Updates, deadlines and latest insights in the UAE’s Climate Policy Framework

As the UAE’s climate policy framework rapidly matures, 2024 and 2025 have ushered in a transformative era for environmental compliance, affecting not just traditional heavy emitters but an expanding spectrum of industries. The introduction of Federal Decree-Law No. 11 of 2024 and Cabinet Resolution No. 67 of 2024 marks a decisive pivot toward comprehensive greenhouse gas (GHG) regulation, with new obligations for measurement, reporting, and risk disclosure now reaching finance, insurance, and healthcare as well as energy, construction, and manufacturing.

The Expanding Scope of UAE Climate Law

The regulatory landscape has fundamentally shifted. Federal Decree-Law No. 11 of 2024, effective since 30 May 2025, mandates all UAE businesses, including those in free zones, to implement GHG emissions reporting, set reduction targets, and develop climate adaptation plans. Cabinet Resolution No. 67 of 2024, in force since 28 December 2024, establishes the National Register for Carbon Credits, with a final compliance deadline of 28 June 2025 for high-emission entities. These rules now require not just annual reporting but also verified data submission to the Ministry of Climate Change and Environment (MOCCAE), leveraging MRV (Measurement, Reporting, Verification) systems aligned with international standards.

Understanding GHG Emissions and Their Regulatory Centrality

At the heart of these new requirements is the concept of GHG emissions—gases such as carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), and fluorinated gases that trap heat in the atmosphere and drive climate change. These emissions are generated by a range of human activities, from burning fossil fuels to agriculture and industrial processes. The UAE’s climate laws place GHG management at the center of compliance, requiring organizations to not only measure and report emissions but to proactively reduce them in alignment with the UAE Net Zero 2050 strategy and Paris Agreement commitments.

Reporting, Verification and Penalties

Businesses are now compelled to adopt robust MRV systems for annual GHG emissions tracking and to participate in the National Register for Carbon Credits if they exceed the 0.5 million metric tons annual emissions threshold. Non-compliance carries significant risks: fines can reach AED 2 million for late or missing reports, with repeat offenders facing doubled penalties and operational restrictions. False reporting or failure to register under the carbon credit regime can result in fines up to AED 1 million.

Strategic Alignment and Incentives

These regulations are not isolated measures, they are designed to support the UAE’s broader sustainability agenda, including the Green Agenda 2030 and Energy Strategy 2050. The legal framework also promotes the development of a voluntary carbon market and offers potential incentives such as tax breaks for renewable energy adoption and the ability to generate revenue through carbon credit trading. Early compliance can enhance ESG ratings and open doors to green finance and investment opportunities.

Sectoral Impacts: Finance, Insurance, and Healthcare in Focus

While energy, construction, and manufacturing remain high-risk sectors, the most notable regulatory evolution is the emerging focus on finance, insurance, and healthcare. The rationale is clear: climate-related risks are systemic and can threaten financial stability, operational continuity, and regulatory compliance across the economy.

Finance

Banks, investment firms, and asset managers must now integrate climate-risk management into their governance structures and risk frameworks. Disclosure of climate-related financial risks and sustainability strategies is required, following global standards such as the Task Force on Climate-related Financial Disclosures (TCFD). Reporting extends to the climate impact of lending and investment portfolios, promoting transparency and sustainable finance.

Insurance

Insurers are expected to assess and disclose climate risks in both underwriting and investment activities, report the carbon footprint of their products, and set clear climate-risk management targets. This compels the sector to refine risk models and adapt business practices to the new regulatory environment, ensuring resilience and regulatory compliance.

Healthcare

Hospitals, clinics, and pharmaceutical companies must measure and report GHG emissions, assess climate-related risks (such as supply chain vulnerabilities and extreme weather impacts), and develop resilience strategies. Compliance is not just about meeting legal obligations—it is about safeguarding operational continuity and demonstrating commitment to national sustainability goals.

Preparing for Compliance: Immediate Actions

With the compliance deadline for the National Register for Carbon Credits set for 28 June 2025, and GHG reporting now mandatory, businesses must act swiftly:

• Conduct comprehensive GHG audits using established protocols.
• Implement MRV systems for real-time emissions tracking.
• Engage ESG consultants to develop reduction strategies and ensure compliance.
• Register in the National Carbon Register promptly to avoid penalties1.

Risks, Rewards, and the Path Forward

The benefits of compliance are substantial—improved access to green finance, enhanced reputation, and industry leadership. The risks of non-compliance, however, are equally significant: financial penalties, regulatory sanctions, and reputational damage. For finance, insurance, and healthcare, the new climate laws are a call to action to embed climate-risk management and transparent reporting into core business strategy.

Accessing Guidance and Support

Official templates, MRV manuals, and sector-specific checklists are available through the MOCCAE Portal and the Environment Agency – Abu Dhabi (EAD). For organizations seeking tailored compliance guidance, Yungo Law offers comprehensive legal services, including contract drafting, compliance audits, and ongoing advisory support to navigate this evolving regulatory landscape.

Conclusion

The UAE’s latest climate regulations represent a watershed moment in the nation’s sustainability journey. By extending rigorous GHG reporting and climate-risk disclosure requirements to a broader range of sectors, the UAE is setting a new standard for climate governance in the region. Businesses that respond proactively will not only mitigate risk but also position themselves at the forefront of the transition to a low-carbon, resilient economy.

For further details or bespoke legal advice on UAE climate law compliance, contact Clotilde Iaia at Yungo Law ([email protected]). Immediate action is recommended to meet the fast-approaching compliance deadlines and secure your organisation’s future in a rapidly changing regulatory environment.