Semiconductor and micro-electromechanical system (MEMS) technologies have been already proved as strong solutions for producing miniaturized optical spectrometers, light sources and photodetectors. However, the implementation of optical absorption spectroscopy for in-situ gas analysis requires further integration of a gas cell using the same technologies towards full integration of a complete gas analysis system-on-chip. Here, we propose design guidelines and experimental validation of a gas cell fabricated using MEMS technology. The architecture is based on a circular multi-pass gas cell in a miniaturized form. Simulation results based on the proposed modeling scheme helps in determining the optimum dimensions of the gas cell, given the constraints of micro-fabrication. The carbon dioxide spectral signature is successfully measured using the proposed integrated multi-pass gas cell coupled with a MEMS-based spectrometer.