Understanding the Importance of GHG Pre-Verification Audits

Beginning in 2026, Senate Bill 253, also known as the Climate Corporate Data Accountability Act, will require large private and public companies doing business in California to report Scope 1 and Scope 2 GHG emissions from energy usage.

Scope 1, or direct, emissions are combustible sources that an organization owns or operates, such as fuel at its facility. Scope 2, or indirect, emissions are typically purchased electricity, as well as steam heating or cooling. Scope 3 reporting, Indirect emissions from a company’s value chain, will be required beginning in 2027.

Undergoing a pre-verification audit can ensure your organization is prepared for these upcoming regulation changes, allowing you to enter the verification process with confidence and success.

Understanding GHG Pre-Verification

GHG verification is the independent assessment of greenhouse gas (GHG) emissions data to ensure accuracy, completeness, and compliance with regulatory or voluntary reporting standards. Pre-verification is investigating GHG reports that may be subject to regulatory standards before an official verification audit takes place. This involves looking at data collection processes and management to uncover any issues before subjecting your organization to a full regulatory audit.

A third-party sustainability consultant can work with you to determine any GHG gaps in the pre-verification process. If you internally prepare a GHG inventory but it is not yet ready for full verification, pre-verification services may be an effective next step. This scope may include an audit of the GHG inventory and the identification of errors, omissions, and misstatements, as well as opportunities for improvement. Pre-verification services may also include optional assistance in addressing audit findings.

 A client may provide an asserted emissions number of a particular scope, and the consultant will follow a defined verification process using that preliminary data and site visits. The team may also conduct interviews with staff to ensure accuracy of the reported values, followed by data review and any necessary recalculations.

Pre-Verification Audit Approaches

A pre-verification audit may take one of two approaches: 

1. Findings-Only Approach: The consultant presents audit findings, and the organization independently addresses the issues. 
2. Collaborative Approach: The consultant provides additional support to help the organization resolve identified data gaps or compliance issues. 

However, due to third-party impartiality issues, the same consultant team would not be able to provide the actual auditing services after completing pre-verification services. If the team is consulting and advising the organization on how to reach regulatory compliance, that team cannot then assess the organization’s efforts moving forward in an official audit.

Audit findings are typically delivered in a format that allows the organization to make adjustments to meet a 95% materiality threshold. Since pre-verification is non-programmatic, the results can be used flexibly, including for regulatory preparation.

Key Elements of a Pre-verification Audit

1. Initial Review: Consultants start at the highest level of the organizational boundary, ensuring all facilities are operating correctly, before moving down through the lower layers of operational boundaries. 
2. Sampling and Analysis: The consultant team will look for any completeness issues or errors in emission reporting, sampling high-risk emission sources, and analyzing the primary data to ensure it matches what is being reported. In these instances, primary data may include fuel invoices, utility invoices, meter records, or fuel logs. 
3. Emission Calculation Review: Within this step, the team will utilize primary sources to ascertain the methods used for calculating emissions, whether by field type or energy region.
4. Summarize Findings: Typically presented as a technical memorandum or, preferably, a detailed findings log. The detailed findings log is more concise and often the preferred deliverable from a GHG pre-verification audit. It includes corrective action requests that highlight errors and corresponding opportunities for improvement, along with a summary of the pre-verification audit. 

Leverage Expert Support for GHG Pre-Verification 

GHG pre-verification audits are an essential tool for organizations preparing for the upcoming regulatory changes under California’s Senate Bill 253. By proactively assessing data accuracy and identifying potential gaps before formal verification, businesses can ensure compliance, avoid costly errors, and streamline reporting processes.

Partnering with a third-party sustainability consultant such as Cameron-Cole, an ADEC Innovation, provides valuable expertise in navigating these complexities, offering a strategic advantage in achieving accurate and reliable emissions disclosures. As the 2026 verification deadline approaches, now is the ideal time to engage in pre-verification audits and strengthen your organization’s sustainability reporting framework. 

For more than 20 years, Cameron-Cole has provided GHG reporting and verification services for clients ranging from small municipalities to the world's largest corporations. We were among the first organizations in the United States to provide GHG verification services and continue to be one of the most active verification bodies in the country. Contact us to learn more about our services and how we can help you stay ahead of mandatory reporting deadlines and changing guidance.

This blog provides general information and does not constitute the rendering of legal, economic, business, or other professional services or advice. Consult with your advisors regarding the applicability of this content to your specific circumstances.