Overview
Environmental sustainability is a relatively recent and emerging topic in the United Arab Emirates (UAE), reflecting the country’s evolving institutional and legislative maturity.
Unlike more established jurisdictions, the UAE has only recently started to shape a comprehensive legal and policy framework on climate change.
Significant progress began with the ratification of the Paris Agreement through Federal Law No. 238/2016 and accelerated after the UAE hosted COP28 in Dubai in December 2023, culminating in the adoption of Federal Decree-Law No. 11/2024 on Limiting the Impact of Climate Change, which marked the first dedicated federal legislation specifically addressing climate change mitigation in a comprehensive manner.
Although it does not yet establish binding deadlines, Federal Decree-Law No. 11/2024 marks a foundational step in formalising the UAE’s climate strategy aligning national goals with the UAE Net Zero 20502, which is a strategic initiative with broader international climate standards.
Key objectives
The law identifies several strategic objectives. These include managing greenhouse gas emissions to achieve climate neutrality, strengthening resilience of ecosystems and key economic sectors, and promoting innovation and new technologies. It also stresses the importance of data collection and reporting at national and international levels, and the alignment of local strategies with broader national and global climate goals.
Scope of application
The scope of the law is wide. It applies not only to private companies and commercial entities, but also to public institutions, including ministries, local authorities, and free zone authorities. This underlines the idea that climate action is a shared responsibility across all levels of government and the private sector.
From strategy to implementation: Key obligations
The law sets out an implementation framework based on annual emission reduction targets, to be proposed by the Ministry of Climate Change and Environment and adopted at the federal level. These targets will be supported by specific sectoral adaptation plans in areas such as energy, infrastructure, environment, and health, ensuring that mitigation measures are tailored and effective.
Obligations of private entities
Companies identified by the authorities will be required to measure and report their emissions, prepare inventories, and adopt reduction measures within their operations. They must also maintain records and submit data in accordance with methodologies defined by the Ministry. To support compliance, the law provides for incentives and encourages the use of innovative technologies.
The National Carbon Credit Registry
An important innovation is the creation of the National Carbon Credit Registry, established by Cabinet Decision No. 67/2024. This platform allows for the issuance, verification, and trading of carbon credits, offering companies a mechanism to offset emissions they cannot immediately reduce. Registration is mandatory for entities with very high emissions, ensuring that the biggest polluters are directly involved in the system.
Enforcement and deterrence
Finally, the law combines incentives with a system of sanctions. Fines range from AED 50,000 to AED 2 million depending on the seriousness of the breach, and can be doubled in case of repeated violations. In addition to monetary penalties, administrative measures may also be introduced by future regulations, ensuring that compliance is not optional but a legal obligation.
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