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Details
- United Arab Emirates (UAE)
All public and private entities in the UAE (including free-zone companies) whose operations release greenhouse gases are potentially subject to the Climate Change Law. The Ministry of Climate Change and Environment (MoCCAE) and the relevant local authority will determine which sources are subject to measurement and reporting, and under what thresholds or criteria.
Deep dive
Overview of the UAE Climate Change Law
Federal Decree-Law No. (11) of 2024 On the Reduction of Climate Change Effects (the “UAE Climate Change Law”) was issued on 28 August 2024, published in the Official Gazette on 30 August 2024, and enters into force on 30 May 2025 (nine months after publication). It was adopted by the UAE President after review of the Constitution and core federal framework laws, including Federal Law No. 1 of 1972 on ministerial powers and the Federal Penal Code, giving it the status of a binding federal statute.
The law designates the Ministry of Climate Change and Environment (MoCCAE) as the central authority, working with “competent authorities” in each emirate (including free-zone regulators) to manage greenhouse-gas (GHG) emissions, set sectoral reduction targets, and oversee measurement, reporting and verification (MRV). It into a national climate policy framework that includes National Climate Change Plan 2017–2050, the UAE Green Agenda 2015–2030 and the UAE Net Zero 2050 Strategy, which generally aim at managing GHGs while supporting economic diversification.
By turning these strategic initiatives and Paris Agreement commitments into an enforceable law with penalties, the UAE has created the first comprehensive, binding climate framework in the Middle East and North Africa, explicitly aligned with its Net Zero by 2050 pledge and Nationally Determined Contributions (NDCs).
Reporting Requirements
At the core of the UAE Climate Change Law are mandatory obligations for designated “sources” (public and private entities) to measure and report their greenhouse gas emissions. Under Article 6, sources determined by MoCCAE and the relevant local authority must:
Measure emissions from their activities on a regular basis using methodologies and standards approved by MoCCAE or the competent authority.
Prepare and maintain an emissions inventory covering their greenhouse gas emissions over defined reporting periods.
Submit periodic emissions reports to MoCCAE and/or the local authority in the prescribed format and through the national electronic MRV system linked to the National Register for Carbon Credits.
Include in those reports information on actual emissions levels, mitigation actions already in place, and planned future reductions aligned with UAE climate targets.
Maintain records and underlying data that support their reported emissions and reduction measures, so that they can be inspected and verified by authorised officials.
These obligations are complemented by Cabinet Resolution No. 67 of 2024, which requires “entities of huge carbon emissions” to operate robust MRV systems and file annual GHG inventory reports as a condition of participation in the National Register for Carbon Credits.
Scope of Application
Under Federal Decree‑Law No. (11) of 2024 on the Reduction of Climate Change Effects, the scope of application includes:
“Sources”, defined in Article 1 as any public or private legal persons, as well as individual enterprises, whose operations or activities cause release of greenhouse gases (GHGs) into the atmosphere.
Both public and private sector entities, meaning government bodies, private companies, and individual businesses are subject to the law.
Businesses and organisations operating in all geographic zones of the UAE, including those within free-zones and free-zone economic jurisdictions — the law explicitly includes free zones in its applicability.
Entities across all sectors and sizes — the law does not distinguish by sector or size in its broad applicability language: in principle, all sources of emissions, regardless of whether they are large industrial facilities, SMEs, service providers or other enterprises, are within scope.
In short: the law applies broadly to virtually all entities in the UAE whose activities release GHGs, covering public- and private-sector organisations, businesses in free zones, and across all sectors and scales.
Penalties and Enforcement for Reporting Non-Compliance
Violations of the core reporting obligations are explicitly penalised. Article 15 provides that any source which breaches Article 6(1)—for example by failing to measure emissions, to prepare an emissions inventory, or to submit required periodic reports—faces a fine between AED 50,000 and AED 2,000,000, without prejudice to any more severe penalties under other laws. Article 16 doubles these penalties if the same violation is repeated within two years of a final conviction, creating a strong incentive for sustained compliance rather than one-off fixes.
Implementation Outlook
Practical Challenges
The main challenges with UAE's climate change law are practical rather than legal: defining which “sources” must report in each sector, aligning federal and emirate-level rules (including free zones), and building MRV capacity, especially among SMEs that have never quantified their emissions. Businesses also need clarity on how the law will interact with international regimes such as the EU’s Carbon Border Adjustment Mechanism and voluntary carbon markets, which the NRCC seeks to support.
Current Status
The law came into force on 30 May 2025, making the UAE the first MENA country with a binding, cross-economy climate statute. MoCCAE is now rolling out implementing measures: establishing the national electronic MRV system; coordinating sectoral emission-reduction pathways under Article 5; and operationalising the National Carbon Credit Registry under Cabinet Resolution 67 of 2024, which took effect on 28 December 2024 with a first compliance deadline of 28 June 2025 for large emitters. Companies have until 30 May 2026 to fully align their measurement, reporting and reduction practices with the new regime.
Resources
Official text – Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects.
Cabinet Resolution No. (67) of 2024 Concerning the National Register for Carbon Credits.
UAE National Climate Change Plan 2017–2050 (official strategy) – explains the broader policy framework that the law is designed to implement.
MoCCAE / UAE government climate action page – background on the institutional architecture (MoCCAE, UAE Council for Climate Change and Environment).
Understanding the UAE’s new National Register of Carbon Credits, Noor Al Baya, Kim Rosenberg
KPMG's briefing on the Climate Change Law - offers professional analysis and guidance for practitioners.
