United Arab Emirates — climate law, carbon registry and CBAM exposure

The United Arab Emirates requires emission sources to measure their greenhouse gas emissions, report them and keep records, under a federal climate law backed by court-imposed fines. A Cabinet resolution binds emitters at or above a 0.5 million tCO2e threshold to a national carbon-credit register and names the ISO standards their verification must meet, and the Ministry has launched a national measurement, reporting and verification (MRV) platform. UAE exporters of cement, steel, aluminium, fertilisers, hydrogen or electricity to the EU also sit inside the definitive phase of the EU Carbon Border Adjustment Mechanism (CBAM).

What is in force

Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects. 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 Article 6(1) requires sources determined by the Ministry of Climate Change and Environment and the competent local authority to measure their emissions regularly, take measures to reduce those emissions in accordance with the resolutions issued by the Ministry, and prepare an emissions inventory. The same provision requires them to submit periodic reports to the standards the Ministry or competent authority specifies, and to submit data on emission-related activities and on current and planned reduction measures on approved forms. Records of measured emissions must be kept 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, and emission data is to be collected and analysed annually. The Ministry or the competent authority is to verify the accuracy of data on activities related to emissions and the extent to which sources submit it. The Ministry may also issue resolutions on controls and standards for the mitigation means listed in Article 4.² Article 10(3) has the Ministry establish and manage the National Carbon Credit Registry.²

Cabinet Resolution No. (67) of 2024 Concerning the National Register for Carbon Credits. This companion instrument was issued on 10 June 2024, published in Official Gazette No. 778 dated 28 June 2024, and took effect on 28 December 2024, six months after publication.³ Its stated aim is climate neutrality of the State in 2050 and the regulation of carbon-credit registration.⁴ It requires entities of huge carbon emissions to register in the National Register and gave them six months from the enforcement date to regularise, a period that ran to 28 June 2025.⁴

National MRV system. On 16 October 2025 the Ministry announced the launch of the National Measurement, Reporting and Verification (MRV) system, an integrated national platform combining monitoring of greenhouse gas emissions and air pollutants. It is aligned with Article 13 of the Paris Agreement and designed to let the private sector assess its decarbonisation progress.⁵ The release sets no reporting deadlines or thresholds.

EU CBAM, definitive phase. For goods of UAE origin, Regulation (EU) 2023/956 lists cement, electricity, fertilisers, iron and steel, aluminium and hydrogen in Annex I; Annex III excludes only goods originating in Iceland, Liechtenstein, Norway and Switzerland and five territories, so UAE goods are within scope.⁶ The transitional period from 1 October 2023 until 31 December 2025 limited importer obligations to reporting. Applications for authorised CBAM declarant status opened on 31 December 2024 under Article 36(2)(a), and from 1 January 2026 goods may be imported only by an authorised CBAM declarant (Article 4), alongside the declaration, certificate and penalty articles.⁷

What is coming

Under Article 18 of the Decree-Law, sources must adjust their status within one year of entry into force — a period that falls on 30 May 2026 — and the Cabinet may extend that period on the Minister’s proposal.² Whether an extension has been adopted is unconfirmed on a primary source. The Decree-Law also leaves administrative penalties and the complaints mechanism to a Cabinet resolution, and the reporting standards, forms and the determination of which sources report to resolutions of the Ministry.² The existence of those resolutions is likewise unconfirmed here.

Under CBAM, the authorised declarant must submit its CBAM declaration by 30 September of each year, and for the first time in 2027 for the year 2026, and surrender the corresponding certificates by the same date. The quarterly certificate-holding requirement in Article 22(2) applies from 1 January 2027.⁷

Who it binds

The Decree-Law applies to “sources in the State, including free zones”, where a source is any public or private legal person or individual enterprise whose operations release greenhouse gases; the operative MRV duty in Article 6(1) attaches to the sources the Ministry and competent authority determine.² Cabinet Resolution 67/2024 applies in the State, including financial and non-financial free zones, to entities whose scope 1 and scope 2 emissions equal or exceed 0.5 million metric tons of CO2 equivalent a year, and to smaller entities that voluntarily register to obtain or trade carbon credits.⁴

CBAM binds the EU importer, not the UAE producer: goods may be imported into the Union only by an authorised CBAM declarant.⁷ An importer whose CBAM goods do not cumulatively exceed 50 tonnes of net mass in a calendar year is exempt under Article 2a; Regulation (EU) 2025/2083, which introduced that threshold, entered into force on 20 October 2025 and excludes electricity and hydrogen from the exemption.⁸

Verification requirements

The Decree-Law places verification of emissions data with the Ministry or the competent authority and does not name a standard.² Cabinet Resolution 67/2024 does: monitoring uses IPCC methodologies against a baseline of 2019 or later, and an annual GHG emissions report goes to the Ministry and the competent authority. Emissions-reduction reports are 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

Under CBAM, where embedded emissions are determined on actual emissions, the declarant must have them verified by a verifier accredited under Article 18 on the principles in Annex VI. Declarants may otherwise use default values, and may claim a reduction for a carbon price effectively paid in a third country. A UAE operator may register its installation in the CBAM registry for five years, so that verified data can be shared with importers.⁷

Penalties differ in kind. Article 15 of the Decree-Law sets a fine of not less than AED 50,000 and not more than AED 2,000,000 for violating Article 6(1), doubled for repeating the same violation within two years of a final conviction.² Annex 2 of Cabinet Resolution 67/2024 sets 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 CBAM sets a penalty per certificate not surrendered.⁷

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 submit its emissions inventory, verification statement or National Register registration as evidence. Where an organisation exports CBAM goods, a compliance profile lets EU customers see the verification status behind the emissions data they need for their declarations, and the exposure check shows how those goods sit against Annex I. The verifiers directory lists accredited verification bodies drawn from national accreditation registers, by standard; verifiers accredited for CBAM are not yet published by the Commission, so the directory does not hold them.

Footnotes

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

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

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

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

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

6. Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, EUR-Lex. ↩

7. Regulation (EU) 2023/956 — consolidated text, EUR-Lex. ↩ ↩² ↩³ ↩⁴ ↩⁵

8. Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956, EUR-Lex. ↩