What Is Federal Decree-Law No. 11/2024? A Plain-English Guide for UAE Businesses

A New Era for Environmental Accountability in the UAE

In late 2024, the UAE government enacted Federal Decree-Law No. 11/2024 on the regulation of greenhouse gas (GHG) emissions. This landmark legislation marks the country's most significant step toward meeting its Net Zero 2050 commitment and fulfilling its obligations under the Paris Agreement.

If you run a business in the UAE, this law may directly affect you. This guide breaks down the decree in plain English — no legal jargon, no confusion — so you can understand exactly what it means and what you need to do.

What Does the Law Actually Say?

Federal Decree-Law No. 11/2024 establishes a mandatory GHG emissions reporting framework for businesses operating in the UAE. The law requires qualifying entities to:

• Measure and calculate their greenhouse gas emissions annually
• Submit official emissions reports to the Ministry of Climate Change and Environment (MOCCAE)
• Follow standardized methodologies and emission factors approved by the Ministry
• Maintain accurate records and documentation for audit purposes

The law also grants MOCCAE the authority to set reduction targets, issue guidelines, and impose penalties for non-compliance. This is not voluntary — it is a federal legal obligation.

Who Must Comply? Phase 1 Criteria

The law applies to "Sources determined by the Ministry" (Art. 4 of Decree-Law No. 11/2024). MOCCAE has not yet published national revenue or employee-count thresholds. Confirmed triggers under Phase 1 are:

• Operations in MOCCAE-designated high-impact sectors (energy, oil and gas, manufacturing, transport, waste management, construction, and heavy industry)
• High Carbon Emitting Entities (HCEEs): annual emissions of 500,000 tCO₂e or more (Scope 1 & 2)
• Direct designation by MOCCAE or a competent authority (e.g. Abu Dhabi EAD, which has emirate-level thresholds of ≥ 25,000 tCO₂e in Industry, Power, Oil & Gas, and Transport)

There are no exemptions for free zone entities — the law applies across the entire UAE, including JAFZA, DMCC, DIFC, ADGM, and all other free zones.

Phase 2: The 2027 Expansion

Phase 2, expected to take effect in 2027, will significantly expand the scope of mandatory reporting. MOCCAE is expected to broaden the list of designated entities, introduce clearer size-based triggers, and potentially require Scope 3 emissions reporting for designated sectors. Companies that build reporting infrastructure early will find Phase 2 compliance far less disruptive.

Penalties: What Happens If You Don't Comply?

The law carries serious financial penalties:

• AED 50,000 to AED 2,000,000 in fines for failure to report, late submission, or inaccurate reporting (based on public reports; verify with your legal advisor)
• Doubled penalties for repeat offences — a second violation could cost up to AED 4 million
• Potential additional administrative sanctions including suspension of operating licenses in severe cases

What Businesses Need to Do Now

If you suspect your business may fall under Phase 1, here is a practical action plan:

• Step 1: Determine your eligibility — review your sector, estimated emissions (Scope 1 & 2), and whether MOCCAE has directly designated your entity
• Step 2: Identify your emission sources — map Scope 1 (direct) and Scope 2 (electricity) sources
• Step 3: Collect baseline data — gather utility bills, fuel records, fleet logs for the reporting year
• Step 4: Choose the right tools — purpose-built GHG software ensures correct UAE emission factors and MOCCAE compliance
• Step 5: Engage an expert if needed — a sustainability consultant who understands the UAE regulatory landscape saves weeks of guesswork

What Is Still Unclear or Subject to Further Guidance

Intellectual honesty requires acknowledging what the law does not yet fully define. As of 2026, several technical matters remain pending further official guidance:

• Sector-level threshold details: While the HCEE threshold (≥500,000 tCO₂e) is established, some sector-specific designation details are pending the technical guidance document
• Verification requirements: The conditions under which third-party verification will be mandatory — beyond self-reported data — are not fully specified in the current legislation
• Scope 3 phasing: The specific timeline for mandatory Scope 3 reporting is subject to further regulatory guidance
• Portal and submission format: MOCCAE's MRV portal procedures and required submission formats are expected to be clarified through official guidance documents
• Free zone applicability details: The specific conditions under which free zone entities of different types fall within scope remain subject to further clarification
• EAD and federal coordination: How Abu Dhabi entities coordinate between EAD's facility-level MRV requirements and the federal framework is evolving

Monitor moccae.gov.ae and official UAE Government channels for updates. Organisations should not rely solely on third-party summaries — verify all requirements directly.

Check Your Eligibility Today

Not sure if your business needs to report? Check your readiness status with SmartFenek's free assessment. Answer a few questions about your business, and we will tell you exactly where you stand — and what steps to take next.