← Back to Compliance GuideThe Compliance
What the Law
The Eight
The Penalty
All 21 Articles
62
Days to the end of the Article 18 status-adjustment period
AED 2M
Maximum fine for violations of Article 6(1) under Article 15
21
Articles in the Decree-Law, covering mitigation, MRV, adaptation, governance, implementation, and enforcement
How to Read This Overview
Amal distinguishes three layers throughout this overview: what the law directly appears to require, what depends on implementing guidance or legal interpretation, and what Amal recommends as sound readiness practice. These are not the same thing and should not be treated as such. The Arabic text of the Decree-Law prevails in the event of any conflict with the English version. This overview is produced for general information purposes and does not constitute legal advice.
Key Dates
The Compliance
Timeline
✓
28 August 2024
Decree-Law Issued
Federal Decree-Law No. 11 of 2024 signed and issued. Cabinet Resolution No. 67 of 2024, concerning the National Register for Carbon Credits (NRCC), was issued in the same year.
✓
30 May 2025
Decree-Law Entered Into Force
The Decree-Law entered into force on 30 May 2025. Article 6 obligations apply to sources determined by the Ministry and the competent authority, and Article 15 penalties apply to violations of Article 6(1).
!
28 June 2025
NRCC Status-Regularisation Deadline for Existing Huge-Emissions Entities
Cabinet Resolution No. 67 of 2024 entered into force on 28 December 2024. Existing entities of huge carbon emissions were given six months from that date to regularise their status under the Resolution. The Resolution applies to entities with annual Scope 1 and Scope 2 emissions of 0.5 million metric tons CO₂e or more.
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30 May 2026 — 62 days remaining
Article 18 Status-Adjustment Period Ends
Article 18 requires sources subject to the law to adjust their status to comply within one year from the date the Decree-Law entered into force, unless extended by Cabinet resolution. This is the primary legal adjustment horizon referenced in the Decree-Law.
Six Core Pillars
What the Law
Actually Requires
I
Article 4
Climate Change Mitigation
Article 4 requires sources to contribute to reducing emissions toward climate neutrality through one or more of eight recognised means: improving energy efficiency; using clean energy; enhancing and protecting natural carbon sinks; carbon capture, use and storage; using alternatives to saturated fluorocarbons; carbon offsetting; implementing integrated waste management; and other technologies or means determined by the Ministry, competent authority, or entity concerned. The specific obligations attached to each means are subject to implementing resolutions.
Amal's View
Amal's view: Sources should map their operations against the eight categories now, even before implementing guidance is issued. Entities with material exposure in energy, logistics, manufacturing, or real estate should prioritise energy efficiency and clean energy transition as the categories most likely to attract early regulatory attention.
II
Article 6
Measurement, Reporting and Verification (MRV)
Article 6 applies to sources determined by the Ministry and the competent authority, in coordination with the entity concerned. Those sources must measure emissions regularly, prepare an emissions inventory, submit periodic reports, provide activity and reduction-measure data, retain records of measured emission quantities for five years, and allow access to those records by authorised judicial officers during that period. The specific sources, reporting forms, cycles, and thresholds are subject to implementing resolutions. Article 15 imposes fines for violations of Article 6(1).
Amal's View
Amal's view: The absence of a documented GHG inventory is the most common compliance gap we observe. Sources should begin building their Scope 1 and Scope 2 inventory now, using the GHG Protocol as the baseline methodology, and establish data retention systems that meet the five-year minimum under Article 6(1)(c).
III
Article 7
Climate Change Adaptation Plans
Article 7 requires competent authorities, in coordination with the Ministry and the entity concerned, to develop and implement adaptation plans in sectors including infrastructure, energy, environment, health, insurance, and any other sector determined by the Ministry or the competent authority. The extent to which private entities are directly subject to adaptation planning obligations depends on implementing guidance from MOCCAE and emirate-level regulators.
Amal's View
Amal's view: For most private entities, the immediate obligation under Article 7 flows through sector regulators rather than directly from the law. Entities in infrastructure, energy, real estate, and insurance should monitor sector-specific guidance closely.
IV
Article 10
Incentives and Carbon Offsetting Mechanisms
Article 10 empowers the Ministry and competent authority to incentivise sources through mechanisms such as carbon offsetting activities, emissions trading, shadow carbon pricing, and other related policies and mechanisms. It also requires the Ministry to adopt climate-performance indicators for project feasibility studies and provides that the Ministry shall establish and manage the National Carbon Credit Registry. These are incentive and enabling mechanisms, not direct mandates on sources absent implementing determination.
Amal's View
Amal's view: The National Register for Carbon Credits (NRCC), established by Cabinet Resolution No. 67 of 2024, is the primary carbon market mechanism under the law. Sources with significant emissions should understand the NRCC registration process and assess whether voluntary participation in carbon offsetting is strategically appropriate ahead of any mandatory participation requirement.
V
Arts. 14–16
Enforcement and Penalties
Article 14 grants judicial-officer capacity to designated Ministry and competent authority personnel for detecting violations. Article 15 imposes fines of AED 50,000 to AED 2,000,000 for violations of Article 6(1). Article 16 provides that penalties are doubled for repetition of the same violation within two years from the date of the final judgment of conviction, provided the doubled penalty does not exceed AED 4,000,000. Administrative penalties for other violations are to be determined by Cabinet resolution under Article 17.
Amal's View
Amal's view: The explicit fine provision in Article 15 is tied to Article 6(1) — meaning the primary enforcement risk is the failure to measure, report, or retain data as required. Sources that build a credible, documented MRV system before the Article 18 deadline reduce their enforcement exposure materially.
VI
Arts. 5 and 12
National Pathway and NDC Commitments
Article 5 requires the Cabinet to determine annual sectoral emission reduction targets to achieve climate neutrality. Article 12 addresses the approval and periodic review of the UAE's Nationally Determined Contributions under the Paris Agreement. Both provisions create a framework under which regulatory requirements are likely to become progressively more demanding over time — though the pace and scope of that tightening depends on Cabinet and ministerial determination.
Amal's View
Amal's view: The NDC pathway and Article 5 sectoral targets create a ratchet dynamic — the regulatory floor is likely to rise over time. This is Amal's interpretation of the direction of travel, not a direct statutory statement. Sources that treat compliance as a one-time exercise rather than an ongoing programme are likely to face increasing costs as targets tighten.
Article 4 — Mitigation
The Eight
Recognised Means
1
Improving energy efficiency
2
Using clean energy
3
Enhancing and protecting natural carbon sinks
4
Carbon capture, use and storage
5
Using alternatives to saturated fluorocarbons
6
Carbon offsetting
7
Implementing integrated waste management
8
Other technologies or means determined by the Ministry, competent authority, or entity concerned
Articles 15–16 — Penalties
The Penalty
Provisions
Note on Penalty Structure
The Decree-Law specifies a fine range of AED 50,000 to AED 2,000,000 for violations of Article 6(1). It does not itself classify violations into minor, material, or serious categories on the face of the statute. Article 16 doubles penalties for repeat violations within two years from the final judgment of conviction, up to AED 4,000,000. Administrative penalties for other violations are to be determined by Cabinet resolution under Article 17.
AED 50,000 – AED 2,000,000
Base fine range under Article 15
Article 15 imposes fines within this range for violations of Article 6(1). The Decree-Law does not prescribe subcategories of violation on the face of the statute.
Up to AED 4,000,000
Repeat violation rule under Article 16
Article 16 provides that penalties are doubled for repetition of the same violation within two years from the date of the final judgment of conviction, provided the doubled penalty does not exceed AED 4,000,000.
Full Article Reference
All 21 Articles
Summarised
1
Definitions
Establishes the legal definitions for all key terms used in the Decree-Law, including 'source', 'competent authority', 'climate neutrality', 'carbon credits', and 'MRV'.
2
Objectives of the Decree-Law
Sets out the law's primary objectives: achieving climate neutrality, reducing GHG emissions, protecting the environment and public health, and meeting the UAE's international commitments under the Paris Agreement.
3
Applicability
Applies to sources of GHG emissions in the UAE, including natural and legal persons, government entities, and free zone entities. Specific thresholds and categories of sources are subject to implementing resolutions.
4
Climate Change Mitigation
Requires sources to contribute to emission reductions through eight recognised means. The Ministry, competent authority, or entity concerned may determine additional means by resolution.
5
National Pathway to Climate Neutrality
Requires the Cabinet to determine annual sectoral emission reduction targets aligned with the national pathway to climate neutrality.
6
Measurement, Reporting and Verification
Core MRV obligation for determined sources: measure emissions, prepare an inventory, submit periodic reports, provide activity and reduction-measure data, retain records for five years, and allow access by authorised judicial officers. Specific sources, forms, cycles, and thresholds by implementing resolution.
7
Climate Change Adaptation Plans
Requires competent authorities, in coordination with the Ministry and the entity concerned, to develop and implement adaptation plans across designated sectors including infrastructure, energy, environment, health, and insurance.
8
Climate Data and Science
Addresses the Ministry's role in climate data collection, scientific research, and the development of knowledge infrastructure to support the law's objectives.
9
Establishment of Climate Action Boards or Committees
Provides for the establishment of climate action boards or committees to coordinate implementation of the Decree-Law across relevant entities and sectors.
10
Incentives and Carbon Offsetting Mechanisms
Empowers the Ministry and competent authority to incentivise sources through carbon offsetting, emissions trading, shadow carbon pricing, and related mechanisms. Requires climate-performance indicators for project feasibility studies. Provides for establishment of the National Carbon Credit Registry.
11
International Cooperation Mechanisms
Authorises the Ministry to participate in international climate agreements, negotiations, and cooperation frameworks on behalf of the UAE.
12
Nationally Determined Contributions (NDCs)
Governs the preparation, approval, and periodic review of the UAE's Nationally Determined Contributions under the Paris Agreement.
13
International Reports
Addresses the preparation and submission of international climate reports, including those required under the UNFCCC and related frameworks.
14
Capacity of Judicial Officers
Grants judicial-officer capacity to designated Ministry and competent authority personnel for detecting, investigating, and documenting violations of the Decree-Law.
15
Penalties
Imposes fines of AED 50,000 to AED 2,000,000 for violations of Article 6(1). The Decree-Law does not itself classify violations into subcategories on the face of the statute.
16
Repeating the Same Violation
Provides that penalties are doubled for repetition of the same violation within two years from the date of the final judgment of conviction, up to a maximum of AED 4,000,000.
17
Administrative Penalties
Provides that violations subject to administrative penalties, the value of those penalties, the competent authority, the grievance mechanism, and the allocation of penalty proceeds shall be determined by a Cabinet resolution.
18
Adjustment of Status
Requires sources subject to the law to adjust their status to comply within one year from the date the Decree-Law entered into force, unless extended by Cabinet resolution.
19
Issuance of Implementing Resolutions
Authorises the Cabinet and the Ministry to issue the implementing resolutions necessary to give effect to the Decree-Law.
20
Repeals
Repeals any provisions that conflict with the Decree-Law.
21
Publication and Entry into Force
Provides for publication in the Official Gazette and specifies the date of entry into force as one year from the date of publication.
Sources Consulted
Primary LawFederal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects
Primary LawUAE Cabinet Resolution No. 67 of 2024 concerning the National Register for Carbon Credits
FrameworkGHG Protocol Corporate Accounting and Reporting Standard (reference framework, not a source of legal obligation under the Decree-Law)
FrameworkISSB IFRS S2 Climate-related Disclosures (reference framework, not a source of legal obligation under the Decree-Law)
FrameworkTCFD Recommendations and Guidance (reference framework, not a source of legal obligation under the Decree-Law)
GuidanceMOCCAE UAE Net Zero by 2050 Strategic Initiative
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