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.

This guide helps you assess reporting readiness. It is not a legal determination of applicability.

Phase 1 Criteria: Confirmed Triggers

Federal Decree-Law No. 11 of 2024 applies to "Sources determined by the Ministry." MOCCAE has not published national revenue or employee-count thresholds. Confirmed triggers under Phase 1 are:

• Operations in MOCCAE-designated high-impact sectors — energy, manufacturing, transport, waste management, construction
• Annual emissions of 500,000 tCO₂e or more (HCEE threshold) — across Scope 1 and Scope 2
• Direct designation by MOCCAE or a competent authority — any entity may be designated regardless of revenue or headcount

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 Zone Status Is Not an Exemption

Federal Decree-Law No. 11/2024 applies to entities in the UAE regardless of free zone registration. Whether your company is in JAFZA, DMCC, DIFC, ADGM, or any other free zone, free zone status does not automatically remove federal applicability. Actual reporting obligation depends on sector, designation, thresholds, and further official guidance. Companies should assess applicability and prepare data if exposed.

Where Does Your Company Fit? A Readiness Orientation

Rather than a binary yes/no, most UAE companies fall into one of these five readiness positions:

• Clearly in scope: Operating in a MOCCAE-designated sector with emissions above 500,000 tCO₂e annually, or already directly designated — begin structured reporting preparation now
• Likely in scope: In a designated sector but below the confirmed HCEE threshold — monitor sector-specific guidance and prepare data collection processes
• Monitor guidance: In a sector adjacent to designated industries, or with significant but unquantified emissions — track MOCCAE announcements and begin boundary definition
• Probably not Phase 1 but should prepare: Outside current designated sectors with modest emissions — Phase 2 expansion is possible; begin data hygiene and emissions inventory now
• Seek confirmation: Unusual operating structure (shared premises, holding company, multi-emirate operations) — consult a sustainability advisor and verify directly through official channels

Using the SmartFenek Eligibility Checker

The SmartFenek eligibility checker walks through the key applicability questions in under two minutes. It covers sector classification, emirate context, and emission profile characteristics — and maps your answers to the five readiness positions above. Use it as a practical orientation tool, not a substitute for legal or regulatory advice.

Find Out in 2 Minutes

Check your readiness status in 2 minutes. Answer a few questions about your sector, emissions, and operations, and SmartFenek will tell you whether you likely fall under Phase 1 — along with recommended next steps.