Getting the Most Out of the EITI's New Provision on Greenhouse Gas Data
When the 2023 EITI Standard introduced Requirement 3.4 on greenhouse gas emissions in response to civil society demands, it marked the first time the global extractive industries transparency standard addressed this important climate data. But the provision is only "encouraged," at the lowest tier of the EITI's hierarchy of obligations—with no consequences for non-compliance.
Yet the response has been strong. As of June 2026, 25 implementing countries are already reporting on GHG emissions, and civil society in at least five more is actively pushing for disclosure. That is more than half of all implementing countries engaging with a provision they have no obligation to follow.
EITI implementing countries doing some form of GHG emissions reporting | EITI countries that are not reporting on GHG emissions but where civil society is working to advance emissions disclosures |
25 Angola, Argentina, Burkina Faso, Cameroon, Central African Republic, Chad, Côte d'Ivoire, Democratic Republic of the Congo, Ecuador, Ghana, Guyana, Kazakhstan, Mauritania, Madagascar, Mongolia, Nigeria, Norway, Peru, Republic of Congo, Senegal, Timor-Leste, Trinidad and Tobago, Uganda, Ukraine and United Kingdom | 5 Colombia, Guinea, Indonesia, Philippines, and Zambia |
Source: NRGI review of latest EITI reports, June 2026
The question now is not whether countries will engage with the provision, but whether they will use it to get the data they actually need to inform public debate about emissions from their extractive industries.
The data producing countries actually need
Requirement 3.4 has two parts. The first encourages companies to disclose GHG emissions in alignment with leading disclosure standards—something many large extractive companies already do, to varying degrees, through the CDP, corporate sustainability reports, or upcoming mandatory frameworks like the EU's Corporate Sustainability Reporting Directive and the ISSB's IFRS S2.
The second part encourages multi-stakeholder groups (MSGs) to request disaggregated disclosures. This is where the real opportunity lies—not because the EITI is going beyond what other frameworks require, but because it gives producing countries access to emissions data at a level of detail that actually serves their needs.
Most existing emissions disclosures are aggregated at the company level—global totals that may help investors compare companies' overall climate footprints and assess portfolio risk. But a company-wide emissions figure tells a government official in Senegal or a community leader in Mozambique nothing about the emissions profile of the company’s specific operations in their country. It tells them nothing about which projects are the highest emitters and therefore most exposed to carbon pricing, import restrictions like the EU's Methane Regulation and Carbon Border Adjustment Mechanism (CBAM), or shifting investor expectations. For workers, suppliers and communities whose livelihoods depend on these projects, this matters: high-emitting projects carry greater climate-related financial risk and are linked to greater environmental impacts. The people who depend on them deserve to understand that risk. Aggregated data hides it.
Even national-level data fall short for stakeholders in producing countries. What they need is project-level data. Only this level of detail lets them understand the emissions footprint of individual operations, assess economic risks, hold companies to account for reduction commitments, and inform national climate plans.
Project-level disclosure is already becoming the norm
Asking for project-level emissions data is not a radical proposition. In mining, the Global Reporting Initiative's GRI 14 Mining Sector Standard already recommends it. The most recent drafts of the revised Initiative for Responsible Mining Assurance (IRMA) standard and the Consolidated Mining Standard Initiative both require site-level disclosure. South32, Anglo American, BHP and Newmont disclose project-level emissions data through their sustainability reporting, and they are far from alone. Project-level disclosure is becoming standard practice across the mining sector.
Oil and gas has historically been more resistant to granular disclosure, but that is changing. The widely used Oil and Gas Methane Partnership 2.0 (OGMP 2.0) framework requires companies to produce site-level data to achieve its top-level reporting tier, and over 65 companies have now met that standard, including majors like Eni, Equinor, Repsol, Shell, and TotalEnergies. Given that these companies are already producing site-level, measurement-based emissions data, sharing it through the EITI MSG should be straightforward.
What countries and civil society are doing
Ambition varies across EITI implementing countries. In Côte d'Ivoire, Burkina Faso and Ghana, at least some mining companies are already providing project-level emissions data through EITI reporting. Norway publishes project-level oil and gas emissions data on the Norwegian Petroleum website, run by the Ministry of Energy and the Norwegian Offshore Directorate.
Much of this progress is being driven by civil society. In Nigeria, NRGI worked with the Nigeria EITI (NEITI) to develop a standardized GHG reporting template that is now integrated into the national EITI audit process, bringing company emissions data into a consolidated public dataset for the first time. NRGI has supported the development of tools to make this data more accessible and used it to help journalists, civil society organizations, and parliamentarians scrutinize corporate emissions performance. In Senegal—a new hydrocarbon producer—NRGI also produced some of the first independent estimates of methane emissions from the country’s oil and gas operations and is now working with EITI and government stakeholders to build a methane emissions governance framework, including a dedicated monitoring, reporting, and verification system for the sector.
Elsewhere, with support from the World Bank's Extractives Global Programmatic Support (EGPS) trust fund, Transparency International and NRGI ran a program supporting local civil society groups to use the 2023 EITI Standard to strengthen accountability. Two of the ten projects selected focused specifically on Requirement 3.4. In Indonesia, Publish What You Pay Indonesia produced a scoping study on GHG reporting gaps in the coal sector that led the Ministry of Energy to commit to using the findings for policy development. In Kazakhstan, Public Association Echo developed a standardized GHG reporting form and policy brief that resulted in the Terms of Reference for the National EITI Report being expanded to include disclosure of GHG reduction measures and emission quotas. Both projects independently identified project-level disaggregation as the critical missing piece for meaningful local oversight.
Why EITI? Turning data into dialogue
Data published through EITI is truly public. Many existing disclosure platforms for GHG emissions, including the CDP, the OGMP and UNEP’s Methane Alert and Response System (MARS), are oriented more toward investors, governments or company decision-makers than to the general public. Some put data behind paywalls. By contrast, data published through EITI is open to everyone.
But the distinctive value of bringing emissions data into EITI processes is not just the data itself—it is the multi-stakeholder structure that surrounds it. Emissions data disclosed through EITI enters a process where representatives of government, industry, and civil society are already convened to discuss extractive sector governance. Environmental groups can scrutinize methane emissions. Workers and suppliers can ask whether governments and companies are doing enough to ensure that projects they depend on remain competitive in light of international GHG regulations. Citizens can ask whether state-owned companies—which a recent IEA-led assessment found tend to fall short on reporting against their emissions pledges—are putting public finances at risk. Governments can assess whether extractive sector oversight aligns with national climate commitments. This process—different stakeholders examining the same data from different angles—is what turns transparency into accountability and supports more informed decision-making.
What MSGs should do now
The EITI International Secretariat published a guidance note on Requirement 3.4 in October 2025, setting out a six-step process for implementation. It is a practical resource. Importantly, the guidance shows why project-level data is important, and why MSGs should request it. This data serves citizens and governments. Many companies already report it. The momentum behind Requirement 3.4 shows that EITI stakeholders understand the value of emissions transparency. The task now is to ensure that the data countries collect is detailed enough to make a difference.
Authors
Robert Pitman
Portfolio Coordination Lead