UAE Federal Decree-Law 11/2024, formally titled the Federal Law on the Reduction of Climate Change Effects, is the first comprehensive climate legislation issued by the United Arab Emirates. It entered into force on 30 May 2026 and requires every UAE entity to maintain a greenhouse gas (GHG) inventory, file an annual disclosure with the Ministry of Climate Change and Environment (MOCCAE), and implement reduction measures aligned with the UAE Net Zero 2050 strategy.
If you operate in the UAE, the law applies to you. There is no size threshold, no sectoral exemption, and no free-zone carve-out. This guide explains what the law requires, what the penalties are, what verification standards apply, and the practical path from where most entities are today to a filing your auditor can defend twelve months from now.
UAE Climate Law at a glance
| Item | Detail |
|---|---|
| Official short name | UAE Climate Law |
| Formal citation | Federal Decree-Law 11 of 2024 |
| Long title | Federal Law on the Reduction of Climate Change Effects |
| Entered into force | 30 May 2026 |
| Implementing regulation | Cabinet Resolution 67/2024 |
| Competent authority | Ministry of Climate Change and Environment (MOCCAE) |
| Filing portal | National MRV system, mrv.ae (IEQT format) |
| Filing cadence | Annual, due 30 May each year |
| Scope | Every UAE entity. No size threshold. Free zones included. |
| Inventory standard | ISO 14064-1:2018 and GHG Protocol Corporate Standard |
| Verification standard | ISO 14064-3:2019 (mandatory above 500,000 tCO2e Scope 1+2) |
| Data retention | Five years |
| Penalty range | AED 50,000 to AED 2,000,000 per offence |
| Doubled penalty for repeat violations | Up to AED 4,000,000 within 24 months |
Who does the law apply to?
Article 4 of the Federal Decree-Law sets the scope broadly. Every establishment operating in the UAE, public or private, with an active trade licence is in scope. This includes:
- Mainland onshore companies of any size or sector
- Free-zone entities in ADGM, DIFC, JAFZA, DMCC, DAFZA, KIZAD, SAIF Zone, RAKEZ, FAZ, Ajman Free Zone, and every other federal or emirate-level free zone
- Listed Public Joint Stock Companies (PJSC) on ADX or DFM
- Federal and local government bodies, authorities and councils
- Branches of foreign companies operating in the UAE
- Sole proprietorships and professional licences above the de minimis threshold
There is no carve-out for small or medium enterprises. The MOCCAE filing format scales with the size of the entity, but the obligation to file does not.
The four core obligations
The law imposes four substantive obligations on every in-scope entity.
1. Maintain a GHG inventory
Quantify Scope 1 (direct emissions from owned or controlled sources) and Scope 2 (indirect emissions from purchased electricity, steam, heat or cooling) on an annual basis. The inventory must be prepared in accordance with ISO 14064-1:2018 and the GHG Protocol Corporate Standard. Scope 3 emissions are encouraged but not mandatory in the first cycle.
Sub-region grid factors apply to electricity. The UAE grid is not homogeneous; emissions vary by utility:
| Utility | Coverage | kgCO2e / kWh (2024) |
|---|---|---|
| DEWA | Dubai | 0.420 |
| AADC | Abu Dhabi (central distribution) | 0.355 |
| EWEC | Abu Dhabi (western region and bulk supply) | 0.480 |
| FEWA | Northern Emirates (Ras Al Khaimah, Ajman, Umm Al Quwain, Fujairah) | 0.500 |
2. File the annual MOCCAE disclosure
Submit the inventory to MOCCAE via the National MRV system at mrv.ae in the IEQT (Inventory, Emissions, Quantities, Targets) workbook format. The format is prescribed; cells must be in the correct sheets and columns. A submission with the right numbers in the wrong cells will be rejected.
SuperESG generates the MOCCAE-format XLSX in one click from your activity-data ledger. See our step-by-step guide: How to file a MOCCAE GHG inventory.
3. Implement reduction measures
Article 8 requires every entity to develop and implement reduction measures aligned with the UAE Net Zero 2050 strategy. The law does not prescribe specific targets, but it does require that measures be evidenced and reported. For most entities this means a baseline year, a reduction trajectory, and a portfolio of measures (energy efficiency, on-site renewables, fleet electrification, refrigerant management, waste reduction) tracked against quantified outcomes.
4. Retain audit-grade evidence for five years
Every meter reading, utility bill, emission factor citation, evidence file, and submitted disclosure must be retained for five years from the end of the reporting period. This is the obligation most entities underestimate. A filing produced from a consultant's spreadsheet without retained source documents is not defensible in a MOCCAE inspection.
Penalties under Cabinet Resolution 67/2024
Cabinet Resolution 67/2024 sets the administrative penalty schedule. Fines range from AED 50,000 to AED 2,000,000 per offence. The schedule scales with the severity of the violation:
| Violation | Penalty range |
|---|---|
| Failure to file annual GHG inventory | AED 100,000 to AED 500,000 |
| Filing materially false or misleading data | AED 500,000 to AED 2,000,000 |
| Failure to retain supporting evidence for five years | AED 50,000 to AED 250,000 |
| Failure to implement required reduction measures | AED 250,000 to AED 1,000,000 |
| Obstruction of MOCCAE inspection | AED 500,000 to AED 2,000,000 |
| Any violation, repeated within 24 months | Doubled, up to AED 4,000,000 |
Fines are counted per offence, not per filing year. An entity that fails to file, fails to retain evidence, and provides incomplete data has three separate offences. Repeated violations within a 24-month window double the applicable fine.
We've covered the penalty regime in detail, including remediation paths for entities that missed the first deadline, in What happens if you miss the UAE Climate Law deadline.
When is third-party verification required?
ISO 14064-3:2019 third-party verification is mandatory for entities whose combined Scope 1 and Scope 2 emissions exceed 500,000 tonnes of CO2-equivalent per year. Below that threshold, verification is voluntary, but practically expected by:
- External financial auditors signing off on annual accounts
- Sustainability assurance providers issuing limited or reasonable assurance opinions
- Lenders applying sustainability-linked loan covenants
- Investors and ratings agencies running ESG due diligence
In practice, even entities far below the 500,000 tCO2e threshold benefit from a workflow that could be verified, because the same workflow produces a defensible audit trail. The cost of building a ledger that satisfies ISO 14064-3 is the same as the cost of building one that does not; the difference is in the design.
The path to a defensible filing
Most UAE entities take one of three paths to MOCCAE compliance. Only one of them holds up under inspection twelve months later.
Path 1: Consultant-led spreadsheet
The most common path in 2026. A consultant collects utility bills, transcribes the kWh totals into a workbook, applies emission factors from a slide deck, produces an XLSX, and emails it back. Fast to file. Hard to defend. The consultant has the source documents; the entity has a number. When MOCCAE inspects in 2027, the entity cannot reproduce the calculation from its own records.
Path 2: In-house spreadsheet built from scratch
The finance team or sustainability lead builds the workbook in-house. Source documents are retained on the company drive. Slower to file. More defensible than path 1, but the ledger is a black box: when an auditor asks how a specific tonne was calculated, the answer is in a formula three sheets deep that nobody can trace.
Path 3: A platform with audit-grade lineage
Every utility bill is uploaded as evidence. The bill is matched to a published emission factor with version and source URL. The factor and the quantity produce a kgCO2e value that is stored as a row in a ledger. Every disclosure on every framework reads from the ledger; nothing is recalculated downstream. When MOCCAE inspects, the entity opens the platform, drills from the disclosed total to the source utility bill, and shows the inspector the original PDF.
SuperESG is built for path 3. Read our methodology for the full factor library and the audit-trail design.
Related UAE frameworks
The Federal Climate Law is the floor. Several additional frameworks apply to subsets of UAE entities and are expected to be reported alongside the MOCCAE filing.
| Framework | Applies to | Authority |
|---|---|---|
| SCA Decision 3/RM/2020 Article 76 | Listed PJSCs on ADX and DFM | Securities and Commodities Authority |
| ADX ESG Disclosure Guidance (June 2025) | ADX-listed entities | Abu Dhabi Securities Exchange |
| DFM ESG Reporting Guide (2025) | DFM-listed entities | Dubai Financial Market |
| ADGM Sustainability Disclosure | ADGM free-zone entities above turnover thresholds | Abu Dhabi Global Market |
| DFSA Markets Brief MB 27 | DIFC-regulated firms | Dubai Financial Services Authority |
| IFRS S2 (Climate) | Overlay expected by ADX | ISSB / IFRS Foundation |
| GRI Universal Standards 2021 | Overlay expected by DFM | Global Reporting Initiative |
Frequently asked questions
What is UAE Federal Decree-Law 11/2024?
UAE Federal Decree-Law 11/2024 is the Federal Law on the Reduction of Climate Change Effects, the first comprehensive climate legislation issued by the United Arab Emirates. It came into force on 30 May 2026 and requires every UAE entity to maintain a greenhouse gas (GHG) inventory, file an annual disclosure with the Ministry of Climate Change and Environment (MOCCAE), and implement reduction measures aligned with the UAE Net Zero 2050 strategy.
Who does the UAE Climate Law apply to?
Every entity operating in the UAE. There is no size threshold and no sectoral exemption. The law applies equally to onshore mainland companies, free-zone entities (including ADGM, DIFC, JAFZA, DMCC and the rest), small and medium businesses, and large listed conglomerates. Government bodies and authorities are also in scope. If you have a UAE trade licence, you have a compliance obligation.
What is the deadline for the first MOCCAE filing?
30 May 2026. The first annual GHG inventory had to be submitted to MOCCAE by that date, in the format prescribed by the National MRV system at mrv.ae. Subsequent filings are due each year on the same date. Entities that missed the first deadline are not exempt; they must still file and may be subject to penalty proceedings under Article 11 of the law.
What are the penalties for non-compliance?
Administrative fines range from AED 50,000 to AED 2,000,000 per offence under Cabinet Resolution 67/2024. Repeat violations within 24 months double, taking the maximum to AED 4,000,000. Fines are counted per offence, not per filing year, so a single entity with multiple separate violations can accumulate significant exposure. The Ministry can also order suspension of activities pending remediation.
When is third-party verification required?
ISO 14064-3:2019 third-party verification is mandatory for entities with combined Scope 1 and Scope 2 emissions above 500,000 tonnes of CO2-equivalent per year. Below that threshold, verification is voluntary, but most external auditors and assurance firms request a working ledger before they will sign off on annual sustainability disclosures.
How long must climate data be retained?
Five years. Every meter reading, utility bill, emission factor source, evidence file, and submitted disclosure must be retained for inspection by MOCCAE for a minimum of five years from the end of the reporting period. This applies equally to manual records and platform-generated audit trails.
What is the difference between the Federal Climate Law and other UAE ESG frameworks?
Federal Decree-Law 11/2024 is the primary climate obligation for every UAE entity. It sits underneath a stack of additional frameworks that apply to subsets of entities: SCA Decision 3/RM/2020 (listed PJSCs), ADX June 2025 Disclosure Guidance (Abu Dhabi-listed entities), DFM 2025 ESG Reporting Guide (Dubai-listed entities), ADGM ESG Disclosure rules (free-zone entities above thresholds), DFSA Markets Brief MB 27 (DIFC-regulated firms), IFRS S2 (overlay expected by ADX), and GRI Universal Standards (overlay expected by DFM). The Federal Climate Law is the floor; the others are sector-specific ceilings.
Primary sources
- Federal Decree-Law 11 of 2024 — full text, UAE Legislation Portal
- Cabinet Resolution 67 of 2024 — implementing regulation
- Ministry of Climate Change and Environment (MOCCAE) — moccae.gov.ae
- National MRV system — mrv.ae
- SCA Decision 3/RM/2020 Article 76 — sca.gov.ae
- Abu Dhabi Securities Exchange (ADX) — ESG Disclosure Guidance, June 2025
- Dubai Financial Market (DFM) — ESG Reporting Guide, 2025
- ISO 14064-1:2018 and ISO 14064-3:2019 — International Organization for Standardization
- GHG Protocol Corporate Standard — World Resources Institute and World Business Council for Sustainable Development
This article reflects the law as in force on 31 May 2026. Subsequent updates to Cabinet resolutions or MOCCAE workbook formats may change specific filing details. SuperESG users receive automatic updates to the factor library and workbook generator when MOCCAE publishes revisions. See how SuperESG works.