Federal Decree-Law No. 11 of 2024 β€” Reduction of Climate Change Effects

Issued
Aug 2024
Enforcement starts
30 May 2025
Article 24
Max penalty
AED 2M
Per violation, doubled on repeat

Key provisions

  • Establishes legal framework for UAE's Net Zero by 2050 target
  • Mandates GHG inventory reporting by all public + private entities operating in UAE that emit GHGs from facilities/activities
  • Requires entities to identify, calculate, and report Scope 1 emissions to the Ministry of Climate Change & Environment (MOCCAE) annually via the National Registry
  • Requires entities to develop and implement mitigation plans + adaptation plans
  • Establishes the legal basis for the National Carbon Credit Registry (operationalised by Cabinet Resolution 67/2024)
  • Creates obligations for free zones (DMCC, ADGM, JAFZA, etc.) to coordinate with MOCCAE

Penalties (interviewers test this)

ViolationPenalty range
Failure to reportAED 50,000 – AED 2,000,000
Submitting incorrect/misleading infoAED 100,000 – AED 2,000,000
Failing to implement reduction planAED 50,000 – AED 2,000,000 + doubled on repeat
False data submitted to access carbon marketAggravated penalties

Who's covered

All entities operating in UAE β€” including free zones β€” with material GHG emissions. Sector-specific thresholds being defined by MOCCAE in implementing regulations.

βœ…
Sample interview answer β€” "Walk me through Federal Decree-Law 11 of 2024"

"It's the UAE's first economy-wide climate law, issued August 2024 with enforcement from 30 May 2025. It mandates GHG inventory reporting by all public and private entities operating in the UAE β€” including free zones β€” to MOCCAE through the National Registry. It requires entities to develop mitigation and adaptation plans, and underpins the National Carbon Credit Registry operationalised by Cabinet Resolution 67 of 2024. Penalties run from AED 50,000 to AED 2 million per violation, doubled on repeat.

From a sustainability engineer's perspective, this means three things: every regulated facility needs a Scope 1 inventory aligned with IPCC and GHG Protocol; we need a documented MRV system that will hold up to third-party verification; and there's now a domestic mechanism to monetise reductions through verified carbon credits."

Cabinet Resolution No. 67 of 2024

Issued August 2024 alongside Decree-Law 11/2024. Sets out the executive regulations and procedures for implementing the Climate Change Law.

Key elements

  • Defines GHG inventory methodology (aligned with IPCC + GHG Protocol)
  • Sector classifications, reporting thresholds, verification requirements
  • Requirements for carbon offset projects and the National Voluntary Carbon Market
  • Procedures for issuing, transferring, retiring carbon credits
  • Conditions for access to international carbon markets under Article 6 of the Paris Agreement
  • Sets MRV (Measurement, Reporting, Verification) requirements β€” third-party verification mandatory above sector thresholds

This is the operational backbone β€” Federal Decree-Law sets the principle, Cabinet Resolution sets the how.

UAE Net Zero by 2050 Strategic Initiative

Launched: October 2021 β€” first MENA country to commit. Updated NDC submitted to UNFCCC July 2024: 47% reduction in GHG emissions vs business-as-usual by 2035 (vs the previous 31% by 2030 NDC).

Key targets

  • Net Zero by 2050 (economy-wide)
  • AED 600 billion (USD 163bn) investment in renewables by 2050
  • 14 GW clean energy capacity by 2030 (vs 2.4 GW in 2020)
  • 30% reduction in methane emissions by 2030 (Global Methane Pledge)
  • COP28 host (Dec 2023, Expo City Dubai) β€” produced the UAE Consensus on transitioning away from fossil fuels

Sectoral plans

Power (Dubai Clean Energy 2050 + Abu Dhabi targets), Transport, Industry, Buildings, Waste, Agriculture & Land Use.

SCA β€” ESG Disclosure for Listed Companies

SCA Decision No. (3/RM) of 2020 (still operative, with subsequent guidance updates).

🎯
Common gotcha

Asked "what is the SCA threshold?" β€” the answer is there is no threshold. All Public Joint Stock Companies (PJSCs) listed on DFM and ADX must publish an annual Sustainability Report regardless of size. (Unlike Saudi Tadawul's voluntary regime.)

Key requirements

  • Annual sustainability report alongside financial statements
  • Must disclose against GRI Standards or equivalent (ISSB, SASB, TCFD now accepted as equivalent under updated guidance 2023)
  • Report in Arabic + English
  • Board-level approval and signed-off statement
  • Disclosure of material ESG topics, governance structure, KPIs

DFM & ADX Disclosure Guides

DFM (Dubai Financial Market)

  • DFM ESG Reporting Guide (latest 2024 update)
  • 32 ESG indicators across E (11), S (12), G (9)
  • Aligned with WFE ESG Guidance, GRI, SASB, TCFD, ISSB
  • Voluntary at metric level but mandatory annual reporting under SCA
  • Runs the S&P Hawkamah ESG UAE Index
  • UN SSE Partner Exchange since 2017

ADX (Abu Dhabi Securities Exchange)

  • ADX ESG Disclosure Guidance (revised 2024)
  • 31 ESG metrics aligned with WFE + UN SSE
  • UN SSE Partner Exchange since 2018
  • Encourages CDP participation and ISSB adoption
  • Both signed the UAE Climate-Responsible Companies Pledge

UAE Climate-Responsible Companies Pledge

Launched: May 2023, ahead of COP28. Spearheaded by MOCCAE.

What signatories commit to

  1. Measure and report Scope 1 + 2 (and where possible Scope 3) emissions annually
  2. Set decarbonisation targets aligned with UAE Net Zero 2050
  3. Develop and execute reduction plans
  4. Disclose progress annually

Signatories (~150+)

ADNOC, Emirates NBD, FAB, Aldar, Etihad, Emirates Airline, Mubadala, ADQ, Masdar, DP World, Emaar, Majid Al Futtaim, etc.

Why it matters in interviews: Demonstrates a public commitment that companies must follow up with concrete MRV systems β€” exactly the work a sustainability engineer does.

Dubai Clean Energy Strategy 2050 / Dubai Net Zero 2050

Targets

  • 25% clean energy by 2030, 75% by 2050 (originally launched 2015 by HH Sheikh Mohammed)
  • Updated to 100% clean energy by 2050 under Dubai Net Zero 2050
  • AED 600bn investment
  • Mohammed bin Rashid Al Maktoum Solar Park β€” 5 GW by 2030, world's largest single-site solar park

Implementing bodies

DEWA, Dubai Supreme Council of Energy.

Related initiatives

  • Dubai Demand Side Management Strategy 2030 β€” 30% reduction in energy + water demand
  • Al Sa'fat Green Building Regulations (Dubai Municipality, mandatory since 2016)
  • Dubai 2040 Urban Master Plan

Abu Dhabi β€” Environment Vision 2030 / Climate Strategy

  • Environment Vision 2030 β€” 5 priority areas: climate change & clean energy; air quality + noise pollution; water resources; biodiversity, habitats & cultural heritage; waste
  • Abu Dhabi Climate Change Strategy (2024) β€” sectoral net-zero pathways for power, water, oil & gas, transport, buildings, waste, industry
  • TAQA Net Zero by 2050 + ADNOC Net Zero by 2045 (ADNOC accelerated 5 years vs UAE)
  • Masdar (Mubadala-owned) β€” 100 GW renewable capacity globally by 2030

Estidama Pearl Rating System

Authority: Department of Municipalities and Transport (DMT), Abu Dhabi. Mandatory since 2010.

Rating scope

  • PBRS β€” Pearl Building Rating System
  • PCRS β€” Pearl Community Rating System
  • PVRS β€” Pearl Villa Rating System

Rating tiers

1–5 Pearls. New private builds need minimum 1 Pearl; government buildings need 2 Pearl minimum.

5 pillars

  1. Livable buildings, communities
  2. Natural systems
  3. Integrated development process
  4. Water
  5. Energy

Plus Innovating Practice + Materials

Credential: PQP (Pearl Qualified Professional) β€” the licence to do PBRS work for AD projects. Local UAE training (~AED 4–6k); a real CV asset for Abu Dhabi roles.

Al Sa'fat (Dubai Green Building System)

Authority: Dubai Municipality. Launched 2017, fully mandatory 2020.

Tiers

  • Bronze β€” mandatory for all new buildings since 2020
  • Silver, Gold, Platinum β€” aspirational

Free Al Sa'fat manuals available from Dubai Municipality. Local CPDs at Dubai Carbon Centre of Excellence and EmiratesGBC.

Other UAE rules to mention in interviews

Federal Decree-Law No. 32 of 2021 (Commercial Companies Law)

Requires PJSCs to disclose CSR contributions (Article 80).

CBUAE Sustainable Finance Working Group

Principles for Effective Management of Climate-related Financial Risks (Nov 2023). Banks must integrate climate risk into ICAAP/ILAAP from 2024.

UAE Sustainable Finance Framework (2023)

Guidance for green/sustainability-linked bonds & sukuk. UAE issued the first sovereign green sukuk in MENA.

DFSA (DIFC)

Voluntary sustainability disclosure regime for DIFC-domiciled funds (2023).

FSRA (ADGM)

Sustainable Finance Regulatory Framework (2023). Mandatory ESG disclosure for ADGM-listed sukuk/bonds claiming green/sustainable label.

National Climate Change Plan 2017–2050

The umbrella climate plan, predates Net Zero 2050. Three pillars: manage GHG emissions, build adaptation capacity, drive green-economy innovation.

Practice Q&A

Q1 Who is the UAE climate regulator and what's the legal basis for emissions reporting? β–Ό

"The federal climate regulator is MOCCAE β€” the Ministry of Climate Change and Environment. The legal basis is Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects, issued August 2024 with enforcement from 30 May 2025, and its executive regulations under Cabinet Resolution No. 67 of 2024. Together they require all public and private entities operating in the UAE β€” including free zones β€” to report Scope 1 emissions annually via the National Registry, develop mitigation and adaptation plans, and access carbon markets through the National Voluntary Carbon Market. Penalties run AED 50,000 to AED 2 million per violation, doubled on repeat. For listed companies there's an additional layer β€” the SCA Sustainability Report, mandatory for all PJSCs without threshold, plus the DFM and ADX disclosure guides aligned with GRI, SASB, TCFD, and ISSB."

Q2 What's the difference between Estidama and Al Sa'fat? β–Ό

"Estidama is Abu Dhabi's mandatory rating system since 2010, run by DMT/UPC. It scores buildings on five pillars β€” livability, natural systems, integrated development, water, energy β€” plus innovating practice and material selection. Buildings are rated 1–5 Pearls; new private builds need minimum 1 Pearl, government 2.

Al Sa'fat is Dubai Municipality's equivalent since 2017, with Bronze mandatory for all new buildings since 2020 and Silver/Gold/Platinum aspirational. In design practice both drive early decisions on orientation, shading, envelope U-value typically <0.32 W/mΒ²K for walls, double-skin glazing, district-cooling connection, low-flow fixtures, greywater reuse, embodied-carbon material selection. Both integrate with LEED β€” most UAE developers pursue dual certification because LEED commands market premium internationally while Estidama/Al Sa'fat are regulatory necessities."

Q3 How does UAE position vs CSRD? β–Ό

"The UAE has not adopted CSRD-equivalent mandatory disclosure for domestic companies β€” disclosure is governed by SCA, DFM/ADX, and the Decree-Law 11/2024. However, any UAE company with EU subsidiaries or branches above the CSRD thresholds is in scope of ESRS. The thresholds: large EU undertakings meeting two of three (>250 employees, >€50m turnover, >€25m balance sheet); listed SMEs; and the non-EU parent regime β€” €150m EU turnover plus an EU branch >€40m or a qualifying EU subsidiary, reporting under ESRS for non-EU groups, due FY2028 reporting in 2029.

Concretely affected: DP World (€150m+ EU turnover via terminals), Emirates NBD, Aldar, Mubadala, ADQ. The Omnibus Simplification Package adopted April 2025 postponed Wave 2 by two years to FY2027 and proposed raising the employee threshold to >1,000."

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Cheat sheet β€” memorise these 6 numbers
  • 30 May 2025 β€” Decree-Law 11/2024 enforcement starts
  • AED 50,000 – AED 2,000,000 β€” penalty range
  • 47% by 2035 β€” UAE NDC vs BAU (updated July 2024)
  • 14 GW β€” clean energy target by 2030
  • AED 600 billion β€” Net Zero 2050 investment
  • Zero β€” SCA threshold (all listed PJSCs report)