UAE Climate Reporting Requirements: What Every Company Must Know

The UAE now has a binding federal climate law. Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects entered into force on 30 May 2025, requiring public and private entities, including free zone companies, to measure and report their greenhouse gas emissions, on pain of fines up to AED 2 million.1,2 Most mid-market companies still assume it applies to someone else. It does not.

The law defines an emissions "source" as any public or private legal person or individual enterprise whose activities release greenhouse gases, regardless of size or sector.3 The one-year adjustment period ended on 30 May 2026, the obligations are live. This guide maps the landscape as it stands in July 2026: the federal climate law, the Securities and Commodities Authority (SCA) rules for listed companies, ADX and DFM exchange guidance, the DIFC and ADGM regimes, and the ISSB's IFRS S1 and S2 as the emerging baseline.

Key takeaways. Federal Decree-Law No. 11 of 2024 is binding law, in force since 30 May 2025, requiring entities across the UAE, free zones included, to measure, record and report GHG emissions, with fines of AED 50,000 to AED 2 million, doubled for repeats within two years.2,3 Emitters of 500,000 tCO₂e or more per year (Scope 1 and 2) faced an earlier deadline of 28 June 2025 under Cabinet Resolution No. 67 of 2024.4,5 SCA-listed companies must already publish an annual GRI-based sustainability report, a listing obligation, not guidance.7 The exchange ESG guides are voluntary and ADGM's rules comply-or-explain, but the federal law is neither: it is mandatory.8,11 IFRS S1 and S2 are not yet mandated in the UAE, yet regulators and regional peers are converging on the ISSB baseline, building on it now is the lowest-regret move.13

What does Federal Decree-Law No. 11 of 2024 actually require?

The Climate Law converts national ambition into enforceable corporate duties. Issued in August 2024 and in force since 30 May 2025,2 it is the legislative backbone of UAE Net Zero 2050, the first net-zero commitment announced by a MENA nation.15 Entities designated as emissions sources must:

  • Measure: quantify GHG emissions using methodologies specified by the Ministry of Climate Change and Environment (MOCCAE) or the competent emirate-level authority.3
  • Report: submit periodic emissions reports with existing and planned reduction measures,2 via the national measurement, reporting and verification (MRV) system MOCCAE has launched.4
  • Keep records: retain emissions data and supporting records for at least five years.2
  • Reduce: incorporate the annual reduction targets MOCCAE will set into strategy, and adopt mitigation and adaptation measures.2

Two features deserve particular attention. First, territorial scope: the law applies onshore and in free zones, a deliberate choice that captures the tens of thousands of companies registered in the DIFC, ADGM, JAFZA, DMCC and the rest.3 Second, record-keeping: five years of retained, defensible emissions data is an evidentiary standard closer to tax records than to voluntary CSR reporting. A spreadsheet built once a year by a consultant will not withstand it.

The Climate Law carries administrative fines of AED 50,000 to AED 2,000,000 (roughly US$13,600 to US$545,000) per violation, doubled if the same violation is repeated within two years: and it applies to every entity in the UAE, free zones included.23

The practical takeaway: treat the measurement and record-keeping duties as applying now, because the adjustment period has already run out.

Figure 1. From voluntary exchange guidance (2019) to binding federal climate law in six years, teal markers are binding obligations, navy are policy milestones, amber flags MRV reporting deadlines that may still shift.
2019 ADX & DFM issue ESG guidance 2020 SCA mandates GRI reports for listed cos Oct 2021 UAE Net Zero 2050 announced Aug 2024 Climate Law issued; Cabinet Res. 67/2024 30 May 2025 Climate Law in force 28 Jun 2025 NRCC deadline, emitters ≥500k tCO₂e 30 May 2026 Adjustment period ends, duties live 2026–27 Detailed MRV deadlines , may be phased Amber: MOCCAE representatives have signalled some detailed reporting timelines may be phased or extended pending technical guidance (law-firm commentary, 2026).

Who must measure and report GHG emissions under the UAE climate law?

The honest answer as of July 2026: potentially everyone. The sharpest obligations crystallise first for large emitters and in emirates with live reporting systems. Three tiers are visible.

Tier 1, large emitters. Cabinet Resolution No. 67 of 2024 established the National Register for Carbon Credits (NRCC), and the regularisation deadline for entities above its threshold was 28 June 2025.4,5 These entities need annual GHG inventories prepared to recognised standards, with independent verification by approved verifiers.

Scope 1+Scope 2≥500,000 tCO₂e / year→NRCC registration + verified reporting

The Cabinet Resolution 67/2024 threshold test: at or above 500,000 tCO₂e a year across Scopes 1 and 2, NRCC registration, quantification and independent verification are mandatory.4,5

Tier 2, entities captured by emirate-level systems. Abu Dhabi operates the most developed regime: facilities in industry, power, oil and gas, and transport with annual Scope 1 emissions of 25,000 tCO₂e or more must report through an electronic portal by 31 March each year.3 Other emirates are expected to follow with their own designations and thresholds.

Tier 3, everyone else. The Climate Law's text contains no de minimis threshold. Advisers reporting on MOCCAE's implementation indicate the initial mandatory focus is Scope 1 and Scope 2, and law-firm commentary in 2026 noted MOCCAE signals that some reporting timelines may be phased or extended while technical guidance is finalised.3,4 That is a reason to plan sensibly, not to wait, the duties to measure and keep records exist now, and designated sources will not get a second adjustment period.

Practical test: if your company operates vehicles, generates on-site emissions, or buys electricity or chilled water in the UAE, and virtually every company does at least one, assume you have a measurement obligation and determine your tier.

What must SCA-listed companies publish?

Listed companies carry a second, longer-standing layer of obligation. Under SCA Chairman of the Board Decision No. (3/R.M) of 2020 concerning the corporate governance guide, public joint stock companies listed on ADX or DFM must publish an annual sustainability report, Article 76 anchors it to the Global Reporting Initiative (GRI) standards.7 This has applied since financial year 2020. It is a compliance obligation, not an option.

The exchanges add a guidance layer on top:

  • ADX published its ESG Disclosure Guidance in 2019, built around 31 KPIs aligned with GRI and the Sustainable Stock Exchanges (SSE) initiative's model guidance, GHG emissions and intensity, energy, water, board diversity and more.8,9
  • DFM issued its ESG Reporting Guide in 2019 on the same SSE/GRI model and maintains an active ESG programme for issuers.10

The distinction matters for prioritisation: the SCA report is mandatory, while the exchange KPI guides tell you what good looks like and what institutional investors expect to find. A listed company in 2026 answers to the SCA, its exchange and the federal climate regime at once, the only efficient way to do that is a single underlying data set reported through different lenses.

What do the DIFC and ADGM regimes require?

Neither financial free zone exempts its companies from the federal Climate Law, which expressly reaches into free zones.3 But each adds its own layer.

ADGM (regulated by the FSRA) is furthest ahead. Its Sustainable Finance Regulatory Framework, implemented in July 2023, covers green and climate transition funds, portfolios and bonds, and, for corporates, ESG disclosure: ADGM companies with turnover above US$68 million, and FSRA-licensed fund and asset managers with over US$6 billion under management, must make annual ESG disclosures on a comply-or-explain basis, using a globally accepted standard such as GRI, TCFD or the ISSB Standards.11,12

DIFC (regulated by the DFSA) has taken a principles-led route. The DFSA is a founding member of the UAE Sustainable Finance Working Group alongside the Central Bank, the SCA and the FSRA, which issued Principles for Sustainability-Related Disclosures for reporting entities, minimum guidance each regulator applies within its own framework rather than a single binding mandate.13 Expect the DFSA to firm up expectations as the ISSB baseline consolidates, and remember the federal Climate Law already applies in the DIFC today.

Where climate reporting is mandatory in the UAE, the full landscape

Table 1 puts the regime map in one place. Read the status column carefully: several of these are binding law or listing rules today, and only the ISSB layer is genuinely voluntary.

Regime Who is captured What is required Status (Jul 2026)
Federal Decree-Law No. 11 of 2024 (MOCCAE) All public and private entities, incl. free zones; no size threshold in the law Measure GHG emissions, report via the national MRV system, keep records 5 years, adopt reduction measures2 Mandatory in force 30 May 2025; fines AED 50k–2m, doubled for repeats
Cabinet Resolution No. 67 of 2024 (NRCC) Large emitters ≥500,000 tCO₂e/year (Scope 1 + 2) Register, quantify, independently verify emissions; deadline was 28 Jun 20254,5 Mandatory fines AED 500k / 1m / 2m for successive offences6
Abu Dhabi emirate reporting Facilities ≥25,000 tCO₂e Scope 1 in industry, power, oil & gas, transport Annual calendar-year GHG report via electronic portal by 31 March3 Mandatory for designated facilities
SCA Decision 3/R.M of 2020, Art. 76 Public joint stock companies listed on ADX or DFM Annual sustainability report against GRI standards7 Mandatory for listed since FY2020
ADGM Sustainable Finance Framework (FSRA, 2023) ADGM companies with turnover > US$68m; managers with AUM > US$6bn Annual ESG disclosures using a recognised standard (GRI, TCFD, ISSB)11,12 Comply-or-explain
ADX ESG Disclosure Guidance (2019) ADX-listed companies 31 ESG KPIs aligned with GRI/SSE, incl. GHG emissions and intensity8,9 Guidance expected by investors
DFM ESG Reporting Guide (2019) DFM-listed companies ESG KPI disclosure aligned with GRI/SSE model guidance10 Guidance
DFSA / UAE SFWG Disclosure Principles Reporting entities in DIFC and across the UAE financial sector Minimum sustainability-disclosure principles, applied within each regulator's framework13 Guidance expected to harden
IFRS S1 & S2 (ISSB) No UAE mandate yet; referenced by regulators, adopted voluntarily by leading issuers Governance, strategy, risk management, metrics incl. Scope 1–314 Voluntary the emerging baseline

The obligations stack rather than substitute: every entity sits on the federal base layer, and listing, free zone registration and emitter size each add a layer on top, Figure 2 shows how the strands fit together.

Figure 2. The UAE multi-regulator landscape: the federal Climate Law is the base layer for every entity, with SCA listing rules, exchange guidance and the two financial free zone regimes stacked on top.
Five regulatory strands, one underlying GHG data set SCA Listed PJSCs (ADX/DFM) Annual GRI sustainability report, Art. 76, since FY2020 MANDATORY FOR LISTED ADX & DFM Listed companies ESG guides (2019): 31 KPIs, GRI/SSE model GUIDANCE DIFC (DFSA) DIFC reporting entities UAE SFWG principles for sustainability disclosures GUIDANCE, HARDENING ADGM (FSRA) Turnover > US$68m; managers AUM > US$6bn ESG disclosure (2023) COMPLY-OR-EXPLAIN NRCC, emitters ≥500,000 tCO₂e/yr (Scope 1+2) Cabinet Res. 67/2024 · verified inventory · deadline 28 Jun 2025 Abu Dhabi, facilities ≥25,000 tCO₂e Scope 1 Industry, power, oil & gas, transport · portal report by 31 Mar Federal Decree-Law No. 11 of 2024, every UAE entity, onshore and free zone Measure · report via national MRV · keep records 5 years · reduce, MANDATORY Boxes show the regulator, who is captured and the instrument; layers stack, a listed ADGM company can sit in three at once.

What are the penalties for non-compliance?

Failure to measure, failure to keep records and failure to report are each sanctionable. Under the parallel NRCC regime, large emitters face escalating fines of AED 500,000, AED 1,000,000 and AED 2,000,000 for first, second and third offences.4,6 A first fine at even the middle of the federal range would exceed the cost of a compliant reporting capability many times over. Figure 3 puts the fine bands and the two hard thresholds on one page.

Figure 3. Climate Law fines run AED 50,000–2,000,000 per violation (doubled for repeats within two years, in amber), NRCC fines escalate per offence, and the two mandatory-reporting thresholds sit at 500,000 and 25,000 tCO₂e per year.
A. Administrative fines (AED per violation) 0 1m 2m 3m 4m Climate Law, minimum AED 50,000 Climate Law, maximum ×2 if repeated within two years AED 2,000,000 NRCC, 1st offence AED 500,000 NRCC, 2nd offence AED 1,000,000 NRCC, 3rd offence AED 2,000,000 B. Mandatory reporting thresholds (tCO₂e per year) NRCC federal (Scope 1+2) 500,000 tCO₂e Abu Dhabi facilities (Scope 1) 25,000 tCO₂e, industry, power, oil & gas, transport The Abu Dhabi sectoral threshold is 1/20th of the federal NRCC threshold, far smaller facilities are already in scope at emirate level. Sources: Federal Decree-Law 11/2024; Cabinet Resolution 67/2024; law-firm summaries (refs 2–6). AED 2m ≈ US$545,000.

Is ISSB reporting (IFRS S1 and S2) mandatory in the UAE?

Not yet, and precision matters here, because vendors routinely overstate the position. As of July 2026 the UAE has made no formal jurisdictional adoption announcement for IFRS S1 and S2.14 What is true:

  • The four financial regulators' joint disclosure principles are built by reference to international standards and best practice.13
  • ADGM explicitly lists the ISSB Standards among the accepted frameworks for its ESG disclosures.12
  • A growing number of UAE listed companies already reference the ISSB Standards voluntarily.14
  • Regional momentum is unmistakable: Qatar was first in the region to announce ISSB adoption, with QFC requirements expected from 1 January 2026, and Jordan has mandated IFRS S2 for the Amman exchange's top listed companies from 2026.14 The ISSB itself finalised targeted amendments to IFRS S2 in December 2025 to ease implementation.16

Why build on IFRS S1 and S2 today, without a mandate? Because the ISSB framework, governance, strategy, risk management, metrics and targets, is a superset of what the UAE regimes ask for. A company that can produce an IFRS S2-aligned disclosure can, from the same data, satisfy the federal MRV submission, the SCA sustainability report, the exchange KPI guides and ADGM's ESG disclosure. Build once, report four ways. A minimal, regulator-by-regulator patchwork will be rebuilt within two reporting cycles.

How do you build a compliant GHG inventory (Scopes 1, 2 and 3)?

Every regime above rests on the same foundation: a GHG inventory that would survive scrutiny by a verifier, a regulator or an auditor. The current mandatory regimes focus on Scope 1 (direct emissions, fuel, fleet, refrigerants, process emissions) and Scope 2 (purchased electricity, cooling and heat).3,4 IFRS S2 goes further, requiring material Scope 3 disclosure across all 15 value-chain categories, from purchased goods and services to financed emissions.

A UAE-specific inventory has particular wrinkles worth planning for:

  • Electricity and cooling: district cooling is a major Scope 2 line for UAE real estate and occupiers, and emirate-level grid emission factors differ, document which you used and why.
  • Organisational boundary: UAE groups commonly span onshore entities, free zone entities and international branches. Fix your consolidation approach (operational control is the usual choice) before collecting a single data point, the Climate Law, the NRCC and IFRS S2 all assume a defined boundary.
  • Evidence: the five-year record-keeping duty means every figure needs a source document, utility invoices, fuel cards, refrigerant logs, tenancy schedules, retained and linked to the calculation. This is where most first-year inventories fail verification.
  • Scope 3 phasing: no UAE regime mandates Scope 3 today, but ISSB alignment does where material. Screen all 15 categories, quantify the two or three that dominate (typically purchased goods, capital goods, and use of sold products or financed emissions), and improve data quality year on year.

The practical takeaway: treat the GHG inventory like a financial ledger, defined boundary, documented factors, evidence behind every number, because regulators will.

Net Zero 2050 alignment and scenario analysis

The Climate Law is not only a reporting statute. It obliges entities to work towards national reduction targets and adopt adaptation measures, in service of the UAE Net Zero 2050 strategic initiative announced in October 20212,15, converting "net zero" from a marketing pledge into a planning constraint.

IFRS S2 supplies the tool: climate-resilience assessment using scenario analysis. For a UAE company the exercise is unusually concrete, national reduction targets, energy prices and NRCC carbon-credit markets on the transition side; extreme heat, water stress and coastal exposure on the physical side, which in the Gulf are operating conditions rather than tail risks. A proportionate first pass, two scenarios, one orderly-transition and one hot-house, applied to your top revenue and cost drivers, is achievable in a quarter and satisfies the "qualitative, commensurate with capability" bar the ISSB sets for first-time reporters.

How the obligations bite differently by sector

Real estate and construction

Scope 2 dominates through electricity and district cooling; embodied carbon makes Scope 3 category 2 (capital goods) material for developers. Abu Dhabi's 25,000 tCO₂e facility threshold can capture large mixed-use assets directly.3 Expect tenant data requests to intensify as listed occupiers chase their own Scope 3 numbers, metered, evidence-backed consumption data is becoming a leasing advantage.

Logistics and transport

Transport is one of Abu Dhabi's four designated reporting sectors.3 Fleet fuel is Scope 1 and easy to measure well; the harder questions are subcontracted haulage (Scope 3 category 4) and refrigerated warehousing, refrigerant leakage is a routinely under-counted Scope 1 line. A UAE regime-compliant inventory doubles as the answer to the CSRD- and ISSB-driven data requests already arriving from European and listed customers.

Financial services

Banks, asset managers and insurers face the layered regime most acutely: the federal law for their own operations, SCA rules if listed, ADGM ESG disclosures or DFSA expectations in the free zones, and the SFWG principles throughout.11,13 Their dominant exposure is financed emissions, Scope 3 category 15, and the data lead time there is measured in years, not months.

What a readiness plan looks like, and what verifiers actually check

A practical sequence for a finance or sustainability team starting from a low base:

  • Determine your exposure (weeks 1–2). Which emirates do you operate in? Are you listed? DIFC or ADGM registered? Above the ADGM turnover threshold? Anywhere near 25,000 tCO₂e, roughly 9–10 million litres of diesel, or the electricity of a large campus? Map every group entity against Table 1.
  • Assign ownership and register (weeks 2–4). Give a named executive accountability, the emerging UAE pattern pairs the CFO with a sustainability lead, and establish your registration position with MOCCAE's MRV system and any emirate-level portal.4
  • Fix the boundary and build the Scope 1–2 inventory (months 1–3). Choose a consolidation approach, collect twelve months of fuel, refrigerant, electricity and cooling data, and apply documented emission factors.
  • Establish the evidence register and controls (months 2–4). Five-year retention, version control, an audit trail from source document to reported number, a repeatable close process.
  • Screen Scope 3 and run a first scenario analysis (months 3–6). Rank the 15 categories by materiality, quantify the leaders, run a two-scenario resilience assessment against Net Zero 2050 assumptions.
  • Report through every required lens (months 4–6). Produce the MRV submission, the SCA/GRI report if listed, exchange KPIs and an ISSB-aligned disclosure from one data set, then improve data quality each cycle.

What do verifiers and regulators actually probe? Four things, consistently: that your organisational boundary matches your legal structure; that every activity-data figure traces to a source document; that emission factors are current, referenced and appropriate to the emirate and utility; and that year-on-year movements are explained rather than silently restated. First-year inventories rarely fail on arithmetic, they fail on evidence.

The whole sequence is achievable in roughly six months from a standing start. The companies that struggle are not the ones that started small; they are the ones that started late.

Frequently asked questions

Is greenhouse gas emissions reporting mandatory in the UAE?

Yes. Federal Decree-Law No. 11 of 2024, in force since 30 May 2025, requires public and private entities in the UAE, including free zone companies, to measure their greenhouse gas emissions, report them in line with standards set by the Ministry of Climate Change and Environment, keep records for at least five years, and work towards national reduction targets.2 Detailed thresholds and reporting mechanics are being rolled out through implementing decisions and emirate-level systems.3

What are the penalties for non-compliance with the UAE climate law?

Fines under Federal Decree-Law No. 11 of 2024 range from AED 50,000 to AED 2,000,000, and can be doubled for repeat violations committed within two years.2 Separately, Cabinet Resolution No. 67 of 2024 sets escalating fines of AED 500,000, AED 1,000,000 and AED 2,000,000 for large emitters that fail to comply with the National Register for Carbon Credits regime.4,6

Do DIFC and ADGM free zone companies have to comply with Federal Decree-Law 11 of 2024?

Yes. The climate law expressly applies to entities operating in UAE free zones, including financial free zones such as the DIFC and ADGM.3 Free zone companies may also face additional regime-specific obligations, such as ADGM's ESG disclosure requirements for larger companies.12

Is ISSB reporting (IFRS S1 and S2) mandatory in the UAE?

Not yet, as of July 2026, the UAE has not formally mandated IFRS S1 and S2. But UAE regulators reference international standards in their disclosure principles, ADGM lists ISSB among accepted reporting standards, many UAE listed companies already reference the ISSB Standards voluntarily, and regional peers such as Qatar have announced adoption.14 Building reporting around IFRS S1 and S2 today is the lowest-risk strategy.

Do UAE listed companies have to report Scope 3 emissions?

There is no explicit federal Scope 3 mandate yet; current mandatory GHG regimes focus on Scope 1 and Scope 2. However, SCA-listed companies reporting under GRI standards are expected to address material emissions, and IFRS S2 requires Scope 3 disclosure across all 15 categories where material, so companies planning ISSB alignment should start building Scope 3 capability now.

When is the UAE climate law compliance deadline?

The law entered into force on 30 May 2025 with a one-year adjustment period ending 30 May 2026, so obligations are now live. Large emitters over 500,000 tCO2e per year had until 28 June 2025 to regularise under Cabinet Resolution No. 67 of 2024.4 Ministry representatives have indicated that some detailed reporting timelines may be phased or extended pending technical guidance,3 but companies should treat measurement and record-keeping duties as applying now.

The law's core obligation is measurement, start there.

Every regime in this guide rests on one defensible Scope 1–3 GHG inventory. EcoLedger's GHG Emissions Calculator Pro builds it with documented emission factors, all 15 Scope 3 categories and an audit trail behind every figure, the evidence standard the Climate Law now demands.

See the Carbon Accounting Software

References

  1. UAE Legislation Portal, Federal Decree-Law of 2024 on the Reduction of Climate Change Effects (official text), accessed July 2026.
  2. PwC Middle East, UAE Climate Change Law, accessed July 2026.
  3. Ropes & Gray LLP, Preparing for New UAE GHG Emissions Reporting and Reduction Requirements (April 2026), accessed July 2026.
  4. Meysan, UAE Launches National Measurement, Reporting and Verification System under the Climate Change Law, accessed July 2026.
  5. UAE Legislation Portal, Cabinet Resolution No. (67) of 2024 Concerning the National Register for Carbon Credits, accessed July 2026.
  6. Reed Smith LLP, New carbon credit law to impact UAE businesses (December 2024), accessed July 2026.
  7. Greenplaces regulation library, SCA Decision 3/RM/2020, UAE listed company sustainability reporting, accessed July 2026.
  8. Abu Dhabi Securities Exchange, ESG Disclosure Guidance for Listed Companies, accessed July 2026.
  9. UN Sustainable Stock Exchanges Initiative, Abu Dhabi Securities Exchange creates ESG disclosure guidance for listed companies, accessed July 2026.
  10. Dubai Financial Market, ESG & Sustainability, accessed July 2026.
  11. ADGM, ADGM Implements its Sustainable Finance Regulatory Framework (July 2023), accessed July 2026.
  12. Holtara, Navigating ADGM's ESG Disclosure Framework, accessed July 2026.
  13. DFSA, Members of the UAE Sustainable Finance Working Group launch consultation on Principles for Sustainability-Related Disclosures for Reporting Entities, accessed July 2026.
  14. KPMG Lower Gulf, Two years in: adoption of the ISSB Standards, accessed July 2026.
  15. UAE Government Portal, UAE Net Zero 2050, accessed July 2026.
  16. IFRS Foundation, ISSB issues targeted amendments to IFRS S2 to support implementation (December 2025), accessed July 2026.

This guide reflects the position as of 16 July 2026 and is general information, not legal advice. Implementing decisions under Federal Decree-Law No. 11 of 2024 continue to evolve, confirm current thresholds and deadlines with MOCCAE, your emirate authority, or counsel.

Back to blog