How to comply with GHG reporting under the UAE Climate Law

Short answer

• The law reaches almost every business. If your UAE operations generate emissions you are in scope, with no size or revenue threshold and no free zone exemption.
• Voluntary ESG reports do not count. Compliance means registering on the national MRV platform and filing measured, verifiable emissions data, not a GRI or TCFD report.
• The deadline is moving but not gone. Full compliance is set for 30 May 2026, though the regulator has signalled a likely extension. Plan for the original date.
• Penalties are administrative and real. Reporting and record-keeping failures carry fines up to AED 2 million, doubling for repeat violations, plus possible licence action.

A Dubai logistics company with a fleet of trucks, two warehouses and a free zone licence has never measured a tonne of carbon in its life. Its finance director has heard that a climate law now applies, has also heard that the deadline might slip, and has decided to wait. That decision is the mistake the UAE Climate Law is built to catch. The law does not ask whether a company cares about emissions. It asks whether the company generates them, and a truck fleet answers that question on its own.

Federal Decree-Law No. 11 of 2024 turned greenhouse gas measurement into a filing obligation for businesses across the UAE. The reporting itself is not the hard part. The hard part is that compliance runs on a specific national platform, in a specific format, verified in a specific way, and a company that has never built an emissions inventory cannot produce one in the final fortnight. Regulatory compliance lawyers in the UAE are fielding the same question from companies of every size: what counts as compliance, and what counts as a violation.

Who counts as a Source under the UAE Climate Law

The UAE Climate Law, Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects, uses the term Source for any entity whose activities generate greenhouse gas emissions. That definition is wide on purpose. It covers public and private companies, individual enterprises, and entities operating anywhere in the UAE, free zones included. There is no minimum threshold for company size, turnover, or emissions volume. The test is activity, not scale.

This is the point most businesses get wrong. The law does not work like VAT or corporate tax, where a revenue figure decides whether you are in. A small trading company with a few delivery vans and a leased office is a Source in the same way an industrial plant is. The obligations are heavier for emissions-intensive sectors such as energy, oil and gas, manufacturing, construction, transport and real estate, but no sector and no size sits outside the law.

For many companies this is the moment a voluntary idea became a legal duty. The shift from optional sustainability reporting to enforceable obligation is the subject of our guide on why ESG is now enforceable in the UAE. The practical consequence is that every UAE entity should run an applicability check now and assume it is in scope until the facts show otherwise.

Why an ESG report does not make you Climate Law compliant

A company that already files an annual sustainability report for the Abu Dhabi or Dubai exchanges often assumes that work covers the Climate Law. It does not. Exchange ESG disclosure and Climate Law GHG reporting are two separate obligations, with different audiences, different formats, and different filing channels.

Exchange-level ESG reporting is a disclosure framework aimed at investors in listed companies. The Climate Law is a nationwide measurement obligation that applies whether or not a company is listed, and a report prepared to GRI, TCFD or CDP standards is not automatically a valid Climate Law submission. The law requires registration on the national reporting platform, a structured emissions inventory, a formal reduction plan, and records held in a form a regulator can inspect. A polished ESG narrative does not satisfy any of those four things on its own.

Companies that do report to an exchange still have a head start, because the underlying emissions data overlaps. The mistake is treating the two as one filing. For the exchange side of the picture, our guide to ESG reporting requirements for UAE businesses sets out the ADX, DFM and ADGM frameworks. The Climate Law sits alongside them as a compliance track of its own.

Measuring Scope 1 and Scope 2 emissions

The core of compliance is an emissions inventory. The current focus is Scope 1 and Scope 2. Scope 1 covers direct emissions from sources the company owns or controls, including vehicle fleets, on-site fuel combustion, industrial processes and refrigerant losses. Scope 2 covers indirect emissions from purchased energy, mainly electricity and district cooling. Scope 3, the wider value chain, is expected to become mandatory from 2027, but that is not yet fixed in law.

The numbers have to be built on an approved methodology. MOCCAE recognises the GHG Protocol and ISO 14064, and a company with an existing programme on either standard is already part of the way there. A company starting from nothing needs roughly twelve months of operational data, utility bills, fuel records and process logs, to construct a credible baseline. Inventories must be built at facility level rather than estimated across a group, because the reporting system expects entity-specific figures.

This is the work that cannot be rushed. Collecting a year of clean activity data, choosing emission factors, and reconciling sources across multiple sites takes months, not days. A company that has not started should treat the inventory as the first task, ahead of any platform registration.

Reporting through the national MRV platform

Measurement only becomes compliance once it is filed correctly. The Climate Law operates through a national Measurement, Reporting and Verification system, and in October 2025 MOCCAE launched its central digital platform, the Integrated Emissions Quantification Tool, to run it. This platform is the mandatory channel for submission. Emissions calculated in a spreadsheet and kept internally do not meet the obligation.

Registration is a process in its own right. An in-scope entity creates an account on the national MRV platform, supplies its licence and entity details, assigns the people responsible for providing and validating data, and is approved through its emirate-level focal point before it can submit. Reporting then runs on an annual cycle, with the platform moving each entity through data collection, calculation, validation and submission. Advisers tracking the rollout, including PwC, have noted that parts of the framework are still settling as the platform beds in. Companies with operations in Abu Dhabi should also account for the Environment Agency Abu Dhabi transparency system, which runs in parallel and links to the national platform.

The practical risk is leaving registration until the deadline. Setting up an account, learning the submission format and resolving access roles all take time, and a company that registers late discovers the platform problems with no margin to fix them.

Verification and the records you must keep

A submitted figure is not the end of the obligation. The Climate Law is built on verification, which means the data a company files is open to independent checking. Higher emitters are expected to obtain third-party verification from a MOCCAE-approved verifier, accredited to the relevant ISO standard, and the assurance requirement is being phased in, with a longer runway for smaller companies before full third-party verification applies to them.

Record-keeping carries its own rule. Every entity must retain the data, calculations and reports behind its emissions figures for at least five years, in a form that MOCCAE can access on request. This matters because the inventory a company files is only as defensible as the evidence under it. A figure with no traceable source, no documented emission factor and no retained working is a figure a regulator can challenge, and the company then has to prove a number it can no longer reconstruct.

The lesson is to treat the inventory as an audit file from the start. The same discipline a finance team applies to tax records, source documents kept, methods documented, working papers retained, is the discipline the Climate Law expects for emissions data.

Reduction plans and the carbon credit registry for large emitters

Reporting emissions is only half of what the law asks. Each Source must also submit a reduction plan, setting out the measures it is taking and planning to cut its emissions. The law does not hand every company a fixed target, but it does require demonstrated, active effort, and MOCCAE sets annual reduction targets at sector level. A plan made of vague intentions will not satisfy this. The expectation is concrete measures with timelines, drawn from recognised routes such as energy efficiency, clean energy, carbon capture, low-emission alternatives to fluorinated gases, carbon offsetting, and integrated waste management. Where reduction work overlaps with cleaner power, our guide to the UAE energy transition covers the legal side of renewable and clean-tech projects.

A separate track applies to the largest emitters. Under Cabinet Decision No. 67 of 2024, entities emitting 0.5 million tonnes of CO2 equivalent or more a year, across Scope 1 and Scope 2, are treated as huge carbon emission entities and had to register with the National Register for Carbon Credits by 28 June 2025. These entities face stricter inventory and assurance requirements, and the registry also supports the issuance and trading of carbon credits, with trading platforms developing under the oversight of the Securities and Commodities Authority.

Most small and medium companies sit well below the half-million-tonne threshold and fall outside the large-emitter track. They should still watch their emissions profile as operations grow, and they cannot use the threshold to avoid the general reporting and reduction duties, which carry no threshold at all.

Deadlines and penalties under the UAE Climate Law

The Climate Law came into force on 30 May 2025 and gave designated Sources one year, until 30 May 2026, to bring their status into line with it. As of early 2026, MOCCAE has signalled that this deadline is likely to be extended while a technical guidance document is finalised, and no revised date has been confirmed. The sensible reading is to build toward 30 May 2026 and treat any extension as breathing room rather than a reason to pause. The implementing detail is still settling, and a company that waits for total certainty will be left without enough time to act.

The penalties give the deadline its weight. Failures in measuring, reporting or keeping records of emissions carry administrative fines ranging from AED 50,000 to AED 2,000,000, and a repeat violation within two years can see the penalty doubled. Beyond fines, the law allows administrative measures, including restrictions on operations, suspension of licences, and orders to carry out corrective environmental work. Further detail on the penalty structure is expected in a Cabinet Resolution. International firms tracking the regime, including Ropes and Gray, have noted both the likely extension and the enforcement exposure that sits behind it.

The point that should reach the boardroom is simple. The fine is recoverable. The lost time is not. A company that starts its inventory late cannot buy back the months it needs to collect clean data.

How should UAE businesses approach Climate Law compliance before the deadline?

GHG reporting under the UAE Climate Law is a defined compliance exercise, not a sustainability gesture. An in-scope business has to confirm it is a Source, build a Scope 1 and Scope 2 inventory on an approved methodology, register on the national MRV platform, file in the required format, arrange verification where it applies, keep five years of records, and submit a credible reduction plan. Each step depends on the one before it, which is why the work cannot be compressed into the final weeks.

The most time-sensitive issue is the inventory. Whatever happens to the 30 May 2026 date, a company that has never measured its emissions needs roughly a year of operational data to produce a defensible baseline, and that clock does not move when the deadline does. Registration, verification and the reduction plan all sit downstream of the inventory and cannot start until it exists. The possible extension changes the calendar, not the workload.

A UAE business that has not begun should treat applicability and baseline measurement as immediate tasks, and should not assume that an existing ESG report covers the obligation. For companies assessing their exposure, building an MRV process, or preparing a reduction plan that will stand up to verification, our corporate and regulatory team advises on Climate Law compliance across sectors and free zones.