UAE issues climate law guidance for high-emitters before 2025 deadline

The UAE issued regulatory guidance for its 2024 Federal Decree-Law on climate change, effective May 30 2025, requiring entities emitting 500,000 tonnes or more CO2-equivalent annually to register and submit baseline emissions by June 28 2025. Indian companies with UAE operations or supply-chain links must assess registration obligations and penalties of up to AED 1 million.

Federal Decree-Law No. 11 of 2024 "On the Reduction of Climate Change Effects" took effect May 30, 2025, with guidance developed alongside the Ministry of Climate Change and Environment. Entities emitting 500,000 metric tons or more of CO2-equivalent annually across Scope 1 and 2, classed as "entities of huge carbon emissions," must establish climate governance, MRV systems, and submit baseline emissions data by June 28, 2025, to the National Carbon Credit Registry. Voluntary participation is open to other entities.

High-emission sectors and large industrial operators are directly regulated, while other entities may register voluntarily to trade carbon credits or demonstrate proactive measures. Regulated entities must develop tailored emissions-reduction strategies with clear targets, and from May 2026 operationalise climate adaptation plans assessing physical risks to assets and supply chains. Annual compliance reports verified by accredited third parties must document emissions trends, reduction outcomes, and energy efficiency measures.

Affected firms should register with the NCCR and submit baseline data by June 28, 2025, then build decarbonisation roadmaps aligned with the UAE Net Zero by 2050 initiative and adopt TCFD-aligned reporting. Non-compliance invites penalties up to AED 1 million, operational suspension, legal action, and reputational damage. Early compliance offers access to sustainability-linked loans and entry into carbon trading. Indian firms operating in the UAE should integrate climate risk into core planning cycles.

Key figure — Baseline emissions submission deadline: June 28, 2025, to the NCCR