During 2026, the Department of Forestry, Fisheries and the Environment (DFFE) held stakeholder engagements to present proposed changes to the National Greenhouse Gas Emission Reporting Regulations.
The proposals are intended to support a single national framework for reporting and disseminating greenhouse gas emissions information, while strengthening the analysis of emissions trends and changes in emissions intensity across the economy.
On 2 September 2026, the DFFE advised stakeholders that they may submit comments on the proposed changes before the draft regulations are published. The summary below highlights the key proposed changes by sector.
A new adjustment process is proposed for emission reports containing minor issues, such as the use of outdated emission factors. The DFFE would be able to adjust reported emissions using the latest approved methodologies. Data providers would then have 30 days to review the adjustment and either accept it or raise a dispute. If no response is received within that period, the submission will be finalised using the adjusted information.
Registration and Thresholds
• Clarification that the 10 MWth threshold applies across all fuel combustion activities collectively, rather than separately per activity. Where the combined capacity exceeds the threshold, all relevant combustion activities would need to be registered and reported.
• Entities voluntarily registering activities below the reporting threshold will become subject to all mandatory reporting requirements applicable to threshold-reporting facilities.
Methodologies
• Mandatory adoption of higher-tier methodologies for fuel combustion activities where Tier 2 emission factors are available.
• Once a higher-tier methodology has been adopted, reporting entities may not revert to a lower-tier methodology in later years.
• Applications for alternative emission factors submitted during a reporting year will only take effect from the following reporting period.
New Reporting Requirements
• Mandatory submission of supporting documents, including detailed monthly fuel consumption breakdowns.
• Introduction of Scope 2 emissions reporting as a new activity category, including reporting of purchased electricity, steam, heat, and cooling
• More disaggregated reporting of generator fuel use (for example, at provincial level).
• Reporting of production data alongside fuel combustion data to facilitate emission intensity and energy trend analysis.
• Introduction of a specific reporting category for pipeline transport emissions (1A3e(i)).
Methodological Requirements – All IPPU activities will be required to use Tier 3 methodologies, unless a sector-specific Tier 2 emission factor has been formally developed.
Supporting Information – Mandatory submission of supporting documentation, including, process flow diagrams, relevant laboratory analyses, calculation worksheets, and other information necessary to validate reported emissions.
Additional Reporting Categories – The proposals include reporting on the non-energy use of fuels, the storage and use of CO2, and primary rare earth production. A threshold of 50 tonnes of rare earth production per month is proposed.
Third-Party Registration and Verification
• Mandatory registration of third parties involved in sequestration reporting. Third parties will need to provide information such as harvested area, harvest quantities, proportion of the harvest purchased, and geospatial verification data.
• Where sequestration claims rely on third-party data, the third-party information must undergo independent verification.
Livestock Thresholds and Reporting
• Additional clarification of the poultry threshold under 3A2i, specifying that the threshold refers to a farm’s capacity to house 40 000 or more birds, not the actual bird population at a point in time.
• Introduction of feedlot reporting requirements, including the number of cattle and sheep in feedlots, and the number of days livestock remain in feedlots. With proposed reporting thresholds of 8 000 for cattle, and 1 000 for sheep.
Thresholds for Solid Waste
• Solid Waste Disposal: Reduced from 5 tonnes/day received or 25 000 tonnes total capacity to 2 tonnes/day received, or 15 000 tonnes total capacity.
• Waste Incineration: Reduced from 1 tonne/hour to 10 kg/hour of waste treated.
Wastewater Treatment Thresholds
• Domestic wastewater treatment: Reduced from 2 million litres/day to 1 million litres/day.
• Industrial wastewater treatment: Reduced from threshold of 1 000 m³/day to no threshold (all facilities with treatment plants will have to report)
Methane Recovery – Mandatory explicit reporting of methane recovered from waste management activities.
If adopted, the amendments would increase the level and detail of greenhouse gas reporting required by many companies. Lower thresholds and new activity categories could bring additional facilities and emissions sources into the reporting framework, while higher-tier methodologies and mandatory supporting documentation would strengthen the evidence expected with annual submissions.
The proposals may also have implications for carbon tax reporting if National Treasury adopts corresponding changes under the Carbon Tax Act. The proposed threshold changes are particularly important because they may affect whether an activity is reportable and, potentially, how the activity is treated for carbon tax purposes.
• Assess which proposed amendments may affect your current registration and reporting boundary.
• Review whether existing data, methodologies and supporting documentation would meet the proposed requirements.
• Consider the potential implications of lower thresholds and newly reportable activities.
• Prepare and submit initial comments to the DFFE by 8th September 2026 or wait to provide comments once the draft regulations are formally published for public comment.
If you require support in assessing the implications of the proposed amendments or preparing comments for submission to the DFFE, we would be pleased to discuss how we can assist. Please feel free to contact us to arrange a discussion.
Rumbidzai Mhunduru
rumbidzaim@catalystsolutions.global
+27 65 875 6217
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