where the methodology needs updating. Finally, monitoring plans are assessed by an external auditor (regulation 8), reflecting that the monitoring approach itself must be capable of producing reliable emissions figures.
2) Records and measurement systems (Part 2, Division 3)
Division 3 includes practical compliance obligations. Regulation 9 requires records to be kept. This is a key feature for practitioners: record-keeping supports both internal governance and external assurance. Regulation 10 addresses measurement systems, equipment, tools and devices. This provision signals that the Regulations are not limited to documentation; they also require that the measurement infrastructure and tools used to generate emissions data meet compliance expectations. In practice, this often translates into calibration, maintenance, and controls over measurement processes.
3) Verification of emissions reports (Part 3)
Part 3 is the heart of the assurance regime. It sets out a structured verification workflow, including planning, execution, reporting, and Agency-facing steps. Division 1 contains preliminary matters, including definitions for this Part (regulation 11) and the application of the verification requirements (regulation 12). Division 2 addresses the pre-verification engagement assessment, including appointment of the verification team (regulation 13), appointment of an independent reviewer (regulation 14), and the conduct of pre-verification engagement assessment (regulation 15). Regulation 16 requires notice of verification, and regulation 17 addresses change in the accredited external auditor—important for continuity and accountability.
Division 3 requires planning of verification (regulation 18) and submission of documents relating to planning to the Agency (regulation 19). This is a procedural safeguard: the Agency can see the verification approach before work is finalised. Division 4 requires verification of the emissions report (regulation 20). It also addresses correction of misstatements and non-conformities (regulation 21) and an independent review of verification (regulation 22). Division 5 then requires a verification report (regulation 23), submission of that report (regulation 24), and approval of the emissions report (regulation 25). In other words, verification is not merely a private audit; it culminates in a formal verification report and an approval step that affects the status of the emissions report for carbon pricing purposes.
4) Accreditation, independence, and the verification ecosystem (Part 4)
Part 4 governs who may act as an accredited external auditor and the conditions under which they must operate. Regulation 28 provides for application for accreditation. Regulations 29 and 30 set criteria for non-complex sector and complex sector accreditation, respectively. The Regulations also specify requirements for lead verifier (regulation 31), independent reviewer (regulation 32), and complex sector expert (regulation 33). The schedule identifies “complex sectors”, which likely triggers heightened expertise and governance requirements.
Regulation 34 provides for award of accreditation. Regulation 35 addresses suspension, revocation of accreditation, etc., which is critical for enforcement and risk management. Regulation 36 requires notifications to the Agency relating to accreditation. Finally, regulation 37 sets independence between the registered person and the accredited external auditor. This independence requirement is central to the integrity of verification: it prevents conflicts of interest and ensures that assurance is objective.
5) Enforcement and Agency surveillance (Part 5)
Part 5 includes enforcement mechanisms. Regulation 38 provides for surveillance by the Agency. While the excerpt does not detail the surveillance powers, the heading indicates that the Agency can monitor compliance with MRV obligations. For practitioners, this means that compliance is not only “paper-based”; the Agency may conduct oversight activities that can affect enforcement outcomes.
How Is This Legislation Structured?
The Regulations are organised into five Parts and a Schedule:
- Part 1 (Preliminary): Contains citation and definitions (regulations 1 and 2). Definitions are crucial because they anchor technical terms used throughout the MRV framework.
- Part 2 (Emissions Reports and Monitoring Plans): Divided into three Divisions: emissions reports (Div. 1), monitoring plans (Div. 2), and miscellaneous operational requirements including records and measurement systems (Div. 3).
- Part 3 (Verification of Emissions Reports): Divided into six Divisions: preliminary (Div. 1), pre-verification engagement assessment (Div. 2), planning (Div. 3), verification execution (Div. 4), reporting (Div. 5), and miscellaneous record/information duties (Div. 6).
- Part 4 (Accreditation and Independence): Sets out the accreditation process, criteria for different sector complexity, roles within verification teams, and independence requirements.
- Part 5 (Enforcement): Provides for Agency surveillance.
- Schedule: Lists “complex sectors”, which affects accreditation criteria and the level of expertise required.
Who Does This Legislation Apply To?
The MRV Regulations apply to entities that operate “taxable facilities” under the Carbon Pricing Act 2018. In practical terms, this includes corporations responsible for emissions accounting and reporting obligations. The Regulations also apply to accredited external auditors and their verification teams, including lead verifiers, independent reviewers, and complex sector experts, because Part 3 and Part 4 impose procedural and professional requirements on them.
Additionally, the Regulations create obligations that interact with the Agency’s oversight role. For example, monitoring plans and verification planning documents are submitted to the Agency, and verification reports are submitted and linked to approval of emissions reports. Therefore, the compliance chain involves both the registered person (the facility operator) and the accredited external auditor, with the Agency as the supervisory authority.
Why Is This Legislation Important?
For lawyers advising regulated businesses, the MRV Regulations are important because they operationalise the carbon pricing regime. Carbon pricing outcomes depend on the emissions numbers that are measured and reported. The Regulations therefore create a compliance framework that can affect financial liabilities, audit outcomes, and regulatory risk.
From a risk perspective, the Regulations emphasise three themes: methodological discipline (through monitoring plans and revisions), assurance credibility (through verification planning, correction of misstatements, independent review, and verification reporting), and institutional integrity (through accreditation criteria and independence requirements). The record-keeping and measurement system provisions further support traceability—meaning that if an emissions figure is challenged, the facility should be able to demonstrate how it was derived.
Practically, the MRV Regulations also shape internal governance. Facilities must establish processes to collect activity data, apply conversion factors, maintain measurement systems, and manage documentation for both the monitoring plan and verification engagement. They must also coordinate with accredited external auditors to ensure that verification is properly planned, conducted, and reported, including any required corrections and independent reviews. Finally, Agency surveillance means that compliance failures may be detected even where internal processes appear adequate.
Related Legislation
- Carbon Pricing Act 2018 (authorising Act; MRV Regulations made under Section 76)
- Carbon Pricing (Registration and General Matters) Regulations 2018 (notably referenced for the definition of “EDMA system” in regulation 2)
- Energy Conservation (Registrable Corporations) Order 2013 (referenced for the definition of “fuel” in regulation 2)
Source Documents
This article provides an overview of the Carbon Pricing (Measurement, Reporting and Verification) Regulations 2018 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.