UAE DECREE 11 · MANDATORY CLIMATE DISCLOSURE

UAE Federal Decree Law No. 11 of 2024 made climate reporting mandatory across the country.

Federal law, not a sector rule. Applies onshore and offshore, public and private.

Runs on your public disclosures. Nothing from you.

Deadline: Effective 30 May 2024, implementing regulations issued Q4 2024 In scope: All entities operating in the UAE, onshore and free zones, above thresholds set by Cabinet Penalty: Administrative fines up to AED 2 million, escalating to activity suspension
This is for

You are the Head of Sustainability at a UAE-headquartered company, or the UAE office of a group headquartered elsewhere. The UAE Cabinet made climate disclosure mandatory. Your board asked what it means for the group.

The answer

UAE Federal Decree Law No. 11 of 2024 on the Reduction of Climate Change Effects was issued on 30 May 2024. It creates a legal obligation on all entities operating in the UAE, including free zones, to inventory greenhouse-gas emissions, submit annual reports to the Ministry of Climate Change and Environment, and take reduction measures. The Cabinet issues implementing regulations, sector thresholds, and technical specifications. First reports become due after the implementing regulations take effect.

What UAE Decree 11 actually is

Decree 11 covers direct emissions (Scope 1), energy indirect emissions (Scope 2), and other indirect emissions (Scope 3) where the Cabinet specifies. It applies onshore, in the free zones, and to activities in the Exclusive Economic Zone.

The Ministry of Climate Change and Environment operates the national GHG inventory register. Data is submitted through a national platform, with methodologies aligned to IPCC 2006 Guidelines with 2019 Refinements.

The Decree lays out reduction measures alongside the reporting obligation. Companies must set reduction plans, and the Cabinet can set sectoral targets that align with the UAE Net Zero by 2050 commitment.

Why now

The implementing regulations were published in Q4 2024 and phase-in through 2025 and 2026. Company registration on the national platform and first inventory submissions come inside the phase-in window. Getting a UAE-scope emission inventory in place before the platform goes live is the difference between a first report that clears and a first report that gets rejected.

WHAT BREAKS

What breaks when your carbon number is not defensible.

Three failure modes we see on every UAE Decree 11 scan.

FAILURE 01

Emissions calculated at group level, not UAE level

The group publishes a global inventory but has no UAE-only cut. The Ministry portal cannot accept a global number.

FAILURE 02

Free-zone entities left out of the boundary

The UAE office reports for onshore only. Free-zone subsidiaries are also in scope. The submission is incomplete.

FAILURE 03

IPCC methodology not tagged per source

The inventory uses non-IPCC factors. The Ministry portal validates methodology per source. Non-compliant sources are rejected.

HOW CARBON-OS ANSWERS

Three moves that make UAE Decree 11 defensible.

ANSWER 01

A UAE entity boundary

Carbon-OS separates the UAE entity view from the group view. The UAE inventory is a first-class report, not a filter.

ANSWER 02

Onshore, free zone, EEZ, all mapped

Every UAE operating unit tagged by location type. Nothing hidden in a free zone.

ANSWER 03

IPCC methodology per source

Every emission source carries its IPCC 2006 (with 2019 refinements) methodology reference. The Ministry portal accepts on first pass.

See where your UAE Decree 11 number stands. Free scan.

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FAQS

What people ask, straight.

When did Decree 11 take effect?

The Decree was issued on 30 May 2024. Implementing regulations followed in Q4 2024 and phase in through 2025 and 2026.

Does Decree 11 apply to free-zone entities?

Yes. The Decree applies onshore, in all free zones, and to activities in the UAE Exclusive Economic Zone.

Which entities are in scope?

Sector thresholds are set by the Cabinet. In practice, the Decree covers all entities of any material size operating in the UAE, with the largest emitters first.

What is the penalty for non-compliance?

Administrative fines up to AED 2 million per violation, doubling for repeat offences, and up to activity suspension for continued non-compliance.

How does Decree 11 fit the UAE Net Zero 2050 commitment?

The Decree is the primary legal instrument for measuring the emissions the UAE targets under its Net Zero 2050 commitment. The inventory is what makes the target trackable.

RELATED FRAMEWORKS

See the neighbours.

Sources: UAE MOCCAE laws and legislations; Federal Decree Law No. 11 of 2024 on Reduction of Climate Change Effects.