Do I Need to Report? A GHG Eligibility Guide for UAE Companies

The Question Every UAE Business Is Asking

Since the enactment of Federal Decree-Law No. 11/2024, the most common question we hear is: "Does this apply to me?" The answer depends on a few specific criteria.

Phase 1 Criteria: The Four Thresholds

Your business must report if it meets any one of these:

• Annual revenue of AED 250 million or more — based on audited financial statements
• 250 or more employees — full-time employees registered with MOHRE
• Operations in designated high-impact sectors — energy, manufacturing, transport, waste management, construction
• Annual emissions of 500,000 tCO2e or more — across Scope 1 and Scope 2

What Are "Designated Sectors"?

MOCCAE publishes the list of designated sectors. The initial list focuses on:

• Energy and utilities — power generation, oil and gas, refining, LNG
• Manufacturing — cement, steel, aluminium, chemicals, glass, ceramics
• Transport and logistics — airlines, shipping, freight, large fleet operators
• Waste management — landfill operators, waste processing, recycling
• Construction — major contractors and developers with significant on-site emissions

Free Zones Are NOT Exempt

Federal Decree-Law No. 11/2024 applies to all entities in the UAE, including those registered in free zones. Whether your company is in JAFZA, DMCC, DIFC, ADGM, or any other free zone, the law applies equally. Free zone tax exemptions do not extend to environmental reporting obligations.

What If You're Unsure?

• Err on the side of reporting — no penalty for voluntary reporting, significant penalties for failing to report when required
• Seek a professional assessment — a sustainability consultant can evaluate your specific situation
• Use automated tools — eligibility checkers cross-reference your data against known criteria instantly

Find Out in 2 Minutes

Use our eligibility checker to find out in 2 minutes. Enter your revenue, headcount, and sector, and SmartFenek will instantly tell you whether you fall under Phase 1 — along with recommended next steps.