UAE Regulation · First in the Middle East

What Federal Decree-Law No. 11/2024 means for your business — and what to do now

Updated June 2026 · 8 min read

For most companies in the UAE, measuring carbon used to be optional — a sustainability gesture for those who cared. As of 2025, it is the law, and it almost certainly applies to you.

Federal Decree-Law No. 11 of 2024 — the UAE’s first binding climate regulation, and the first of its kind in the Middle East — turns greenhouse-gas measurement into a filing obligation for businesses across the country. If your operations produce emissions, the question is no longer whether you report, but how soon you’re ready to.

What the law actually is

Issued in August 2024 and in force since 30 May 2025, the law supports the UAE’s Net Zero 2050 strategy and its commitments under the Paris Agreement. It is overseen by the Ministry of Climate Change and Environment (MOCCAE), which requires covered entities to measure, report and plan to reduce their greenhouse-gas (GHG) emissions.

Reporting is done through MOCCAE’s National MRV (Measurement, Reporting & Verification) Transparency System and its Integrated Emissions Quantification Tool (IEQT), launched in October 2025, at mrv.ae. For now the focus is on Scope 1 (direct) and Scope 2 (purchased energy) emissions; Scope 3 (value chain) is expected to follow from 2027. All supporting records must be kept for at least five years.

Who is in scope — the part most businesses get wrong

This is where the costliest assumptions are made. The law applies to all public and private entities operating in the UAE that generate emissions. There is no minimum size, no revenue threshold, and no sector exemption. The test is activity, not scale.

Two myths cause most of the trouble:

• “We’re too small.” A trading company with two delivery vans and a leased office is a “Source” under the law in the same way a factory is. Unlike VAT or corporate tax, there is no revenue figure that decides whether you’re in.
• “We’re in a free zone.” Free-zone status does not exempt you. The obligation extends to companies in DIFC, ADGM, JAFZA, Shams and every other free zone across the Emirates.

If you use electricity, cooling, company vehicles or generators, your business produces emissions — and is in scope.

What you actually have to do

• Measure your Scope 1 sources (fuel, company vehicles, generators) and Scope 2 sources (purchased electricity and district cooling).
• Prepare a GHG inventory using approved methodologies.
• Submit periodic reports through the MRV / IEQT portal at mrv.ae.
• Keep all data, calculations and reports for at least five years.
• Submit a reduction plan with concrete measures and timelines — not vague intentions.

A separate track under Cabinet Decision No. 67 of 2024 applies to the largest emitters — entities producing 500,000 tonnes of CO₂e or more per year — which must register with the National Register for Carbon Credits. Most SMEs are well below this threshold, but it’s worth knowing where the line sits.

The penalties

The fines are administrative and real. Failures in measuring, reporting or record-keeping carry penalties from AED 50,000 to AED 2,000,000 per violation, doubling to as much as AED 4,000,000 for a repeat violation within two years. Beyond fines, the law allows operational restrictions, licence suspension and orders to carry out corrective work.

The deadline — and the trap to avoid

The law gave designated Sources one year from entry into force — until 30 May 2026 — to bring their status into line. As of 2026, MOCCAE has signalled that this deadline may be extended while technical guidance is finalised, and no revised date has been confirmed.

Here is the trap: treating a possible extension as a reason to wait. The law is already in force. The sensible reading is to build toward the original date and treat any extension as breathing room, not a pause. A company that waits for total certainty will be left without enough time to act — and “we were waiting for the deadline to move” is not a defence that survives an audit.

What to do now

1. Confirm you’re in scope. If your UAE operations produce emissions, you almost certainly are.
2. Get a rough number. Estimate your Scope 1 & 2 emissions in a couple of minutes to see where you stand.
3. Gather your data. Fuel, electricity, district cooling, vehicles and generators — twelve months of figures.
4. Build an IEQT-ready inventory using recognised methodologies.
5. Register on mrv.ae and set up record-keeping for the five-year requirement.
6. Draft a simple reduction plan with concrete, time-bound measures.

This article is general information, not legal advice. Always verify specific requirements against the official sources at mrv.ae.