Originally published 2024 • Updated Oct 29, 2025
UAE’s New Climate Law and Its Impact on Regional Businesses:
6 Months In
The UAE’s Federal Decree-Law No. (11) of 2024 on the Reduction of Climate Change Effects entered into force on May 30, 2025, marking a shift from climate ambition to climate accounting. The law hard‑wires measurement, reporting and verification (MRV) into the obligations of designated “sources” and sets penalties for non‑compliance, while also creating the market plumbing for carbon credits at federal level. For boards and disclosure teams, this has fused legal compliance, operational decarbonisation, and ESG reporting into a single, auditable workflow.
Where companies are after six months
Over the past six months, the corporate response has moved from policy awareness to execution. Most large emitters and listed companies have been standing up greenhouse‑gas inventories (Scopes 1–2 first, with Scope 3 hotspot mapping), building internal controls, and preparing to submit standardised data to government systems, as required by Article (6) of the Decree‑Law. The emphasis has been on getting methods consistent and records defensible—so that year‑end Sustainability Reports don’t just narrate intent, but evidence performance in a way that can be assured.
The National MRV System
A key accelerant arrived in October 2025 with the launch of the National MRV System by the Ministry of Climate Change and Environment. The platform centralises emissions data and environmental governance, giving companies a federal “single source of truth” for submissions and national progress tracking. Many firms have begun onboarding so their 2025 baselines are captured in a consistent format that aligns with investor expectations and the way Sustainability Reports present methodologies and results.
Carbon credits and the NRCC
In parallel, the National Register for Carbon Credits (NRCC)—established under Cabinet Resolution No. (67) of 2024—has begun shaping corporate strategy. From June 28, 2025, entities of huge carbon emissions (≥ 0.5 MtCO₂e/year across Scopes 1–2) fell into mandatory compliance, with participation open to smaller entities. Heavy industry and energy companies prioritised registry readiness and started building credit/offset strategies that dovetail with their reduction plans. The resolution applies across the UAE, including free zones, anchoring carbon accounting to a formal federal register.
Investor signalling and disclosure practice
Investor expectations have reinforced this shift. Abu Dhabi Securities Exchange (ADX) issued ESG Disclosure Guidance for Listed Companies in 2025, pushing for consistent, decision‑useful climate metrics and clearer alignment with global standards (e.g., IFRS S2 and GRI). Even where guidance is “voluntary,” the market read is plain: treat ESG with the same rigour as financials.
What to do this quarter
• Lock your 2025 baseline methods and ownership (Ops + Finance + Sustainability).
• Map Article (6) obligations to your internal controls and audit trail; document system boundaries and data sources.
• Complete onboarding to the National MRV System; align file formats, sign-offs, and deadlines.
• If in scope (≥ 0.5 MtCO₂e), confirm NRCC registration, credit strategy, and internal approval thresholds.
• For listed issuers, align with ADX ESG guidance structure and plan limited assurance on key metrics.
How NRCC credits show up in ESG reporting
• Project type and expected tCO₂e
• Verification standard and retirement status
• Reconcile credits with residual emissions
• Cross-reference National Register entry
• Quality criteria: durability, additionality, double-counting
Have there been amendments?
As of October 28, 2025, there are no published amendments to Federal Decree‑Law No. (11) of 2024 on the UAE’s official legislation portal. What has evolved is the implementation architecture: the NRCC framework (effective December 28, 2024; compliance June 28, 2025) and the National MRV System launched in October 2025 now operationalise the statute’s requirements. In short, the rails are in place; companies are moving from promises to auditable performance.
What this means for your next Sustainability Report
Expect your 2025–26 disclosures to become more standardised and evidence‑based. Use the MRV rollout to document methodologies, controls, and responsibilities; show how registry interactions and reduction projects translate into KPIs; and make verification/assurance plans explicit so readers understand what’s been independently checked. For listed entities, echo ADX’s structure and terminology so investors can compare like‑for‑like across peers.
Helpful internal reads
• Scope 3 and supplier engagement in UAE supply chains → /blog/scope-3-uae-supply-chains<br/>
• UAE sustainable finance and taxonomy overview → /services/sustainable-finance-uae
Editor’s note: This page reflects the law as in force and publicly announced implementation measures as of October 28, 2025. We’ll update if official amendments are published.