Preparing for New UAE GHG Emissions Reporting and Reduction Requirements – A Primer for U.S.-based Multinationals

New UAE greenhouse gas emissions reporting and reduction requirements currently are scheduled to apply starting this year. Last year, a new large emitter reporting regime took effect in the UAE. These requirements parallel new obligations in other parts of the world that are impacting U.S.-based multinationals. In this joint Alert, Ropes & Gray and Al Tamimi & Company discuss these mandates.

In 2024, two instruments were issued in the United Arab Emirates:

• Federal Decree Law No. (11) of 2024 on the Reduction of Climate Change Effects (the Decree); and
• Cabinet Resolution No. 67 of 2024 Concerning the National Register for Carbon Credits (the Cabinet Resolution).

The Decree and the Cabinet Resolution are further discussed below.

Federal Decree on the Reduction of Climate Change Effects

The Decree states that covered entities are required to comply by May 30, 2026. However, representatives of the UAE Ministry of Climate Change and Environment (MOCCAE) have indicated that this deadline is expected to be extended, with a revised compliance date to be confirmed following MOCCAE’s pending issuance of a technical guidance document. As further discussed below, MOCCAE has not yet issued detailed guidance on several key compliance requirements, and the Decree contemplates the adoption of additional implementing resolutions to address these gaps.

Covered Entities

The Decree applies broadly to all emissions “sources” in the UAE, including in free zones. The Decree defines “sources” to include all public and private legal persons, as well as individual enterprises, whose operations or activities result in the release of GHGs into the atmosphere. MOCCAE or a designated authority in a UAE emirate is required to determine the sources that are required to report. The Decree itself does not include a compliance threshold, whether based on the size of the entity, the nature of its activities, or the emissions generated.

To date, Abu Dhabi is the only emirate that has issued a reporting system that sets reporting thresholds under the Decree. Under Abu Dhabi’s Measurement, Reporting and Verification (MRV) system, operators of facilities located within the Emirate of Abu Dhabi with annual Scope 1 emissions of 25,000 tons of CO2e or more for the prior calendar year and that operate in the following covered sectors are subject to annual reporting requirements:

• Industry: facilities engaged in the physical or chemical transformation of materials into products, including associated on-site combustion emissions (excluding service-oriented facilities);
• Power (electricity and water): Facilities engaged in the generation of electricity or the production and distribution of desalinated water and associated utilities;
• Oil and Gas: Facilities engaged in the exploration, extraction, processing, refining, storage, or transmission of crude oil, natural gas, and associated petroleum products; and
• Transport: Entities operating a road or rail fleet from a fixed base of operations within the Emirate of Abu Dhabi (excluding aviation and marine transport).

Operators of facilities located within Abu Dhabi that operate in the covered sectors but emit less than 25,000 tons of CO2e annually will be required to submit at least one year of emissions data to confirm their applicability status, after which they will not be required to report unless and until they meet the emissions threshold for a particular calendar year.

MOCCAE announced in October 2025 that it was launching a national MRV system but has not published further details, including with respect to the scope of entities required to report pursuant to the Decree. It is expected that, following the issuance of MOCCAE’s technical guidance document, reporting thresholds similar to those currently applicable in Abu Dhabi may be introduced at the national level.

Disclosure Requirements

Covered entities are required to measure GHG emissions from their operations and activities and report according to standards to be specified by MOCCAE or a designated authority in a UAE emirate.

Under the Decree, emissions inventory reports will be required to include information on the following:

• GHG emissions from activities and operations within the UAE;
• Activities related to emissions;
• Emissions reduction measures currently in place;
• Planned future emissions reduction measures; and
• The expected results of the reduction measures.

The Decree does not specify the emissions scopes that must be measured and reported (i.e., all of Scope 1, 2, and 3, or a subset), the emissions calculation methodology to be used, the reporting boundary (i.e., geographic-specific vs. entity-specific) or the reporting period (i.e., fiscal year or calendar year). Details on these items are expected to be provided in MOCCAE’s technical guidance document or in future MOCCAE implementing resolutions adopting the reporting forms to be used.

The Decree requires covered entities to submit “periodic” emissions inventory reports. The due date and frequency have not yet been set, although further clarity is expected following the issuance of MOCCAE’s forthcoming technical guidance document. The Decree requires MOCCAE to collect emissions data and emissions reduction measures on an annual basis, suggesting that emissions inventory reports will be required to be submitted annually, which would be consistent with the reporting cadence in other jurisdictions. Reports will be required to be submitted electronically through a mechanism to be established by MOCCAE or a designated authority in a UAE emirate.

Abu Dhabi MRV System

The Abu Dhabi MRV system requires annual reporting of facility-level Scope 1 emissions in accordance with a reporting template published by the Abu Dhabi Environment Agency. Among other things, the template requires disclosure of calendar year Scope 1 emissions data, emissions sources, and a description of the facility’s activities. Operators of multiple in-scope facilities are required to submit a separate report for each facility. Reports are required to be submitted through an electronic portal operated by the Abu Dhabi Environment Agency by March 31 of each year.

The Abu Dhabi MRV system will require independent third-party verification of emissions reports beginning in 2027 (for reporting year 2026). The verifier must meet the accreditation requirements of the International Organization for Standardization (ISO), including ISO 14065. The Environment Agency is expected to issue an annual list of ATCO-accredited verifiers beginning in 2027. The accredited verifier will be required to issue a verification report, which must be submitted to the Abu Dhabi Environment Agency together with the annual emissions report.

Emissions Reduction Initiatives

Covered entities also will need to take steps to reduce GHG emissions.

The Decree requires covered entities to contribute to reducing their emissions in order to achieve carbon neutrality, through one or more of the following means:

• Improving energy efficiency;
• Using clean energy;
• Enhancing and protecting natural carbon sinks;
• Carbon capture, use, and storage;
• Using alternatives to saturated fluorocarbons;
• Carbon offsetting;
• Implementing integrated waste management; or
• Any other technologies or means determined by MOCCAE or another competent authority.

The Decree does not specify a timeframe for implementing emissions reduction initiatives or mandate a specific reduction level or pathway.

MOCCAE may issue resolutions regarding controls, standards, and requirements relating to the foregoing emissions reduction approaches, but it is not required to do so under the Decree.

The Abu Dhabi MRV system reporting template requires in-scope facilities to report on GHG emissions mitigation measures, including actions the facility is taking, planning, or studying to reduce its emissions.

Penalties

Violations of emissions measurement, reporting, and recordkeeping requirements are punishable by a fine of between AED 50,000 and AED 2,000,000 (approximately US$13,600 to US$545,000 as of April 2026). Penalties may be doubled in the case of repeated violations within two years of a final judgment of conviction for the initial violation.

Additional administrative penalties for violations are expected to be set forth in a future Cabinet Resolution.

Under Abu Dhabi’s MRV system, the Abu Dhabi Environment Agency is permitted to issue written notices identifying any violations, the corrective actions required, and the timeframe within which such actions must be completed. In the case of continued noncompliance, repeated violations, or where corrective measures are not implemented within the period specified by the Environment Agency, the penalties set forth in the Decree (noted above) may be applied.

Cabinet Resolution Concerning the National Register for Carbon Credits

In contrast to the Decree, the Cabinet Resolution is tailored to apply specifically to large emitters operating in the UAE. Under the Cabinet Resolution, these entities had until June 28, 2025 to come into compliance.

Covered Entities

The Cabinet Resolution applies to public and private sector entities with combined annual Scope 1 and 2 GHG emissions within the UAE of at least 0.5 million metric tons of carbon dioxide equivalent (MT CO2e). An entity that exceeds this threshold but offsets all or part of its emissions to a level below the threshold is not exempt.

The Cabinet Resolution also applies to carbon credit trading platforms. The requirements for trading platforms are not discussed in this Alert.

Disclosure Requirements

Covered entities are required to annually report their Scope 1 and 2 GHG emissions, calculated in accordance with the Greenhouse Gas Protocol standards and pursuant to a national MRV system established by the UAE in October 2025.

Reports are required to be provided to MOCCAE using a form included as an Annex to the Cabinet Resolution.

The Cabinet Resolution does not provide a deadline by which annual emissions reports are required to be submitted.

Assurance

Emissions reported to MOCCAE are required to be audited by an independent third-party verification agency in accordance with the ISO 14065 standard (General principles and requirements for bodies validating and verifying environmental information). The verification agency must obtain authorization from MOCCAE and have ISO accreditation.

National Register for Carbon Credits

The Cabinet Resolution also established a National Register for Carbon Credits. Covered entities are required to register with the National Register.

Once registered, covered entities are required to follow specified procedures for buying, selling, trading, and disposing of carbon credits for the purposes of offsetting their GHG emissions.

Penalties

Violations of the Cabinet Resolution by covered entities may result in administrative fines as follows:

• First-time violations: up to AED 500,000 (approximately US$136,000 as of April 2026);
• Second-time violations: up to AED 1,000,000 (approximately US$272,000 as of April 2026); and
• Subsequent violations: up to AED 2,000,000 (approximately US$545,000 as of April 2026).