Preparing for New UAE GHG Emissions Reporting Requirements

UAE introduces mandatory emissions reporting from May 2025

The United Arab Emirates has passed new climate legislation that fundamentally changes how businesses operating in the region must manage their carbon footprint. Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects takes effect on 30 May 2025. It requires all organisations on the UAE mainland and in free zones to measure, report, verify and reduce their greenhouse gas emissions.

This marks a significant shift from voluntary environmental, social and governance efforts to enforceable legal obligations. The law applies to public and private entities of all sizes. There are no minimum emissions thresholds specified in the primary legislation. Organisations have until 30 May 2026 to achieve full compliance.

The Ministry of Climate Change and Environment now coordinates a national measurement, reporting and verification system. Businesses must submit regular emissions data through a dedicated digital platform. Third-party verification is mandatory. Penalties for non-compliance range from AED 50,000 to AED 2 million for first offences, potentially doubling for repeat violations within two years.

Legal framework supports UAE’s net zero commitment

Federal Decree-Law No. 11 of 2024 anchors the UAE’s Net Zero by 2050 strategy in binding legislation. The country has committed to reducing greenhouse gas emissions by 47% by 2035 compared with 2019 levels. These targets form part of the UAE’s Nationally Determined Contributions under the Paris Agreement.

Cabinet Resolution No. 67 of 2024 complements the Climate Change Law by establishing a National Register for Carbon Credits. This register tracks emissions, credits and retirements across the economy. It provides infrastructure for organisations to offset unavoidable emissions through verified carbon credits.

The law defines covered entities broadly as “Sources” that generate greenhouse gas emissions during their operations. Legal persons and individual enterprises both fall within scope. Consequently, the framework captures manufacturing facilities, logistics operations, commercial buildings, and service providers.

Organisations must measure three categories of emissions. Scope 1 covers direct emissions from owned or controlled sources such as company vehicles and on-site fuel combustion. Scope 2 includes indirect emissions from purchased electricity, heat or steam. Scope 3 encompasses relevant value chain emissions, though implementing regulations will clarify which categories are mandatory.

Measurement and reporting obligations begin in 2025

The Ministry of Climate Change and Environment has launched a digital platform for emissions reporting. All covered entities must register and submit periodic reports through this system. The platform went live in early 2025 to allow organisations time to establish data collection processes before the May deadline.

Businesses must prepare annual emissions inventories using methodologies approved by the Ministry. These inventories require systematic collection of activity data such as fuel consumption, electricity usage, and process outputs. Organisations then apply approved emission factors to convert this activity data into carbon dioxide equivalent figures.

Third-party verification adds a layer of accountability to the reporting process. Accredited auditors review emissions data, calculation methodologies and supporting evidence. They issue verification statements confirming the accuracy and completeness of reported figures. This independent scrutiny ensures the national emissions database reflects genuine carbon footprints rather than unchecked self-assessments.

Record retention requirements extend for five years. Organisations must maintain source documents, calculation worksheets, and verification reports. Regulators can request these records during compliance reviews or investigations.

Implementation timeline creates 12-month compliance window

The law received formal enactment and entered into force on 30 May 2025. From that date, measurement and reporting obligations became legally binding. However, the Ministry of Climate Change and Environment has structured enforcement to give organisations a transitional period.

Full compliance is required by 30 May 2026. This 12-month window allows businesses to establish emissions monitoring systems, train staff, engage verification bodies, and submit their first compliant reports. Organisations should not interpret this as optional preparation time. The law is already in force.

Early movers gain significant advantages during this period. Setting up robust data collection systems takes time. Identifying emission sources, establishing measurement protocols, and integrating reporting into financial calendars require careful planning. Organisations that start immediately can refine their processes through trial runs before enforcement intensifies.

The Ministry continues to develop sector-specific guidance and technical specifications. These implementing regulations will clarify reporting frequencies, materiality thresholds for Scope 3 categories, and approved calculation methodologies. Businesses should monitor official channels for updates as these details emerge throughout 2025.

Reduction measures extend beyond reporting requirements

The Climate Change Law does not stop at measurement and reporting. Article 6 explicitly requires organisations to implement measures that reduce their emissions. This creates a dual obligation: know your carbon footprint and take action to lower it.

The legislation identifies several reduction pathways. Transitioning to clean energy sources reduces Scope 2 emissions from purchased electricity. Energy efficiency improvements lower consumption across operations. Carbon capture, utilisation and storage technologies can mitigate emissions from industrial processes where alternatives are limited.

Verified carbon offsets provide a compliance mechanism for residual emissions that cannot be eliminated through operational changes. The National Register for Carbon Credits facilitates this by tracking offset purchases and retirements. However, offsets should complement rather than replace direct emission reductions.

Adaptation measures also feature in the law. Organisations must consider how climate change affects their operations and implement appropriate responses. For example, businesses in coastal areas might need to address sea level rise risks. Agricultural operations may need to adjust to changing rainfall patterns.

The Ministry of Climate Change and Environment will assess reduction plans as part of the verification process. Organisations cannot simply report static emissions year after year. They must demonstrate progress toward lower carbon intensity or absolute reductions over time.

Enforcement mechanisms carry substantial financial penalties

Administrative fines start at AED 50,000 for first-time violations. Serious or repeated non-compliance can attract penalties up to AED 2 million. Some guidance documents reference maximum fines of AED 4 million for the most severe breaches. Repeat offences within two years of a previous violation face doubled penalties.

These financial consequences make compliance a board-level risk management issue. A AED 2 million fine represents a material expense for most small and medium businesses. Even larger organisations would struggle to justify such costs to shareholders, particularly when they stem from avoidable non-compliance.

Reputational damage compounds the financial impact. Regulatory enforcement actions become public knowledge in business communities. Organisations competing for government contracts or seeking investment may find their non-compliance history affects tender outcomes or investor confidence. The UAE’s public procurement increasingly incorporates environmental criteria, making a clean compliance record commercially valuable.

The Ministry of Climate Change and Environment has powers to conduct audits and inspections. Officers can request documentation, interview staff, and verify that reported data matches operational reality. Organisations should prepare for such oversight by maintaining clear audit trails from source data through to final submissions.

Current compliance landscape and business response

Many UAE-based organisations are now assessing their readiness for the May 2026 deadline. Larger corporations with existing sustainability teams are adapting their voluntary reporting systems to meet legal requirements. Small and medium businesses often lack in-house expertise and are seeking external support to establish compliant processes.

International companies with UAE operations can leverage existing carbon accounting systems developed for other jurisdictions. The measurement methodologies align broadly with international standards such as the Greenhouse Gas Protocol. However, businesses must ensure their systems capture UAE-specific requirements and feed data into the national reporting platform.

Free zone entities sometimes assume environmental regulations apply differently to them. This law explicitly includes free zones in its scope. All organisations generating emissions in the UAE must comply regardless of their licensing jurisdiction or special economic zone status.

The absence of minimum thresholds means even small operations fall within scope. A single-location retail business, a small logistics provider, or a professional services firm all have reporting obligations if they generate measurable emissions. This comprehensive coverage reflects the UAE’s commitment to a complete national emissions inventory.

Essential requirements for covered organisations

The following points summarise the core obligations under Federal Decree-Law No. 11 of 2024:

• All public and private entities operating in the UAE mainland and free zones must measure and report greenhouse gas emissions, with no size or sector exemptions currently specified.
• Organisations must register with the Ministry of Climate Change and Environment’s digital reporting platform and submit verified emissions inventories using approved methodologies.
• Scope 1 direct emissions, Scope 2 indirect energy emissions, and relevant Scope 3 value chain emissions require measurement, though final Scope 3 requirements await implementing regulations.
• Third-party verification by accredited auditors is mandatory to confirm the accuracy of reported emissions data before submission.
• Businesses must implement active reduction measures such as clean energy adoption, energy efficiency improvements, or verified carbon offsets, not simply report static emissions.
• The law entered into force on 30 May 2025 with full compliance required by 30 May 2026, creating a 12-month implementation window.
• Non-compliance attracts fines from AED 50,000 to AED 2 million for first offences, potentially doubling for repeat violations within two years.
• Organisations must retain all emissions records, calculations and verification reports for five years and make them available to regulators upon request.

Practical steps for businesses operating in the UAE

Organisations should start by conducting a preliminary emissions assessment. This exercise identifies major emission sources across operations and estimates the scale of the carbon footprint. Understanding where emissions occur helps prioritise data collection efforts and resource allocation.

Establishing clear internal governance comes next. Assign responsibility for compliance to specific roles or teams. Define reporting lines to senior management and board level. Integrate emissions reporting into existing management systems rather than treating it as a standalone project.

Data systems need attention early in the process. Many organisations discover their existing records do not capture information in the format required for emissions calculations. For example, fuel purchase records might not distinguish between different vehicle types or usage categories. Upgrading invoicing and procurement systems now prevents scrambling for data later.

Engaging a qualified verification body before the first submission deadline helps identify gaps in methodology or documentation. Verifiers can conduct readiness assessments and recommend improvements while there is still time to implement changes. Waiting until days before the deadline leaves no margin for corrections.

Reduction planning should run parallel to measurement preparation. As organisations quantify their emissions, opportunities for reduction become apparent. Perhaps a significant portion of the footprint comes from inefficient equipment that was due for replacement anyway. Maybe switching electricity suppliers to renewable tariffs would substantially cut Scope 2 emissions at minimal cost.

Training staff across relevant functions ensures compliance becomes embedded in operations. Facilities managers, procurement teams, and financial controllers all play roles in gathering accurate data and implementing reduction measures. Brief workshops or guidance documents help these teams understand their responsibilities.

Organisations with operations in multiple jurisdictions should consider how UAE requirements interact with other regulatory frameworks. The UK’s Streamlined Energy and Carbon Reporting, the EU’s Corporate Sustainability Reporting Directive, and similar regulations in other markets create overlapping but not identical obligations. Designing systems that satisfy multiple regimes efficiently reduces duplication.

Additional guidance and official resources

The Ministry of Climate Change and Environment provides the primary source of information on the Climate Change Law and its implementation. Their official guidance documents, platform user manuals, and approved methodologies represent authoritative references for compliance. Organisations should register for updates through official Ministry channels to receive the latest technical specifications as they are published.

The Ministry of Climate Change and Environment website hosts resources including the measurement, reporting and verification platform access, approved verifier lists, and sector-specific guidance as it becomes available. Businesses can also find details of the National Register for Carbon Credits and offset eligibility criteria through this portal.

The UAE’s First Biennial Transparency Report, submitted under the United Nations Framework Convention on Climate Change, provides context on national climate commitments and reporting frameworks. This document is available through the UNFCCC website and demonstrates how organisational reporting feeds into national obligations under the Paris Agreement.

For UK businesses with UAE operations, understanding how this framework compares with domestic requirements helps coordinate compliance efforts. Our compliance support services assist organisations navigating multiple regulatory regimes and establishing efficient carbon reporting systems that satisfy different jurisdictional requirements.

Professional bodies such as the Institute of Environmental Management and Assessment publish guidance on international emissions measurement standards. These resources help businesses understand the technical foundations of carbon accounting that underpin the UAE’s regulatory approach.

Organisations seeking to develop internal capability might consider structured training on greenhouse gas measurement and reporting. The SBS Academy offers programmes covering Scope 1, 2 and 3 emissions calculation, verification preparation, and reduction strategy development for teams implementing new reporting obligations.