Decree-Law No. 11: what covered companies need to have ready

This guide summarises public sources as of October 2026. It is not legal advice. The Arabic text of the law is authoritative, and implementing guidance is still being issued, so check the current position with the Ministry of Climate Change and Environment (MOCCAE) or your adviser.

The law in brief

Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects was issued on 28 August 2024.¹ It provides that it enters into force nine months after publication,¹ which took it into effect on 30 May 2025.²³

Who it applies to

The law applies to “sources”, defined as public and private legal persons, as well as individual enterprises, whose operations or activities release greenhouse gases. It applies across the UAE, including free zones.¹

The law itself sets no size, sector or emissions threshold for this general definition.²⁴ However, the measurement and reporting duties in Article 6 apply to sources “determined by the Ministry and the competent authority”.¹ PwC advises that, until designations are clear, entities should assume they are in scope unless they can show otherwise.²

What covered sources must do

Under Article 6(1), designated sources must:¹

• Measure the emissions from their activities on a regular basis
• Prepare an emissions inventory and submit periodic reports
• Submit data on emissions-related activities to the Ministry and the competent authority
• Keep a record of measured emission quantities for five years from the date of each analysis, accessible to designated officers

Article 4 also requires sources to contribute to reducing their emissions to achieve climate neutrality, through means such as improving energy efficiency, using clean energy and carbon offsetting.¹

On which emissions to report, Scope 1 (direct emissions) and Scope 2 (purchased electricity and cooling) are widely treated as the minimum. Scope 3 value-chain reporting is anticipated by some advisers from 2027, but this has not been confirmed in law.⁴⁵

Penalties

Breaching the Article 6(1) obligations is punishable by a fine of not less than AED 50,000 and not more than AED 2,000,000 (Article 15). Penalties are doubled for a repeat of the same act within two years of a final judgment (Article 16). Administrative penalties are to be set by Cabinet resolution (Article 17).¹

Deadlines and where implementation stands

Article 18 gives sources one year from entry into force to bring their status into line with the law, and allows the Cabinet to extend that period on the Minister's proposal.¹ That made the first compliance date 30 May 2026, subject to any extension.²

As of October 2026, published reporting indicates that the technical guidance on calculating and submitting emissions has not yet been issued. MOCCAE indicated in April 2026 that the date was likely to be extended once guidance is published, but no extension has been formally announced.⁵⁶ In practice, companies should expect the obligation to become operative as designations and guidance arrive, and prepare now.

The reporting infrastructure

• Integrated Emission Quantification Tool. Launched by the Minister of Climate Change and Environment in December 2023 as part of the national Monitoring, Reporting and Verification (MRV) Transparency System, to estimate and report greenhouse gas emissions.⁷
• National MRV System. A national digital platform for tracking greenhouse gas emissions and air pollutants, launched by MOCCAE at GITEX Global 2025.⁸
• National Carbon Credit Registry. The law requires the Ministry to establish and manage it (Article 10(3)).¹ Under Cabinet Resolution No. 67 of 2024, entities emitting 0.5 million tonnes CO₂e or more a year must register.⁴⁵
• Emirate-level programmes. Some emirates run their own processes. Entities in Abu Dhabi may report through the Environment Agency – Abu Dhabi's MRV system, which links to the national platform.⁴

Checklist for your first reporting cycle

Each item below maps to an obligation or mechanism cited above.

1. Confirm your status. Check whether MOCCAE or your emirate's competent authority has designated your entity, and monitor for designations and guidance. (Article 6, Article 18)
2. Set up measurement. Identify every activity that releases greenhouse gases, site by site, and the data that measures it: fuel, electricity, cooling, refrigerants, process emissions. (Article 6(1)(a))
3. Build the inventory. Prepare an emissions inventory covering at least Scope 1 and Scope 2 using a recognised method such as the GHG Protocol. (Article 6(1)(a))
4. Organise the activity data. Keep the underlying activity data ready to submit to the Ministry and competent authority. (Article 6(1)(b))
5. Keep records for five years. Store measured quantities and evidence for five years from each analysis, in a form officers can inspect. (Article 6(1)(c))
6. Document reduction measures. Record what you are doing to reduce emissions, such as efficiency, clean energy or offsets. (Article 4)
7. Check emirate requirements. In Abu Dhabi, confirm whether you fall under the EAD MRV process. (EAD programme)
8. Check carbon registry obligations. If you emit 0.5 MtCO₂e or more a year, register with the National Carbon Credit Registry. (Cabinet Resolution No. 67 of 2024)
9. Plan for Scope 3. Start collecting supplier data so you are not starting from zero if value-chain reporting is required.

Sources

1. Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects, official English text, UAE Legislation portal. uaelegislation.gov.ae ↗
2. PwC Middle East, “UAE's Climate Change Law: Mandatory Emissions Reporting Obligations”, 27 November 2025. pwc.com ↗
3. Khaleej Times, “UAE: Up to Dh2 million fine as new climate law comes into effect”, 30 May 2025. khaleejtimes.com ↗
4. BSA Law, “UAE Climate Law: what every business needs to know before May 2026”, 8 April 2026. bsalaw.com ↗
5. Apollo, “UAE Climate Law: Who Has to Report Emissions and When (2026)”, 12 October 2026. apollo.eco ↗
6. Insight Advisory, “UAE Climate Law 2026: GHG Reporting Deadline & Fines”, June 2026. insightadvisory.ae ↗
7. Aletihad, “Mariam Almheiri launches UAE's Integrated Emission Quantification Tool”, 12 December 2023. en.aletihad.ae ↗
8. Zawya (MOCCAE press release), “MOCCAE launches National MRV System to support UAE's net zero goals”, October 2025. zawya.com ↗