Methane MRV: How Greentruth Stacks Upstream Verification and Downstream Reporting

For producers, operators, and downstream buyers searching foundational queries about methane MRV, gas MRV framework requirements, OGMP 2.0 Level 4 versus Level 5, or how to comply with the EU MRV equivalence requirement, this is the pillar page that orients you. Greentruth operates a two-layer MRV stack: an upstream layer where producer and operator primary data is ingested under the QET-NG methodology and verified by accredited third parties under ISO 14064-3 reasonable assurance, and a downstream layer where the same verified data is packaged into Scope 3 Category 3 EACs through the GasTrace product. Understanding the distinction — what each layer does, which frameworks each layer aligns to, and where the regulatory landings sit — is the foundation for designing a defensible methane reporting program.

Methane MRV, in one paragraph. MRV — Monitoring, Reporting, and Verification — is the discipline of generating, documenting, and independently assuring environmental data for natural gas and methane emissions. The Greentruth MRV stack has two layers: upstream MRV (producer and operator primary data ingested under the QET-NG methodology and verified to ISO 14064-3 reasonable assurance, aligned to NGSI Protocol v2.0, the OGCI Reporting Framework, and ONE Future v6.2023 for US markets; OGMP 2.0 and the EEMDL Protocol for EU compliance) and downstream reporting (the GasTrace product, which consumes the verified data and packages it as Scope 3 Category 3 EACs for buyer disclosure). The two layers serve different audiences and run as separate workflows.

For the foundational platform context

MRV stands for Monitoring, Reporting, and Verification — three sequential disciplines that together produce environmental data defensible enough to support regulatory disclosure, third-party assurance, and corporate climate claims. The three elements are not interchangeable; each plays a specific role.

• Monitoring is the data-generation step. For methane and natural gas, this means physical measurement at the asset: continuous emissions sensors at production sites, source-specific quantification of vents and flares, segment-level reporting across midstream infrastructure, calibrated meters for production volumes and energy content. The quality of monitoring determines the quality of everything downstream.
• Reporting is the structured submission of monitored data into a defined schema and framework. For US methane reporting, that's NGSI Protocol v2.0, the OGCI Reporting Framework, ONE Future v6.2023, and the EPA Subpart W program. For EU compliance, OGMP 2.0 and the EEMDL Protocol set the structure.
• Verification is independent third-party assurance that the monitored data is accurate and that the reporting framework has been applied correctly. For high-integrity environmental claims, verification operates under ISO 14064-3:2019 at reasonable-assurance level — the higher of the two assurance levels in the standard.

A program with strong monitoring but no verification is unaudited data; a program with verification but weak monitoring is verified weak data. The discipline done correctly is the integration of all three, and it's what separates a registry-grade environmental-attribute claim from a self-attestation that an auditor in 2027 might reject.

ISO 14064-3 standard

The architectural distinction is important enough to surface explicitly, because it's a question many readers arrive at the page already confused about: Is GasTrace the MRV layer?

The answer is no. The Greentruth MRV stack has two layers, and they serve different audiences:

Layer 1 — Upstream MRV. This is where producer and operator primary data enters the platform. Natural gas producers, RNG facilities, carbon-storage operators, and renewable electricity programs submit primary MRV data through the QET-NG methodology (or the equivalent QET-RNG, QET-CCS, QET-ELEC methodology). An accredited ISO 14065:2020 verifier reviews the data under ISO 14064-3 reasonable assurance, signs off, and the resulting QET is minted on-chain with the verified attributes attached. This is the upstream MRV layer.

Layer 2 — Downstream Scope 3 Category 3 reporting. This is where downstream buyers — corporate sustainability teams, utilities, data centers, industrial offtakers — consume the verified upstream data for their own disclosure. The product that operates at this layer is GasTrace — the Scope 3 Category 3 EAC product that packages QET-NG retirement records (and the underlying ISO 14064-3 verified producer data) into machine-readable disclosure-ready exports under GHG Protocol, SBTi, CSRD, IFRS S2, SB 253, and TCR.

The distinction matters because the two MRV layers solve different problems. The upstream side is about producers generating high-integrity primary data that survives third-party verification. The downstream side is about buyers consuming that data and integrating it into their corporate disclosure cycles. Customers building a methane reporting program need both layers — the upstream MRV is where data quality is established; the downstream layer is where the data flows into the buyer's audit-ready disclosure stack.

For the downstream Scope 3 Cat 3 product

The upstream MRV layer is the data-generation and data-verification engine that supplies everything downstream. For producers and operators, three properties define what makes upstream MRV registry-grade on Greentruth.

Primary-data preference. The four-tier data-quality hierarchy applies: site-specific primary data is preferred, process-specific primary is second, peer-reviewed secondary is third, and industry-average secondary is the lowest tier and used only where primary is unavailable. The hierarchy is published, captured on every minted QET, and machine-readable through the Machine-Ready API surface — so a downstream consumer can reason directly over the underlying data quality.

Source-specific measurement. For methane MRV specifically, the upstream layer ingests continuous monitoring data from production sites, source-attributed quantification of vents and flares, segment-level OGMP 2.0 reporting (where the operator participates), and operator entity-level CI declarations backed by qualifying data (EPA GHGRP Subpart W, OGMP 2.0 Levels 3–5, FERC Form 2, 10-K / Sustainability disclosures under NGSI v2.0 and ONE Future v6.2023).

ISO 14064-3 reasonable-assurance verification. No data flows downstream without independent third-party verification. An accredited ISO 14065:2020 verifier reviews the producer data, the methodology application, the uncertainty quantification, and the materiality threshold (typically ≤5% for individual batches, ≤2% for aggregated portfolios), and issues an unmodified verification opinion under ISO 14064-3 reasonable assurance.

The output is a minted QET with the verified attributes attached: producer-level carbon intensity in kgCO₂e/MMBtu (using IPCC AR5 GWP100 factors with CH₄ = 28, N₂O = 265), methodology version, R&D GREET 2025 reference dataset version (for QET-NG mints), data-quality tier, geography, pathway, and verifier of record. Every attribute is preserved immutably on the EarnDLT registry on Hedera Hashgraph.

How the data-quality hierarchy works · For QET-NG in detail · For QET-RNG in detail

For US natural gas markets, the upstream MRV layer aligns to three industry framework anchors that the major reporting regimes have converged on:

NGSI Protocol v2.0 (Natural Gas Sustainability Initiative). NGSI v2.0 provides the methodological backbone for producer-level methane intensity reporting in the US natural gas market. It establishes the calculation conventions, the system boundaries, and the data-quality expectations that QET-NG mints align to. For producers operating in the US market without an immediate EU export pathway, NGSI v2.0 is the primary MRV anchor.

OGCI Reporting Framework (Oil and Gas Climate Initiative). The OGCI Reporting Framework supplements NGSI v2.0 with cross-company methane and CO₂ reporting conventions that align large producer programs. OGCI members and producers reporting under analogous protocols benefit from the cross-company comparability the framework enables.

ONE Future v6.2023 (Our Nation's Energy Future Coalition). ONE Future is the cross-segment methane intensity reduction coalition whose v6.2023 reporting requirements apply to participants reporting facility-level and entity-level data. ONE Future participation is a meaningful signal of operator-side methane discipline, and the protocol's reporting conventions integrate with the upstream MRV layer.

For producers and operators participating in any combination of these three frameworks, the QET-NG methodology operates as the integration surface — primary data submitted under NGSI v2.0 / OGCI / ONE Future v6.2023 flows through the methodology and produces an ISO 14064-3 verified mint that downstream buyers can consume directly.

For OGMP 2.0 specifically

For producers and operators with EU export exposure — LNG cargoes, pipeline imports, or downstream EU customer disclosure — the EU compliance extension layers on top of the US framework anchors. Two frameworks dominate the EU compliance extension.

OGMP 2.0 (Oil and Gas Methane Partnership 2.0). Administered by UNEP's International Methane Emissions Observatory (IMEO), OGMP 2.0 is the methane-specific reporting and reduction framework that the EU Methane Regulation's verification regime relies on as the equivalent-practice anchor for upstream and midstream methane data. OGMP 2.0 defines a five-level reporting hierarchy (Levels 1–5) that escalates from generic industry-average emission factors at Level 1 to source-level direct measurement at Level 5. For EU Methane Regulation Article 28 chain-of-custody documentation, Levels 4 and 5 are the operationally meaningful tiers — Level 4 represents source-specific direct measurement at the major-source level, and Level 5 represents site-level reconciliation between measured and reported emissions. Producers operating below Level 4 face progressively higher scrutiny under Article 28 review.

EEMDL Protocol (Energy Emissions Modeling and Data Lab — UT Austin). The EEMDL Protocol provides the methodological foundation that aligns producer-level methane data with the integrity expectations of EU regulators and the major downstream buyers. EEMDL operates as an equivalence anchor — producers running an EEMDL-aligned MRV program produce data that satisfies the EU Methane Regulation's reasonable-assurance verification standard under Article 8 and the chain-of-custody documentation expectation under Article 28.

The Greentruth platform's EU compliance extension explicitly aligns the upstream MRV layer to both anchors. A producer's data, submitted through the QET-NG methodology with OGMP 2.0 Level 4 or Level 5 reporting depth and EEMDL Protocol alignment, produces an ISO 14064-3 reasonable-assurance verified mint that supports the Physical Flow Certificate workflow downstream — which is what unlocks the EU Methane Regulation Article 28 chain-of-custody assertion.

UNEP IMEO / OGMP 2.0

For the EU MR compliance pathway

For EU MRV equivalence specifically

The verification standard that anchors the entire stack is ISO 14064-3:2019, applied at reasonable-assurance level. This matters specifically because the standard defines two assurance levels — limited and reasonable — and the higher of the two is what the major regulatory frameworks require.

Reasonable assurance is the higher level. It involves the verifier obtaining sufficient evidence to provide a positive opinion that the producer's data is, in all material respects, free from material misstatement. The verifier's procedures include substantive testing, recalculation, evidence gathering, site visits (for initial verifications), risk-based verification planning, and a written opinion meeting documented materiality thresholds.

Limited assurance is the lower level. It involves a less rigorous evidence-gathering process and produces a negative-form opinion (“nothing has come to our attention that suggests…”). Limited assurance is not sufficient for EU Methane Regulation Article 28 submissions, for SBTi physical trace-and-claim attribution, or for the high-integrity environmental claims that the major reporting frameworks now expect.

Every QET minted on Greentruth requires an unmodified reasonable-assurance opinion from an ISO 14065:2020 accredited verifier. The verifier must be accredited by an acceptable accreditation body (ANAB, UKAS, DAkkS, INMETRO, or another International Accreditation Forum signatory), with sector-specific scope appropriate to the certificate class. Verifier independence is enforced under the Governance Framework's separation-of-functions rules: no consulting services to the same client within 2–3 years, lead-verifier rotation every 3 years, fixed-fee compensation that is not contingent on outcomes.

For EU Methane Regulation submissions, additional ISO/IEC 17029:2019 accreditation and EU National Accreditation Body scope coverage apply.

How ISO 14064-3 underpins the platform

The downstream side of the stack — where corporate buyers consume the verified upstream data for their own disclosure — runs through GasTrace. The architectural distinction is worth holding clearly because confusion between the upstream layer and the downstream product is common.

GasTrace is not the upstream verification layer. It is the downstream Scope 3 Category 3 EAC product that consumes the outputs of the upstream layer and packages them for buyer disclosure. GasTrace operates on top of QET-NG retirement records — the upstream layer produces the verified mint, the buyer acquires and retires the QET against a reporting claim, and GasTrace produces the machine-readable Scope 3 Cat 3 disclosure-ready export.

What GasTrace adds to the upstream MRV outputs:

• Framework-aligned exports. GHG Protocol Scope 3 Category 3, SBTi, CSRD ESRS E1, IFRS S2, SB 253, and TCR formats produced as machine-readable payloads consumable by the buyer's ESG software (Watershed, Persefoni, Sweep, Workiva, or in-house GHG accounting systems).
• Free at the GREET default tier. GasTrace is offered free at the R&D GREET 2025 default-CI tier — the entry-level disclosure tier that uses the published industry-average factors. Producers operating with higher-tier primary data carry their MRV-tier upgrade into the GasTrace export, but the base disclosure tier is no-cost for buyers wanting to participate in the disclosure cycle.
• Audit-ready chain of custody. Every GasTrace export preserves the full chain back through the QET retirement, the QET mint, and the verifier's ISO 14064-3 opinion — so an auditor or regulator can re-trace the disclosure to the producer's primary MRV data.

The two-layer architecture is what makes the system audit-defensible. The upstream side is the data-quality engine; GasTrace is the disclosure-delivery engine. A buyer adopting Greentruth for Scope 3 Cat 3 reporting interacts primarily with GasTrace, but the integrity of every GasTrace export ultimately traces back to the upstream layer's primary-data and verification discipline.

For the GasTrace product in full

The Greentruth approach is structured for utility across multiple regulatory landings:

EU Methane Regulation (Article 28 chain-of-custody; Article 8 reasonable assurance). Article 28 imposes import-side chain-of-custody obligations that require source-attribution evidence linked to producer-level methane data; Article 8 establishes reasonable-assurance verification as the operative standard. The Greentruth upstream layer — OGMP 2.0 Levels 4/5 + EEMDL Protocol + ISO 14064-3 reasonable assurance — produces the data that Article 28 chain-of-custody documentation needs, and the Physical Flow Certificate workflow operationalizes the Article 28 assertion.

California SB 253 assurance. SB 253 (Climate Corporate Data Accountability Act) imposes Scope 1, 2, and 3 disclosure obligations on companies above the $1B revenue threshold, with phased assurance requirements escalating from limited to reasonable. The Greentruth stack supports SB 253 disclosure with reasonable-assurance-grade upstream verification flowing through to downstream Scope 3 Cat 3 reporting via GasTrace.

California LCFS verification. LCFS pathway verification operates under CARB-approved procedures and requires accredited third-party verifiers operating under ISO 14064-3. Producers minting QET-NG or QET-RNG aligned to LCFS pathway requirements can carry the upstream verification through to the LCFS-eligible inventory available on the Marketplace.

OGMP 2.0 (within the EU compliance extension). OGMP 2.0 itself is both a reporting framework and a regulatory anchor under the EU Methane Regulation's equivalent-practice provisions.

The practical implication for producers and operators: the Greentruth upstream layer is designed so a single primary-data ingestion and verification cycle produces outputs valid across multiple regulatory landings — rather than separate parallel programs for each regime.

How to comply under SB 253

How to comply under LCFS