Mandatory Climate Legislation

Every business operating in the UAE must now measure, report, and reduce greenhouse gas emissions.

Federal Decree-Law No. (11) of 2024, the UAE's first binding climate legislation, entered into force on May 30, 2025. Full MRV compliance is required by May 30, 2026.

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AED 2M

Maximum Fine

May 30

2026 Deadline

100%

Businesses impacted

10+ Days

Path to compliance

Understanding the Law

Until now, sustainability in the UAE has been a reputational consideration for most businesses — a choice, not an obligation. Federal Decree-Law No. (11) of 2024 changes this fundamentally. Enacted on May 30, 2025, it establishes a binding national framework for measuring, reporting, and reducing greenhouse gas emissions across all economic sectors.

The law draws its authority from the UAE's commitment to climate neutrality by 2050 and its obligations under the Paris Agreement. It creates a national Measurement, Reporting, and Verification (MRV) system and empowers the Ministry of Climate Change and Environment (MOCCAE) to enforce compliance with a comprehensive penalty regime.

Critically, there are no carve-outs for small businesses, startups, or free zone entities. If your organisation consumes energy, operates vehicles, or runs any process that produces emissions (direct or indirect) you are subject to the law.

The law applies to all sources of greenhouse gas emissions in the UAE, whether public or private, in free zones or otherwise, without exception as to size or sector.
— Federal Decree-Law No. (11) of 2024, Article 3

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Key facts at a glance

First binding climate law in UAE history: Previous sustainability frameworks were voluntary. This legislation creates legally enforceable emissions obligations with criminal penalties for non-compliance.

Scope 1 and Scope 2 emissions both count: The law requires reporting of both direct emissions from your own operations (Scope 1) and indirect emissions from purchased electricity and heat (Scope 2).

One year to comply: The law entered into force on May 30, 2025, giving businesses exactly twelve months. Establishing a credible MRV system from scratch typically requires six to nine months of structured work.

Judicial inspection rights: Ministry-designated judicial officers are authorised to inspect premises, request records, and audit emissions data at any time without prior notice.

Compliance creates commercial opportunity: Entities exceeding reduction targets can register carbon credits with the National Carbon Credit Registry and trade them in the UAE's emerging carbon market.

What Counts as a Reportable Emission?

Scope 1

Mandatory

Direct Emissions

Emissions from sources your business directly owns or controls.

  • Fuel combustion in boilers and furnaces
  • Company-owned vehicles (petrol, diesel, gas)
  • On-site fossil fuel generators
  • Industrial process emissions
  • Fugitive emissions (refrigerants, gas leaks)

Scope 2

Mandatory

Purchased Energy

Indirect emissions from energy your business buys and uses.

  • Electricity from DEWA, ADDC, or SEWA
  • Purchased district cooling (EMPOWER)
  • Steam or heat from third parties
  • Electricity for leased premises
  • Grid-supplied EV charging

Scope 3

Future Watch

Value Chain

Indirect emissions from your supply chain. Not yet mandated but expanding.

  • Supplier manufacturing processes
  • Business travel and commuting
  • Third-party logistics and distribution
  • End-of-life product treatment
  • Downstream use of sold products

Note: Federal Decree-Law No. (11) currently mandates Scope 1 and Scope 2 reporting. Businesses should nonetheless begin cataloguing Scope 3 data now, as MOCCAE has indicated the framework will expand. Scope 3 visibility will be essential for future compliance cycles and green financing assessments.

Six Binding Legal Obligations
Who Must Comply - Accountability Compass

Who Must Comply

The law covers all 'sources' defined broadly as any entity, individual enterprise, or organisation involved in activities that produce greenhouse gas emissions. There are no exemptions based on company size, revenue, headcount, or legal structure.

SMEs & Startups
Family Business
Industrial
Hospitality & Retail
Finance
Tech & Media
Real Estate
Public Service

Absolute Inclusion

Free zone status provides no immunity. Entities registered in DIFC, JAFZA, DMCC, and all other UAE free zones are expressly covered by the law.

Our Services - Aurlume Blueprint

Our Services

Most compliance providers offer generic sustainability consulting not designed with Decree-Law No. (11) in mind. Aurlume is built specifically around the UAE's regulatory framework, MOCCAE's reporting standards, and the practical realities of SME operations in Dubai.

Our work is technical and operational, not just advisory. We build the systems, gather the data, prepare the reports, and coordinate the verification process — leaving your internal team free to run the business.

01
Phase 01 — Initial Engagement

Compliance Gap Analysis

A structured assessment mapping your operations against Federal Decree-Law No. (11) requirements.

  • Identification of Scope 1 & 2 sources
  • Existing data availability & quality audit
  • Gap assessment against MOCCAE MRV
  • Compliance roadmap with phased milestones
  • Regulatory risk and penalty quantification
02
Phase 02 — Technical Build

GHG Inventory & MRV System

Technical implementation of a complete MRV system aligned with ISO 14064 and the GHG Protocol.

  • Full Scope 1 & 2 emissions inventory
  • ISO 14064 & Protocol documentation
  • Emissions factor selection methodology
  • Data collection workflows & staff guidance
  • Five-year records management infrastructure
03
Phase 03 — Strategic Roadmap

Reduction & Adaptation

A costed decarbonisation roadmap prioritising initiatives with genuine financial returns.

  • Energy efficiency audit & prioritisation
  • Clean energy transition feasibility
  • Verified carbon offset sourcing strategy
  • Cost-benefit analysis for major initiatives
  • Article 9 climate adaptation plan
04
Phase 04 — Submission

Verification & Reporting

End-to-end management of third-party verification and formal submission to MOCCAE.

  • Verification-ready report preparation
  • Accredited verifier selection & coordination
  • Regulatory submission to authorities
  • National Carbon Registry registration
  • Annual maintenance & repeat support
Testimonials - Aurlume Voices
Client Perspectives

Compliance isn't just a law.
It's peace of mind.

Client 1
Ahmed M. Ops Director
Client 2
Sarah H. Compliance Manager
Client 3
Marcus V. Hotel MD
Client 4
Lina K. Risk Partner

"Honestly, we weren't just looking for another report; we needed to know if we were actually breaking any rules. The Aurlume team sat down with us, went through our fuel receipts, and found exactly where our exposure was. They made the mandatory requirements feel completely manageable."

"The technical depth was what really made the difference for us. Most consultants just hand over a PDF of suggestions and leave you to it. Aurlume actually built the tracking spreadsheets and trained our guys on how to use them. It’s been six months and the system is still running perfectly."

"I was worried that the new Climate Law would be a huge drain on our resources. Instead, they showed us that being resilient actually makes us more efficient. We've already seen a 12% drop in our utility costs just by following the roadmap they laid out."

"Verification used to be such a headache for our department. With Aurlume coordinating everything, the accredited verifiers were finished in three days. They knew exactly what the auditors needed to see before they even stepped through the door."

Contact Aurlume for a confidential, no-obligation conversation about your compliance situation. We will tell you precisely what is required, how long it will take, and what it involves — and we will be straightforward about whether we are the right fit for your needs.

48-HOUR RESPONSE

Every inquiry is triaged and responded to within two business days.

STANDARD NDA

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