CII- EMC ‘Corporate Air Emissions Reporting’ (CAER) Guide (2024): Enhancing Sustainability and Compliance

Monitoring air emissions is a critical step for companies striving to integrate sustainability into their operations. Accurate reporting of air emissions not only supports the development of effective reduction strategies but also helps businesses align clean air as part of their sustainability goals. Transparent emission reporting enhances reputational capital, ensures regulatory compliance, and offers sustainability-linked benefits.

Global Frameworks for Emission Reporting

Two significant global frameworks guide corporate air emissions reporting: the Global Reporting Initiative (GRI) and the Sustainability Accounting Standards Board (SASB).

The GRI standards are extensively used worldwide by organizations to disclose their economic, environmental, and social impacts. A key element of the GRI framework is the GRI 305-7 standard, which focuses on reporting nitrogen oxides (NOx), sulfur oxides (SO2), and other significant air emissions. Companies are required to disclose data in absolute terms, detailing sources, calculation methodologies, and the assumptions used. This data must be categorized by business unit, geography, and type of activity to provide a comprehensive picture of air emissions.

On the other hand, the SASB framework offers industry-specific sustainability standards designed to identify and disclose material sustainability-related risks and opportunities. For sectors like utilities and power generation, SASB mandates reporting air pollutants such as NOx, SO₂, particulate matter (PM₁₀), lead (Pb), and mercury (Hg). These emissions are reported as pollution loading in mass units, with methodologies such as Continuous Emissions Monitoring Systems (CEMS) or engineering calculations specified to ensure data accuracy and comparability.

Emission Reporting in India: The BRSR Framework

In India, the Securities and Exchange Board of India (SEBI) has introduced the Business Responsibility and Sustainability Reporting (BRSR) framework. This mandates the top 1,000 listed companies to report their emissions data, covering particulate matter (PM), SO2, NOx, and additional pollutants like volatile organic compounds (VOCs), persistent organic pollutants (POPs), and hazardous air pollutants (HAPs).

Although the BRSR framework enhances environmental disclosures, it lacks specificity in reporting of air emissions. For instance, it does not prescribe the units for reporting emissions or provide detailed guidance on methodologies. This absence of standardization creates challenges in ensuring consistency and comparability among disclosures.

Challenges in Corporate Emission Reporting

Despite the availability of global and local frameworks, companies face several hurdles in emission reporting. One key issue is the inconsistency in reporting practices. While global standards favor reporting emissions in mass units like tonne, Indian companies typically use concentration units such as parts per million (ppm) or micrograms per cubic meter (μg/m³), which align with the requirements of the concerned State Pollution Control Boards. This divergence complicates the consolidation of data at the level of economy.

Another significant challenge is the lack of clarity in pollutant categorization. Overlapping definitions of pollutants such as VOCs, HAPs, and POPs make it difficult for companies to classify and prioritise these air emissions accurately. Moreover, companies must adhere to state-specific Pollution Control Board standards, which can vary significantly across geographies. This lack of uniformity creates barriers to standardizing emissions reporting practices.

Operational barriers also play a role. As described earlier, companies often struggle to differentiate between “air emissions” (pollutant loading) and “ambient air monitoring,” (pollutant concentrations) leading to inconsistencies in disclosures. High costs associated with monitoring certain pollutants, like HAPs and POPs, further deter comprehensive reporting.

How the CAER Guide Addresses Challenges

The Corporate Air Emissions Reporting Guide (CAER Guide) is designed to overcome these challenges by providing comprehensive tools and methodologies for prioritising and reporting air emissions.

The guide offers standardized processes with real-world examples for emissions reporting, helping companies align with frameworks like BRSR and global ESG disclosure standards. It clarifies pollutant categories and provides tools for converting emissions data into relevant units, ensuring consistency and comparability. Additionally, the guide establishes clear distinctions between emission loading and ambient air concentrations, reducing ambiguities in disclosures.

The CAER Guide also aims to enhance the capacity of reporting teams through education and awareness-building initiatives. By adopting the good practices outlined in the guide, companies can improve their reporting accuracy and transparency, ultimately contributing to a cleaner environment.

Empowering Indian Businesses for a Sustainable Future

The CAER Guide serves as a vital resource for businesses of all sizes and sectors. It empowers companies to align with regulatory requirements, adopt global best practices, and enhance their sustainability performance. By improving the quality of air emissions reporting, Indian companies can strengthen their reputational capital and position themselves as leaders in environmental stewardship.

Through proactive management and transparent reporting of air emissions, Indian businesses can play a pivotal role in achieving clean air goals and fostering a sustainable future for generations to come.

🔗 Download the full guide here-

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To know more about CII ‘Cleaner Air Better Life’ Initiative, go to-

 https://sustainabledevelopment.in/alliances/cleaner-air-better-life/