# What happens if we have no routine records when a verifier checks our greenhouse gas inventory?

Canonical: https://senseible.earth/answers/verifier-cannot-give-opinion-without-records

The Greenhouse Gas (GHG) Protocol Corporate Standard says management statements with no supporting documents cannot be verified, and without systems for routinely recording GHG data a verification is difficult and the verifier may be unable to issue an opinion. The verifier may recommend improvements instead.

## What the standard says

- Statements made by management for which there is no supporting documentation cannot be verified.
- Where a company has not implemented systems for routinely accounting and recording GHG emissions data, an external verification will be difficult and may result in the verifier being unable to issue an opinion.
- In that case the verifier may recommend how data collection should be improved so an opinion can be obtained in future years.
- Depending on the agreed scope of work, a verifier may also issue a verification report with recommendations for improvement.

## Who keeps the trail

The standard says companies are responsible for the existence, quality and retention of documentation, creating an audit trail of how the inventory was compiled. If you publish a base year, it says to keep all relevant historical records that support the base year data.

## What counts as supporting records

The standard's list for an external verifier includes invoices, delivery notes, weigh-bridge tickets and meter readings for energy, production data, raw material records for mass balance, emission factors with their justification, calibration records for meters and weigh-bridges, and the quality checks used, such as comparing with last year's data or recalculation by a second person.

## A year of preparation (my suggestion)

1. Start filing every fuel invoice and electricity bill by month from today.
2. Write down the emission factor and its source against each line.
3. Keep weighbridge slips and meter photos with the month they belong to.
4. Run a second-person check on the year-end totals.
5. Ask the verifier for a readiness review before the formal engagement.

## Example: what a gap does to the evidence

- A plant buys diesel in 12 months but has invoices for 9. Invoiced: 9 x 6,000 litres = 54,000 litres.
- The other 3 months are an estimate: 3 x 6,000 = 18,000 litres, or 18,000 / 72,000 = 25% of the year's diesel with no document behind it.
- 25% unsupported is a large share to leave to a verifier. Find the three invoices from the supplier's ledger before the visit.

Quantities are example numbers. The standard sets no percentage for what a verifier will accept.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records, so a year of bills sits in one place with its months. It is not a third-party verifier, and its checks are rule checks on your records, not assurance.

- [Internal review before external verification](https://senseible.earth/answers/internal-review-before-external-verification)
- [How to choose a GHG verifier](https://senseible.earth/answers/how-to-choose-a-ghg-verifier-msme)
- [What to agree in the scope of work](https://senseible.earth/answers/ghg-verification-scope-of-work-what-to-agree)
- [How long to keep carbon records](https://senseible.earth/answers/how-long-to-keep-carbon-accounting-records)
- [Trust and technical validation](https://senseible.earth/trust)

Sources: [GHG Protocol, A Corporate Accounting and Reporting Standard (Revised Edition), chapters 5, 6, 7, 9 and 10](https://ghgprotocol.org/sites/default/files/standards/ghg-protocol-revised.pdf)

Last reviewed 2026-11-06. Statements are from chapter 10 of the Corporate Standard. Verification schemes such as the Carbon Border Adjustment Mechanism (CBAM) have their own evidence rules. The year-of-preparation steps are my own suggestion, not the standard's.