The United Arab Emirates, as a signatory to the Paris Agreement and host of COP28, has positioned itself as a regional leader in advancing climate action and supporting global efforts to limit warming to 1.5°C.

In this context, and in response to the increasing frequency and severity of climate-related events across the region, the UAE enacted Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects. The Climate Change Law establishes a national framework to manage greenhouse gas emissions, strengthen climate governance, and enhance resilience to both acute and chronic climate risks.

In recent years, the UAE has experienced increasing exposure to climate hazards — including extreme rainfall and flooding in 2024, prolonged periods of extreme heat and high humidity, deteriorating air quality, sea-level rise risks to coastal infrastructure, and water scarcity driven by reliance on desalination. These risks highlight the need to address the underlying drivers of climate change, particularly greenhouse gas emissions, alongside strengthening national resilience.

In alignment with the UAE Climate Change Adaptation Programme and the National Climate Change Plan 2050, the law establishes a formalised framework for emissions management. It introduces mechanisms to reduce emissions through target-setting aligned with national strategies and international commitments, the development of a national emissions inventory, and the implementation of mitigation measures including carbon offsetting.

The law also establishes a compliance framework under which the Ministry of Climate Change and Environment, in coordination with the relevant local authorities, will identify entities subject to strict reporting and emissions management requirements — primarily large emitters — with penalties applicable for non-compliance.

What Is the Law, Who Does It Apply To, and Which Sectors Are Most at Risk?

What is the law and when does it apply?

The UAE Climate Change Law — Federal Decree-Law No. 11 of 2024 — was enacted on 28 August 2024 and came into force on 30 May 2025, with full implementation scheduled for 30 May 2026. It represents a significant shift in sustainability governance in the UAE.

Who does the law apply to?

The scope of the law covers all entities — private and public, large and small, including those operating in free zones — across all seven emirates. If your organisation operates in the UAE, this law applies to you.

Which sectors are most at risk?

The UAE Climate Risk Assessment identified several sectors as particularly exposed to climate risk, among them hospitality and tourism, manufacturing, retail, construction, and finance. These sectors are also significant contributors to greenhouse gas emissions, reinforcing the need for targeted mitigation and adaptation measures. The rapid growth of AI and digital infrastructure is also increasing emissions from data centres and technology firms across the region.

Objectives of the law

• National strategy alignment: Enhancing the UAE’s global competitiveness and economic diversification.
• Climate change adaptation: Building resilience across the UAE’s ecosystems, economic sectors, and society to respond effectively to the impacts of climate change.
• Greenhouse gas emissions management: Ensuring alignment with international climate change mitigation efforts.
• Climate change research & innovation: Accelerating the development of scalable mitigation and adaptation solutions.
• Climate data consolidation: Enhancing data-driven decision-making on climate impacts at the national level.

What the Government Is Building — and What It Means for You

Beyond your immediate obligations, the government is implementing national-level mechanisms that will generate new requirements and market conditions for your organisation over the coming years. Planning ahead now is essential to avoid being caught off guard.

• Incentives & carbon offsetting mechanisms: Policy mechanisms will incentivise emissions reduction and low-carbon technology adoption, including carbon offsetting, emissions trading, and internal carbon pricing. A National Carbon Credit Registry will be established to track and manage carbon credits within the UAE, with standardised indicators assessing project-level climate performance across construction and operational phases.
• National target setting: The government will establish and periodically update national emissions reduction targets aligned with international best practice across all sectors. As these are issued, your organisation will need to align its own reduction plans to sector benchmarks.
• Sector-specific adaptation plans: Climate adaptation plans will be implemented across key areas including infrastructure, energy, environment, health, and insurance — informed by ongoing climate risk assessments and incorporating targeted response measures, early warning systems, and defined implementation pathways.
• Carbon market engagement: Your organisation may be required to participate in carbon offsetting, emissions trading, or similar mechanisms as these frameworks are introduced and scaled nationally. Understanding the market early creates a strategic advantage.

What this means for your organisation

As national frameworks are rolled out, four operational shifts will be required:

1. Emissions measurement: Quantify and track greenhouse gas emissions to support national target-setting and sector-level decarbonisation pathways as they are issued.
2. Target alignment: Align with sector-specific emissions reduction plans as national targets are translated into actionable sector requirements.
3. Adaptation planning: Assess climate risks and implement adaptation measures relevant to your sector, supported by defined response actions and systems.
4. Data submission: Provide climate-related data — including emissions and impact information — to support national monitoring and international reporting obligations.

Five Binding Obligations for Your Organisation

These are not voluntary commitments. They are legal requirements under federal law. Every organisation within scope must act on all five.

1. Measure and track emissions: Regularly measure greenhouse gas emissions from your activities, develop and maintain a comprehensive emissions inventory, and identify key emission sources.
2. Implement data collection systems: Align with Ministry-approved electronic systems for emissions monitoring, ensuring proper mechanisms are in place for data submission and integration with relevant authority systems.
3. Take emission reduction actions: Implement emission reduction measures in line with resolutions issued by the Ministry and aligned with national regulatory requirements.
4. Maintain records and report annually: Retain emissions data for a minimum of five years, submit periodic reports as required, and support annual data collection and analysis by the Ministry.
5. Ensure data accuracy and compliance: Maintain accurate and verifiable emissions data and support verification processes conducted by the Ministry or competent authority.

⚠️ Penalties for non-compliance: Organisations that commit any violation of the provisions of the Climate Change Law will be fined between AED 50,000 and AED 2 million.

How Your Organisation Can Reduce or Offset Its Emissions

The law outlines seven recognised climate change mitigation measures your organisation can use to reduce or offset emissions and work towards climate neutrality. The right combination depends on your sector, operations, and emissions profile — and should be embedded in a formal decarbonisation roadmap.

• Improving energy efficiency: Operational changes, energy-efficient technologies, and strategies that reduce energy demand across an organisation’s systems.
• Transitioning to clean energy sources: Solar, wind, hydroelectric, tidal, biomass, and geothermal energy as alternatives to fossil fuels.
• Enhancing and protecting natural carbon sinks: Preserving and restoring natural ecosystems such as forests, mangroves, and soils to strengthen their ability to absorb and store carbon dioxide.
• Carbon capture, use, and storage (CCUS): An emerging technology that captures carbon at its source and stores it underground, converts it into a useful resource, or extracts it from chemicals released into the atmosphere.
• Alternatives to saturated fluorocarbons: Adopting low-impact alternatives to fluorinated gases used in cooling and industrial processes to reduce emissions of high global-warming-potential substances.
• Carbon offsetting: Offsetting emissions through carbon credits, typically for emissions that cannot be mitigated through operational changes.
• Integrated waste management systems: Applying circular economy principles to eliminate waste while minimising emissions across operations.

How AESG Can Help: Aligning Your Organisation With the UAE Climate Law

At AESG, we support our clients in navigating the transition towards climate resilience and effective greenhouse gas management. Our services are designed to take you from initial compliance to long-term strategic advantage — covering every obligation the law creates.

• Carbon footprint assessment: Quantify Scope 1, 2, and relevant Scope 3 emissions across operations, construction activities, building systems, and sector-specific supply chains, following GHG Protocol standards.
• Decarbonisation roadmap development: Develop a sector-specific pathway to Net Zero, aligned with your ESG strategy, science-based targets (SBTi), and regional energy regulations, identifying emission reduction levers across energy efficiency, renewable energy adoption, low-carbon materials, and supply chain interventions.
• Climate vulnerability & risk assessment: Scenario analysis aligned with IFRS S2 (ISSB) and TCFD, mapping physical risks — flooding, heat stress, water scarcity, power disruption — and transition risks including regulatory change, carbon pricing, and reputational exposure.
• Data strategy & validation: Design ESG data collection and monitoring systems across KPIs including energy, water, emissions, and supply chain performance — ensuring traceability, accuracy, and assurance readiness for regulatory scrutiny and third-party verification.
• Framework alignment & report development: Support reporting aligned with the SDGs, GRI, TCFD, CDP, and regional UAE frameworks, developing sector-specific ESG reports as requirements evolve.
• Risk integration & action planning: Prioritise ESG and climate risks and develop mitigation or adaptation plans for projects, operations, and supply chains — translating risk findings into concrete, implementable actions.

Understand Your Obligations Under the UAE Climate Law

The compliance window is closing and the obligations are now legally binding. AESG’s sustainability and ESG specialists can help you measure your emissions, build a compliant decarbonisation roadmap, and turn regulatory compliance into long-term strategic advantage. Get in touch with our team to discuss your organisation’s path to compliance under Federal Decree-Law No. 11 of 2024.