UAE Climate Law 2024: Transforming Net-Zero Commitments into Business Action

The UAE has taken another big step toward sustainability with its new climate laws, turning long-standing commitments into enforceable action.. As the first country in the MENA region to commit to Net Zero by 2050, the UAE has led with initiatives like the Green Agenda 2030, the Energy Strategy 2050, and the National Climate Change Plan—all aimed at driving clean energy, innovation, and cross-sector resilience. The launch of the Climate Change Research Network also helped boost data-driven and collaborative policymaking.

The UAE has taken another definitive step from climate commitment to climate enforcement with the introduction of two landmark legislative instruments:

• Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects, focused on reducing climate change impacts
• Cabinet Resolution No. (67) of 2024, which establishes the National Register for Carbon Credits (NRCC).

Together, these laws provide a comprehensive framework to reduce greenhouse gas (GHG) emissions, activate a national carbon market, and support the UAE’s public and private sectors with its Net Zero by 2050 Strategic Initiative.

The Federal Decree-Law No. (11) of 2024

Effective from 30^th May 2025, this is the UAE’s first dedicated climate change legislation. It applies across all Emirates and economic zones—including free zones—and covers all emission “sources”, including public and private entities, facilities, and enterprises whose activities release greenhouse gases. The Decree-Law takes a universal approach, applying to any operation that generates GHG emissions—regardless of size. However, the Ministry of Climate Change and Environment (MOCCAE) and other competent authorities are authorized to designate “significant emitters”, who will be required to undertake specific obligations, including: establishing and maintaining a verified emissions inventory, submitting periodic emissions reports, implementing mitigation measures such as energy efficiency, clean energy adoption, CCUS, offsetting, and natural sink preservation and retaining emissions records for at least five years. The Ministry will establish an electronic system to monitor emissions and verify compliance to this list.

A major emphasis is placed on independent third-party verification of reported data, to maintain transparency and alignment with global standards. Non-compliance may result in fines ranging from AED 50,000 to AED 2 million, with penalties escalating for repeat offenses. The Cabinet may issue further classifications, thresholds, or technical standards by implementing further regulations.

Cabinet Resolution No. (67) of 2024 – NRCC

The Cabinet Resolution No. (67) of 2024 resolution, effective since 28 December 2024, establishes the National Register for Carbon Credits (NRCC) and introduces a classification-based approach. It applies to both public and private sector entities and divides participants into two main categories:

1. Entities of Huge Carbon Emissions – Defined as those emitting 500,000 metric tons or more of CO₂-equivalent annually from Scope 1 and Scope 2 emissions only.
   These entities are mandated to register in the NRCC and comply with full MRV (Monitoring, Reporting, Verification) protocols.
2. Participating Entities – entities that reduce its emissions under (0.5) million metric tons of CO₂-equivalent annually within the scope one and scope two of GHG emissions. These entities voluntarily apply to be registered at the NRCC and get or trades in carbon credits.

If an entity is a huge emitter does not wish to trade carbon credits, they are still required to comply with the resolution’s MRV (Monitoring, Reporting, and Verification) obligations and to register in the NRCC. Registered entities must monitor emissions using IPCC-aligned methodologies, report annually to MOCCAE, and undergo independent third-party verification by accredited agencies. All validated carbon credits will be recorded in the NRCC to ensure transparency, prevent double-counting, and facilitate trading.

Carbon credits under this resolution are treated as financial instruments, allowing them to be traded on Securities and Commodities Authority (SCA)-licensed platforms. The final deadline to register and comply is 28 June 2025. Late compliance may result in fines of up to AED 1 million, as well as trading license suspension for misconduct or misreporting.

Implications for Businesses and industries

These laws present both responsibilities and strategic opportunities for the UAE’s business community. High-emitting companies must now integrate robust emissions measurement, verification, and mitigation strategies. While the Decree-Law takes a universal approach to regulation and applies to all entities, the NRCC resolution focuses on Scope 1 and 2 emissions for huge emitters making clear that businesses should prioritize operational emissions.

Together, these two laws send a clear message: the UAE is not only setting climate goals—it is establishing the regulatory and economic infrastructure to achieve them. For businesses, this means that climate action is not just a choice, but a requirement tied to law, reputation, and competitiveness.