UAE Federal Decree-Law No. 11 of 2024: What Every Business Needs to Know Before the Compliance Deadline
The UAE has enacted the most significant climate legislation in its history. Does your business know what it must do — and by when?
On 28 August 2024, the UAE President issued Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects. The law entered into force nine months later, on 30 May 2025. With the full compliance deadline now set for 30 May 2026, businesses across the UAE have a narrow window to get their houses in order.
This is not a voluntary framework, an ESG aspiration, or a reporting exercise confined to large multinationals. It is a legally binding federal law — the first of its kind in the MENA region — that applies to public and private entities across the UAE mainland and free zones. Non-compliance carries financial penalties of up to AED 2,000,000, doubling for repeat violations.
In this post, we break down exactly what the law says, who it applies to, what obligations it creates, and what practical steps your business should be taking right now.
What Is Federal Decree-Law No. 11 of 2024?
Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects is the UAE’s primary legal instrument for managing greenhouse gas (GHG) emissions and building national resilience to climate change. It was issued under the authority of the President of the United Arab Emirates and approved by the Cabinet.
The law sits at the heart of the UAE’s climate ambition — specifically its commitment to achieving Net Zero by 2050 and its Nationally Determined Contributions (NDCs) under the Paris Agreement. Hosting COP28 in 2023 placed the UAE under significant international scrutiny, and this legislation represents a concrete step towards translating those commitments into enforceable domestic obligations.
| Key Facts at a Glance 📅 Issued: 28 August 2024 ⚡ Entered into force: 30 May 2025 ⏰ Full compliance deadline: 30 May 2026 🏛️ Regulator: Ministry of Climate Change and Environment (MOCCAE) 🌍 Scope: All UAE entities — mainland and free zones ⚖️ Maximum penalty: AED 2,000,000 (doubled for repeat violations) |
Who Does It Apply To?
Article 3 of the law is unambiguous: the provisions apply to “sources” across the UAE, including free zones. A “source” is defined broadly as any public or private legal person, as well as individual enterprises, whose operations or activities result in the release of greenhouse gases into the atmosphere.
In practice, this means the law has wide reach. If your business operations generate GHG emissions — whether through energy consumption, manufacturing processes, transport fleets, refrigerants, or any other activity — you are likely a source and are subject to the law.
The specific sources required to measure, report and verify their emissions are determined by MOCCAE and the competent authority (the relevant local authority or free zone regulator in each emirate). If you have not yet been notified by your regulator, that does not mean the law does not apply to you — it means you should be taking proactive steps to assess your position now.
The Six Core Obligations Under the Law
The law creates a set of interconnected obligations for businesses. We have grouped them into six areas:
1. Measure Your Emissions (Article 6)
Sources must measure the GHG emissions generated by their activities on a regular basis. The law covers the main greenhouse gases defined in the IPCC framework: carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), nitrogen trifluoride (NF₃), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulphur hexafluoride (SF₆).
You must prepare an emissions inventory — a structured database of the emissions you produce, the measures you are taking to reduce them, and the expected results. Records of measured emission quantities must be maintained for a minimum of five years from the date of each analysis, and must be accessible to authorised MOCCAE officials.
2. Report to MOCCAE (Article 6)
Beyond measurement, sources must submit periodic reports to MOCCAE and the competent authority. These reports cover:
- Data on activities related to emissions
- Current emission reduction measures being implemented
- Planned future reduction measures
- The expected results of those reductions
MOCCAE is in the process of establishing an electronic MRV (Measurement, Reporting and Verification) platform through which this data will be submitted. The Ministry collects and analyses emission data and reduction measures on an annual basis.
3. Reduce Your Emissions (Articles 4 and 5)
Sources are required to contribute to reducing their emissions in order to achieve climate neutrality. The law sets out eight approved means of achieving this:
- Improving energy efficiency
- Using clean energy
- Enhancing and protecting natural carbon sinks
- Carbon capture, use, and storage (CCUS)
- Using alternatives to saturated fluorocarbons
- Carbon offsetting — including investment in renewable energy, energy efficiency, afforestation, and other qualifying projects
- Implementing integrated waste management
- Any other technologies or means as determined by MOCCAE or the competent authority
The Cabinet, on a proposal from MOCCAE, will set annual sector-by-sector emission reduction targets aligned with the national pathway to climate neutrality. These targets will be reviewed and updated periodically.
4. Develop a Climate Adaptation Plan (Article 7)
Beyond mitigation, the law requires the development and implementation of climate adaptation plans. These plans must cover:
- An assessment of the main climate-related risks in your sector
- Measures of response to those risks and early warning systems
- Implementation of the plan and adaptation measures
Competent authorities and entities are required to report data on economic and non-economic losses and damages resulting from climate change impacts to MOCCAE, which feeds into international reporting obligations under the UNFCCC.
5. Verify Your Data (Article 6)
MOCCAE and the competent authority have the power to verify the accuracy of emissions data and assess the extent to which sources are complying with their reporting obligations. While the law does not explicitly mandate private third-party auditors for all sources, best practice and evolving regulatory guidance strongly suggests that independent verification of your emissions inventory will be an expectation — particularly for larger emitters.
6. Establish Governance (Articles 9 and 12)
The law provides for the Cabinet to establish Climate Action Boards or Committees comprising representatives from federal and local government and the private sector. For businesses, this signals the importance of establishing internal governance structures around climate compliance — ensuring Board-level accountability, cross-functional teams, and clear policies.
The Penalties: Why This Cannot Be Ignored
Article 15 sets out the financial consequences of non-compliance. Any source that violates the core obligations under Article 6 — which covers measurement, reporting, data submission and record-keeping — will face:
| Penalties for Non-Compliance First offence: AED 50,000 minimum — AED 2,000,000 maximum Repeat violation: AED 100,000 minimum — AED 4,000,000 maximum (Doubled if the same violation is repeated within two years of a final judgment) Administrative penalties, inspections, corrective orders, and operational consequences may also apply (Article 17). |
Beyond the direct financial exposure, non-compliance carries significant reputational risks. As ESG disclosure expectations tighten across global capital markets, supply chains, and procurement frameworks, a business that cannot demonstrate climate compliance in the UAE will find itself at a disadvantage when seeking finance, investors, or enterprise clients.
What Should Your Business Be Doing Right Now?
With the compliance deadline of 30 May 2026 approaching, the time to act is now. Here is a practical framework for where to start:
- Determine whether and how the law applies to you. Review your operations and identify all potential GHG emission sources. Assess which regulatory body (MOCCAE, emirate-level authority, or free zone regulator) has jurisdiction over your activities.
- Conduct a baseline GHG assessment. If you do not have an emissions inventory, you need one. This is the foundation of everything — you cannot report or reduce what you have not measured. A baseline assessment should cover Scope 1 (direct) and Scope 2 (indirect energy) emissions as a minimum.
- Map the data gaps. Most businesses find that their current data collection infrastructure is not fit for purpose for regulatory-grade emissions reporting. Identify what data you have, what you need, and how you will collect it.
- Assign internal ownership. Compliance with Federal Decree-Law No. 11 is not purely an ESG or sustainability function matter — it touches legal, finance, operations, procurement, and board governance. Assign a cross-functional lead and ensure Board-level visibility.
- Begin developing your reduction strategy. Even if you are still in the measurement phase, start thinking about your pathway to reduction. What operational changes can reduce your emissions? Are there offsetting opportunities relevant to your sector?
- Monitor MOCCAE guidance. The implementing resolutions, MRV platform specifications, and sector-specific targets under this law are still being issued. Stay close to MOCCAE announcements and the guidance from your relevant competent authority.
How Endurisk Advisory Can Help
At Endurisk Advisory, we are a specialist risk and sustainability consultancy with deep expertise in ESG, GHG accounting, compliance governance, and climate risk. We work with businesses across the UAE — from SMEs to larger corporates — to build practical, proportionate responses to regulatory requirements.
Our services relevant to Federal Decree-Law No. 11 compliance include:
- Baseline GHG Assessment: We map your Scope 1 and Scope 2 emission sources, build your emissions inventory, and identify data and systems gaps.
- Carbon Accounting and MRV System Setup: We use AI-enabled tools to support accurate data collection, calculation, and reporting — including alignment with MOCCAE’s MRV platform requirements.
- Emissions Reporting: We prepare and support submission of verified emissions reports aligned with MOCCAE requirements and international standards including GRI, IFRS S1/S2, and TCFD.
- Compliance Governance Frameworks: We help you establish Board-level accountability, internal policies, cross-functional teams, and audit-ready documentation.
- Climate Risk and Adaptation Planning: We develop sector-specific climate adaptation plans and climate risk assessments aligned with Article 7 of the law.
- Fractional Chief Sustainability Officer (CSO) Services: For businesses that need end-to-end sustainability leadership without a full-time hire, our Fractional CSO service provides strategic direction, reporting oversight, and stakeholder engagement on a flexible basis.
We are currently offering a complimentary initial consultation to businesses assessing their readiness under Federal Decree-Law No. 11. To arrange a conversation, visit www.enduriskamc.com or contact us directly.
Looking Ahead
Federal Decree-Law No. 11 of 2024 is not the end of the UAE’s climate regulation journey — it is the beginning. The law creates the architecture for an evolving regime of emission targets, sector plans, and regulatory oversight that will intensify over time. Businesses that build their compliance capabilities now will be far better positioned as that regime matures.
