The UAE Federal Climate Law 2026: Mandatory Emissions Reporting, the Carbon Credit Registry, and Penalties

Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects requires all companies in the UAE, including those registered in free zones, to measure, report, and reduce Scope 1 and Scope 2 greenhouse gas emissions.

The law was issued 28 August 2024 and entered into force 30 May 2025; the statutory full-compliance deadline for all entities is 30 May 2026.

⚠ As of July 2026, the full-compliance deadline (30 May 2026) has formally already passed, but representatives of the Ministry of Climate Change and Environment (MOCCAE) have publicly indicated the deadline is likely to be extended pending technical guidance that has not yet been issued; no revised date has been confirmed. Businesses should prepare for the original deadline and not treat an extension as a given.

The law’s primary text confirms its provisions apply to emission sources within the State, including free zones — no territorial exemption is provided.

1. The Legal Basis: Two Linked Instruments

The UAE’s Federal Climate Law consists of two linked but formally separate regulatory instruments.

Federal Decree-Law No. (11) of 2024 sets out the general obligations to measure, report, and reduce emissions; Cabinet Resolution No. (67) of 2024 Concerning the National Register for Carbon Credits is a separate instrument governing the carbon credit registry itself and the requirements for large-emission entities.

2. Who the Law Applies To

The law applies to all public and private entities in the UAE whose activities generate greenhouse gas emissions, with no threshold based on turnover, headcount, or sector exemption.

⚠ Per the law’s primary text: “The provisions of the present Decree-Law shall apply to sources in the State, including free zones” — free zone registration does not exempt a company from the law’s obligations.

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3. The Full Timeline

Date	Event
28 August 2024	Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects issued
30 May 2025	The law entered into force
28 June 2025	Deadline for “Huge Carbon Emission Entities” (HCEEs) to register with the National Register for Carbon Credits (NRCC)
October 2025 (GITEX Global)	The national MRV (Measurement, Reporting and Verification) transparency system and the Integrated Emissions Quantification Tool (IEQT) went live
30 May 2026	The statutory full-compliance deadline for all entities — already reached at the time this article was prepared
April–May 2026 (as of publication)	MOCCAE representatives indicated the deadline is likely to be extended, but no revised date has been confirmed

4. Huge Carbon Emission Entities: A Separate, Stricter Category

Category	Threshold/requirement
Huge Carbon Emission Entity (HCEE)	0.5 million metric tonnes of CO2 equivalent or more per year (Scope 1 and Scope 2 combined)
Mandatory HCEE registration with the NRCC	Registration plus independent verification under ISO 14064 and ISO 14065 standards
Standard entity (non-HCEE)	Measurement and reporting of Scope 1 and Scope 2; Scope 3 is not mandatory for 2026 and is anticipated — not confirmed by the law — from 2027
Emissions data retention period	At least 5 years, accessible to MOCCAE on request

Cabinet Resolution No. 67 of 2024 defines a Huge Carbon Emission Entity (HCEE) as a source emitting 0.5 million metric tonnes of CO2 equivalent or more per year, combined across Scope 1 and Scope 2.

⚠ The deadline for HCEEs to register with the National Register for Carbon Credits was 28 June 2025 — significantly earlier than the general full-compliance deadline for all other entities (30 May 2026).

5. What Must Actually Be Measured: Scope 1 and Scope 2

The law uses the international Greenhouse Gas Protocol classification: Scope 1 covers direct emissions from a company’s own operations (fuel in company vehicles, generators, refrigerant leaks); Scope 2 covers indirect emissions from purchased electricity.

ℹ Scope 3 reporting (value-chain emissions — from suppliers, business travel, waste) is not mandatory for 2026; it is expected to become mandatory from 2027, though this is not confirmed by the law’s own text and should be treated as a likely, not guaranteed, scenario.

6. Mandatory Emission Reduction Measures

The law requires every entity not only to measure and report, but also to actively reduce emissions through one or more recognised measures.

Recognised measures include improving energy efficiency, using clean energy, protecting and enhancing natural carbon sinks, carbon capture, use and storage (CCUS), switching to alternatives to saturated fluorocarbons, carbon offsetting, and integrated waste management.

7. Penalties for Non-Compliance

Violation	Sanction
First offence (Art. 15)	Fine of AED 50,000 to AED 2,000,000
Repeat offence within 2 years (Art. 16)	Doubling of the fine

⚠ The precise article citation for the law’s penalties differs across secondary sources: the Library of Congress, citing the primary text, refers to Article 15 (the fine range) and Article 16 (doubling on repeat violations), while some other sources refer generally to “Articles 17–20” without breaking down which rule applies where — the Article 15–16 citation, backed by a direct reference to the primary text, should be treated as the more reliable one.

A repeat verification pass found that doubling the maximum fine on a repeat offence yields AED 4,000,000. Beyond financial penalties, the law also provides for administrative measures, confirmed by several independent secondary sources: restrictions on operations, licence suspension, exclusion from government procurement, and orders to carry out corrective environmental work.

8. Record-Keeping and MOCCAE Access

All records supporting emissions data must be retained for at least five years and made available to the Ministry of Climate Change and Environment on request.

9. The National MRV Platform

The Ministry of Climate Change and Environment launched the National MRV (Measurement, Reporting and Verification) Transparency System and the Integrated Emissions Quantification Tool (IEQT) at GITEX Global in October 2025.

✅ Reporting is submitted through the mrv.ae platform; companies in Abu Dhabi may also report through the Environment Agency Abu Dhabi’s (EAD) Enhanced Transparency Framework, which links to the national platform.

10. Step-by-Step Process for a Company

1.     Determine whether the company qualifies as a Huge Carbon Emission Entity (HCEE) — 0.5 million tonnes of CO2 equivalent or more per year across Scope 1 and Scope 2 combined.

2.     If an HCEE, register with the National Register for Carbon Credits (the initial registration wave’s deadline of 28 June 2025 has passed; confirm the current process with MOCCAE for new HCEEs).

3.     For any entity, begin measuring Scope 1 and Scope 2 emissions per the Greenhouse Gas Protocol methodology.

4.     Register on the national MRV platform and file reports through the IEQT tool (mrv.ae).

5.     Develop and document an emission reduction plan with concrete measures and timelines — vague intentions do not satisfy the law’s requirement.

6.     Set up retention of supporting records for at least five years.

7.     Track official MOCCAE announcements on the current status of the full-compliance deadline, rather than treating an anticipated extension as confirmed fact.

11. Common Mistakes

•       Assuming free zone registration exempts a company from the law’s requirements. The law’s primary text expressly extends its application to emission sources in every free zone without exception.

•       Delaying preparation while waiting for an official extension. An extension has been publicly signalled by MOCCAE representatives but no revised date is confirmed — a company unprepared for the original 30 May 2026 deadline carries genuine risk absent an official extension.

•       Preparing reporting only for Scope 1 while ignoring Scope 2. The law requires measurement and reporting of both simultaneously — these are parallel, not sequential, obligations for 2026.

•       Drafting an emission reduction plan in vague, non-specific terms. The law requires demonstrable, concrete measures with timelines, not declarative intentions.

12. Who This Information Fits

•       Any company operating in the UAE, including in free zones, whose activities generate greenhouse gas emissions. The law sets no turnover or headcount threshold — its scope is universal.

13. When Professional Verification Is Essential

Self-assessment is worth supplementing with specialist advice when: determining Huge Carbon Emission Entity (HCEE) status for a specific company; developing a methodologically sound emission reduction plan; and assessing the current status of the full-compliance deadline immediately before it arrives or any anticipated extension.

FAQ

Does the climate law apply to companies in UAE free zones?

Yes, the law’s primary text expressly extends its application to emission sources in every free zone without exception.

What is the full-compliance deadline set for all companies?

30 May 2026 per the law’s text; as of July 2026 this deadline has formally passed, but MOCCAE has indicated a likely extension without confirming a revised date.

What is a Huge Carbon Emission Entity (HCEE)?

A source emitting 0.5 million metric tonnes of CO2 equivalent or more per year, combined across Scope 1 and Scope 2, per Cabinet Resolution No. 67 of 2024.

Is Scope 3 reporting mandatory in 2026?

No, Scope 3 reporting is not mandatory for 2026; it is expected to become mandatory from 2027, though this is not confirmed by the law’s own text.

What is the fine for violating the climate law?

AED 50,000 to AED 2,000,000 for a first offence under Article 15, doubled for a repeat offence within two years under Article 16.

Key Takeaways

•       Federal Decree-Law No. 11 of 2024 was issued 28 August 2024 and entered into force 30 May 2025.

•       The full-compliance deadline for all entities is 30 May 2026; the status of any extension remains unconfirmed as of July 2026.

•       The law extends to every free zone without exception.

•       Huge Carbon Emission Entities (0.5 million tonnes CO2e/year or more) face separate, stricter requirements with an earlier registration deadline.

•       Fines range from AED 50,000 to AED 2,000,000, doubled for a repeat offence within two years.

•       Emissions records must be retained for at least five years and made available to MOCCAE on request.

Summary

Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects requires all companies in the UAE, including those registered in free zones, to measure, report, and reduce Scope 1 and Scope 2 greenhouse gas emissions. The law was issued 28 August 2024 and entered into force 30 May 2025; the full-compliance deadline for all entities is set at 30 May 2026. As of July 2026, this deadline has formally passed, but representatives of the Ministry of Climate Change and Environment (MOCCAE) have publicly indicated the deadline is likely to be extended pending technical guidance; no revised date has been confirmed. The law’s primary text extends its application to emission sources in every free zone without exception. Huge Carbon Emission Entities (0.5 million metric tonnes of CO2 equivalent or more per year across Scope 1 and Scope 2, defined by Cabinet Resolution No. 67 of 2024) were required to register with the National Register for Carbon Credits by 28 June 2025. Penalties for violation range from AED 50,000 to AED 2,000,000 under Article 15, doubled for a repeat offence within two years under Article 16. Reporting is filed through the national MRV platform and the IEQT tool, launched in October 2025.

Sources

• UAE Legislation — Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects, official text (uaelegislation.gov.ae)

• Library of Congress — United Arab Emirates: Climate Law Takes Effect, Supplementing National Emissions Strategy, official overview (loc.gov)

• PwC Middle East — UAE Climate Change Law: Mandatory Emissions Reporting Obligations (pwc.com)

• Ropes & Gray LLP — Preparing for New UAE GHG Emissions Reporting and Reduction Requirements, April 2026 (ropesgray.com)

• BDO UAE — Announcing the Federal Decree-Law No. (11) of 2024 (bdo.ae)

• Spectreco — UAE ESG Compliance: What the 30 May 2026 Deadline Means for GCC Businesses, confirming administrative measures (spectreco.com)

Disclaimer

This article is for informational purposes only and does not constitute legal, tax, or consulting advice. The status of the full-compliance deadline and details of MOCCAE's technical guidance remain under development — verify current information directly on the official uaelegislation.gov.ae portal and MOCCAE's website, and consult a qualified environmental law specialist in the UAE before making decisions. Information is accurate as of July 2026.