Does Federal Decree-Law No. 11 apply to Dubai free-zone companies?

Yes. Article 3 states that the decree applies to sources in the UAE, including free zones. The detailed Article 6 reporting obligation still depends on designation by MOCCAE and the relevant competent authority.

Is every Dubai SME required to submit an emissions report?

The decree has broad scope, but Article 6 applies the detailed measurement, reporting and verification duties to sources determined by MOCCAE and the competent authority. SMEs should confirm their designation, sector rules and submission instructions.

What was the compliance deadline?

The decree became effective on 30 May 2025. Article 18 provided one year to adjust status, resulting in a 30 May 2026 statutory milestone unless extended by Cabinet resolution.

What is the maximum fine?

Article 15 provides for fines up to AED 2 million for violations of Article 6(1). The minimum is AED 50,000. The penalty can be doubled for the same violation repeated within two years of a final judgment of conviction.

How long must emissions records be kept?

Five years from the date of each emissions analysis. Authorised judicial officers must be able to inspect those records during the retention period.

Does the 500,000-tonne threshold exempt SMEs?

No. That threshold determines high-emitting entities under the National Register for Carbon Credits framework established by Cabinet Resolution No. 67 of 2024. It is not a general exemption from the federal decree.

Is Scope 3 reporting mandatory?

Article 6 does not expressly divide reporting into Scope 1, Scope 2 and Scope 3. The applicable scope should be confirmed from MOCCAE, DECCA or sector-specific instructions. SMEs should at least prepare reliable Scope 1 and Scope 2 data and screen material Scope 3 sources.

Who is the competent climate authority in Dubai?

Dubai Law No. 11 of 2024 identifies DECCA as the official Dubai entity responsible for climate change and environmental plans, policies and strategies, including in special development zones and free zones.

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30 May
2025

Decree took legal effect

30 May
2026

Statutory adjustment milestone under Article 18

AED 50k
– 2M

Fine range for Article 6(1) breaches

5 years

Emissions records retention period

Compliance timeline

Where the law stands today

The adjustment window has closed. If your business has been designated for Article 6 reporting, compliance is an immediate obligation rather than a future project.

2024

Federal Decree-Law No. 11 of 2024 issued. Dubai Law No. 11 establishes DECCA.

Enacted

30 May 2025

Decree becomes effective. Article 18 opens a one-year adjustment period.

In force

30 May 2026

Statutory milestone to adjust status, unless extended by Cabinet resolution.

Passed

Today

Designated sources should hold an evidence-backed inventory, reduction plan and five-year records.

Act now

Interactive · Emissions scope explorer

Where your emissions actually sit

Choose the profile closest to your business. These are indicative starting proportions to help you prioritise data collection — not a substitute for measuring your own activity data.

Scope 1Owned vehicles, generators, refrigerants

10%

Scope 2Purchased electricity and district cooling

55%

Scope 3Travel, deliveries, purchased goods, waste

35%

Interactive · Statutory penalty range

What Article 15 and 16 actually expose you to

Article 15 sets a fine of AED 50,000 to AED 2 million for breaches of Article 6(1). Article 16 doubles the penalty where the same violation recurs within two years of a final conviction. This illustrates the statutory range only — it is not a prediction of any enforcement outcome.

Assumed position in the statutory range

Minimum — AED 50,000Maximum — AED 2M

Same violation repeated within two years of a final judgment

Indicative statutory exposure

AED 440,000

Within the Article 15 range for a first violation of Article 6(1).

About the authors

Aurlume Strategy

Aurlume Consultants is an execution-first management consultancy for SMEs in Dubai and across the GCC. Our strategy practice exists because most SME plans fail on execution, not ambition. We identify the single constraint limiting growth, translate it into 90-day sprints with owners and measures, and stay close enough to course-correct when reality intervenes.

We work on fixed scopes, and we measure ourselves on what changed in the business.

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Average revenue lift across engagements

2 days

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A short strategy review separates the symptoms from the bottleneck and gives you a sequenced 90-day plan against it.

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This article provides general information based on our work with SMEs in the UAE and GCC. Every business context differs, and nothing here should be treated as a recommendation for your specific circumstances.