It is Colombia's Climate Action Law, signed on December 22, 2021. It sets two targets, cutting emissions 51% against the reference scenario by 2030 and reaching carbon neutrality by 2050, and creates instruments to get there. One of them, in article 16, is the Mandatory Emissions Report.

The Reporte Obligatorio de Emisiones, the mandatory greenhouse gas emissions report. It requires public, private and mixed legal entities to report their direct and indirect emissions on a platform within Colombia's Environmental Information System. The law declares it enforceable from its enactment and once the Ministry of Environment regulates the article, and that regulation is still a draft in October 2026.

Who will have to report?

Under the draft resolution published in July 2026, companies whose direct emissions plus indirect emissions from purchased energy add up to 11,000 tonnes of CO2 equivalent a year or more. They come in by stages: large companies in 2027, medium in 2028 and small in 2029. Micro-enterprises are excluded.

When is the first report filed?

The draft sets annual filing within the first four months of the year, by April 30 at the latest, from 2027 and with the previous year's emissions. The first report, from large companies, would cover January 1 to December 31, 2026.

Does the report need verification?

Yes. The draft sets two levels: between 11,000 and under 25,000 tonnes, first-party verification by an independent verifier; from 25,000 upwards, third-party verification by a body accredited by ONAC.

What if I am below the threshold?

You still have to calculate. Anyone under 11,000 tonnes files a self-declaration on the platform with their quantified emissions, signed by the legal representative and the statutory auditor, within the same deadline.

Ley 2169 and the ROE: who reports emissions in Colombia

On July 24, 2026 the public consultation closed on the draft resolution regulating the Mandatory Emissions Report. It sets the threshold at 11,000 tonnes of CO2 equivalent a year and the first filing on April 30, 2027, with 2026 emissions. If the resolution is issued as drafted, the year that has to be measured is already in its last quarter.

This guide covers what Ley 2169 says, what the draft proposes and what is already in force in the meantime.

The law in four articles

Ley 2169 was signed on December 22, 2021. It is Colombia's climate action law, and almost everything else hangs from it.

Article 5 sets the targets: cut emissions 51% against the NDC reference scenario by 2030, with a cap of 169.44 million tonnes that year, and reach carbon neutrality by 2050.
Article 7 sets the goal of having the National Program of Tradable Emission Allowances fully implemented by 2030.
Article 16 creates the Mandatory Emissions Report, the ROE. Public, private and mixed legal entities must report their direct and indirect emissions and the information used to build their inventories, under criteria the Ministry of Environment and Sustainable Development defines considering emission levels and company size. The information will be public.
Article 34 requires emissions to be verified through first-party declarations or accredited third-party conformity declarations, as applicable.

The same article 16 says the ROE becomes enforceable from the law's enactment and once the Ministry regulates the article. Almost five years later, that regulation is a draft.

What the draft proposes

The Ministry published the draft resolution in July 2026 and took comments until July 24. It regulates the ROE and adopts two annexes: the Quantification and Reporting Protocol and the Technical Guide to the ROE Platform. Until the final version is issued, what follows may change.

Article 12 sets the threshold: 11,000 tonnes of CO2 equivalent a year, adding direct emissions and indirect emissions from purchased energy. Article 13 crosses it with company size under Decree 957 of 2019 and excludes micro-enterprises.

Entry is phased:

Stage	First report	Who	Period covered
1	2027	Large companies from 11,000 tCO2eq	January 1 to December 31, 2026
2	2028	Large and medium from 11,000 tCO2eq	2027
3	2029	Large, medium and small from 11,000 tCO2eq	2028

In the first two stages, companies report direct emissions and indirect emissions from purchased energy, that is, scopes 1 and 2. In the third, the text speaks of direct and indirect emissions without that qualifier, and a paragraph allows including other indirect emissions voluntarily before 2029. Those emissions do not count towards the threshold or the type of verification.

Public entities have their own table, with central government units in 2027 and public companies and the rest of the sector in 2028 and 2029. Municipalities in categories 3 to 6 are excluded.

One detail for corporate groups: companies required to report in the Beneficial Owners Registry that share a beneficial owner must add up their emissions. If the total exceeds the threshold, each company reports separately, and verification is done on the consolidated figure.

How it is calculated

The draft does not invent a method. It defines direct and indirect emissions using the GHG Protocol Corporate Standard or NTC ISO 14064-1:2020, and requires consolidation under the operational control approach. The gases are the six Kyoto gases plus nitrogen trifluoride where relevant, and the global warming potentials are those of the latest National GHG Inventory.

Article 20 allows three methods: emission factors, mass and energy balance, and direct measurement. If you use your own factors, you must hand over the documentation behind them.

For electricity, UPME publishes the factor for the National Interconnected System. Resolution 085 of February 23, 2026 sets it at 0.220 tonnes of CO2 equivalent per megawatt hour, with 2024 data. Each resolution states the data year it applies to, so use the one matching the period you report. For fuels, the factors come from UPME's FECOC tool.

The report carries at least a description of the organization, the organizational and operational boundaries, quantification by gas in tonnes of the gas and in CO2 equivalent, uncertainty and improvement opportunities. If your inventory already follows the GHG Protocol, the work is presentation. The GHG Protocol and ISO 14064 guide shows how the ISO categories map to scopes.

Verification

Article 23 sets two levels based on the sum of direct emissions and indirect emissions from energy:

Emissions in the period	Verification
11,000 to under 25,000 tCO2e	First party, by an independent verifier
25,000 tCO2e or more	Third party, by a body accredited by ONAC

The first-party verifier cannot have taken part in the calculation, must meet ISO/IEC 17029, ISO 14065 and ISO 14066, and cannot verify the same company for more than three consecutive years. A natural person proves competence with experience certificates; a legal entity, with the Single Registry of Bidders.

For third-party verification, the body must be accredited by ONAC with the ROE Protocol in its scope. Since that scope does not exist yet, a transitional paragraph accepts current accreditations under ISO 14064-1 or the GHG Protocol for two years. ONAC publishes the directory of accredited bodies; check that the scope covers organizational GHG inventories before hiring.

The dates

Article 21 sets one window: within the first four months of each year, by April 30 at the latest, from 2027, with the emissions of the immediately preceding year. The reporting period is always the calendar year.

The platform has six steps: registration, organization details, quantification, reporting, results view and filing certificate. Anyone below the threshold completes the first three and files a self-declaration signed by the legal representative and the statutory auditor. In other words, the calculation is mandatory for everyone in scope; what changes is whether you also report and verify.

Everything registered is public under Law 1712 of 2014 and is deemed filed under oath.

In the meantime, the RUA

The ROE is not the first environmental registry a Colombian company meets. Resolution 839 of 2023 reorganized the Single Environmental Registry and the Pollutant Release and Transfer Register. Many companies with an environmental license or permits already report to the RUA every year, and the draft clarifies that the ROE and the RUA belong to the same Environmental Information System and operate independently.

If you already report to the RUA, much of the fuel and energy data is what the ROE will ask for. It pays to keep it in one place.

What is built on top

The ROE is not an end in itself. Two instruments use it as input.

The first is the National Program of Tradable Emission Allowances. Decree 0969 of August 4, 2026 regulated it: a first testing phase from January 1, 2027 to December 31, 2029 and a second from 2030. During the first, the duty to report remains. Emissions reported to the ROE are the input for deciding who is covered and how many allowances are issued, and the auction reference price is the carbon tax rate.

The second is that tax. The 2026 rate is 29,070.49 pesos per tonne from February 1, capped at 3 UVT. Since the 2022 tax reform, anyone offsetting with certificates canceled in RENARE can stop paying up to 50% of the tax, a cap the government has proposed raising. In both cases, the starting point is a verified inventory.

For the financial sector there is one more piece: External Circular 015 of 2025 from the Financial Superintendence, which asks supervised entities to manage climate risk, with a plan within six months and implementation within 18.

Penalties

Article 36 of the draft refers to the regime of Law 1333 of 2009, as amended by Law 2387 of 2024. It is the environmental sanctioning procedure that already applies to licenses and permits, with fines and closures among its penalties.

What we would do in your place

Measure all of 2026, under the operational control approach and with the six gases. If you are a large company and think you exceed 11,000 tonnes, that is the period you will file in April 2027. If you think you fall short, the calculation still goes in the self-declaration.

Keep the invoice behind every figure. First-party verification checks that the activity data, the factor and the source match; third-party verification does the same with an accredited auditor.

Grumbic calculates emissions from your fuel and electricity invoices, classifies them by scope under the GHG Protocol and ISO 14064-1, applies UPME's factors and keeps every figure linked to the document it came from. That backing is what the verifier asks for.

See the platform or talk to us.

Sources

Information reviewed on October 17, 2026 in the text of the law, the draft resolution of the Ministry of Environment and Sustainable Development and documents from UPME, DIAN and the Financial Superintendence. This guide is informative and does not replace legal advice.