UAE Federal Decree-Law 11/2024 — the MRV duty, the carbon-credit register and what is still left to resolutions

Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects is the UAE’s framework climate statute. It creates a measurement, reporting and verification (MRV) duty, backs it with court-imposed fines, and leaves much of its operative detail — which sources report, on what forms, to what standards — to resolutions of the Ministry of Climate Change and Environment. A companion Cabinet resolution carries the numeric threshold and the named verification standards that the Decree-Law does not.

What it is

The Decree-Law was issued on 28 August 2024, published in Official Gazette No. 782 dated 30 August 2024, and took effect on 30 May 2025, nine months after publication as Article 21 provides.¹ Its core obligation is Article 6(1). Sources determined by the Ministry and the competent authority are to measure their emissions regularly, take measures to reduce those emissions in accordance with the resolutions issued by the Ministry, prepare an emissions inventory and submit periodic reports to the standards the Ministry or competent authority specifies; submit data on emission-related activities and on current and planned reduction measures on approved forms; and keep records of measured emissions for five years, accessible to officials with judicial-officer capacity.² The Ministry is to establish an electronic system for emission measurement and data submission.²

Around that duty sit the framework provisions. Article 4 lists the means by which sources contribute to reducing emissions — energy efficiency, clean energy, carbon sinks, carbon capture, utilisation and storage, alternatives to saturated fluorocarbons, carbon offsetting and integrated waste management — and lets the Ministry issue resolutions on the controls and standards for them. Article 5 has the Cabinet set annual emission-reduction targets for all sectors, and Article 10 provides for incentives including emissions trading and shadow carbon prices and has the Ministry manage the National Carbon Credit Registry.²

Cabinet Resolution No. (67) of 2024 Concerning the National Register for Carbon Credits is a companion instrument rather than an implementing one: it was issued on 10 June 2024, published in Official Gazette No. 778 dated 28 June 2024, took effect on 28 December 2024,³ and its preamble cites Federal Law No. (24) of 1999 on the environment and Federal Law No. (4) of 2000 on the Securities and Commodities Authority rather than the Decree-Law, which came later.⁴ It aims at climate neutrality of the State in 2050, requires entities of huge carbon emissions to register, deems carbon credits financial instruments in case trading is in the State, dates credit approval from the 2019 baseline year, and lets the Ministry use the register to provide documents to ensure compliance of the participating entities with the requirements of carbon border taxes.⁴

On 16 October 2025 the Ministry announced the launch of a National MRV system, an integrated platform combining monitoring of greenhouse gas emissions and air pollutants, aligned with Article 13 of the Paris Agreement.⁵ The release states no deadline, threshold or list of bound entities.

Who it binds

The Decree-Law applies to “sources in the State, including free zones”, a source being any public or private legal person or individual enterprise whose operations release greenhouse gases; the competent authority is the local authority concerned in each emirate, including free zones, and greenhouse gases are defined as gases that contribute to the greenhouse effect, the most important of which are carbon dioxide, methane, nitrous oxide, nitrogen trifluoride, hydrofluorocarbons, perfluorocarbons and sulphur hexafluoride — an illustrative list, not a closed one.² Scope of application and reporting duty differ: the Article 6(1) obligations attach to the sources the Ministry and the competent authority determine.² Whether that determining resolution, or the reporting standards and forms, has been issued is not confirmed on a primary source here, and commentary asserting that every UAE entity has to report by a fixed date does not rest on the text of the Decree-Law.

Cabinet Resolution 67/2024 binds a defined population: entities in the State, including financial and non-financial free zones, whose scope 1 and scope 2 emissions equal or exceed 0.5 million metric tons of CO2 equivalent annually, plus smaller entities that register voluntarily to obtain or trade carbon credits.⁴

Dates

Three dates are printed by the sources: 30 May 2025 for entry into force of the Decree-Law,¹ 28 December 2024 for the Resolution,³ and 16 October 2025 for the MRV announcement.⁵ Two commonly quoted dates are printed nowhere and are arithmetic. Article 18 gives sources one year from entry into force to adjust their status, which by arithmetic from 30 May 2025 ends on 30 May 2026; the Cabinet may extend that period on the Minister’s proposal, and whether it has done so is not confirmed on a primary source here.² Article 14 of the Resolution gives entities of huge carbon emissions six months from the enforcement date to regularise, which by arithmetic from 28 December 2024 ended on 28 June 2025.⁴ The recurring obligations are periodic reports under Article 6(1) and annual collection and analysis of emission data,² plus an annual GHG emissions report under the Resolution.⁴

Thresholds

The Decree-Law contains no numeric threshold. It reaches all sources and then narrows the MRV duty by ministerial determination rather than by size.² The numeric line is in the Resolution: 0.5 million metric tons of CO2 equivalent a year across scope 1 and scope 2, with the Cabinet able to add sectors or amend the threshold.⁴ Penalties are the other quantified element — a fine of not less than AED 50,000 and not more than AED 2,000,000 for violating Article 6(1), doubled for the same violation repeated within two years of a final conviction, with administrative penalties and a complaints mechanism left to a Cabinet resolution;² and, under the Resolution, administrative fines of AED 500,000, 1,000,000 and 2,000,000 for first, second and later failures to measure emissions, deliver the annual report or meet Paris Agreement and IPCC reporting requirements, and AED 100,000 to 300,000 for other breaches.⁴

Verification standard

The Decree-Law names no standard. Article 6(3) provides that the Ministry or the competent authority is to verify the accuracy of data on activities related to emissions and the extent to which sources are committed to submitting it — a supervisory verification by the regulator, not a mandated third-party audit.² Enforcement runs through employees designated as judicial officers to detect violations.²

The named standards are in the Resolution: monitoring on IPCC methodologies against a baseline of 2019 or later, an annual GHG emissions report to the Ministry and the competent authority, and emissions-reduction reports audited by a verification agency authorised by the Ministry, working to ISO 14065, approved for ISO 14064 or ISO 14067 scope and accredited to ISO 17029 or ISO 17065; the Minister is to approve a list of authorised verification agencies.⁴

What an organisation on ESGOS can do

An organisation operating in the UAE can find its listing in the directory and claim it from its profile page, or get listed and attach its emissions inventory, verification statement or National Register registration as evidence, so that the standard a verification body worked to is visible next to the figure it checked. Where EU customers ask for the same emissions data, a compliance profile lets them see that verification status, and the exposure check shows which goods sit inside EU import regimes. The verifiers directory lists accredited verification bodies drawn from national accreditation registers, by standard.

Footnotes

1. Federal Decree-Law on the Reduction of Climate Change Effects — legislation record, UAE Legislation portal. ↩ ↩²

2. Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects (official English text), UAE Legislation portal. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹

3. Cabinet Resolution Concerning the National Register for Carbon Credits — legislation record, UAE Legislation portal. ↩ ↩²

4. Cabinet Resolution No. (67) of 2024 Concerning the National Register for Carbon Credits (official English text), UAE Legislation portal. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

5. UAE launches National MRV System to support UAE’s net zero goals, UAE Ministry of Climate Change and Environment. ↩ ↩²