The UAE carbon register and climate law,
without the jargon

Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects is the Climate Change Law. It entered into force on 30 May 2025 and applies to every “source” of greenhouse-gas emissions in the country, public or private, mainland or free zone. It obliges sources to measure their emissions, keep records for at least five years, report periodically to the Ministry of Climate Change and Environment (MOCCAE) in the form it prescribes, and implement reduction measures.

Cabinet Resolution No. 67 of 2024 concerning the National Register for Carbon Credits created the NRCC. In force since 28 December 2024, it makes registration mandatory for large emitters and for carbon-credit trading platforms, sets an annual verified-reporting duty for them, and provides the register on which carbon credits and their transactions are recorded. It is the market-infrastructure half of the picture.

Tier 1 — 500,000 tCO2e and above: NRCC registration is mandatory

An entity whose combined Scope 1 and Scope 2 emissions reach 500,000 tonnes of CO2-equivalent in a year must register on the NRCC, report annually using Greenhouse Gas Protocol methods, and have that report verified by an accredited third party. Existing entities had until 28 June 2025 to regularise. In the UAE this tier is dominated by power and water, oil and gas, aluminium, steel, cement, petrochemicals and aviation.

Tier 2 — designated sources under the Climate Change Law

The Decree-Law contains no size threshold of its own. Its MRV obligations attach once MOCCAE, or the competent emirate or free-zone authority for climate affairs, designates an entity as a source and tells it what to report, how and by when. Abu Dhabi already runs a facility-level scheme through the Environment Agency for facilities at or above 25,000 tCO2e of Scope 1 emissions a year, on a calendar-year cycle with third-party verification becoming mandatory for 2026 data. Other emirates and free zones are expected to follow with their own designations.

Tier 3 — everyone else

Any business that emits at all is a source in principle, and any entity may register with the NRCC voluntarily. Below the designation line the practical obligation today is to be able to produce a defensible Scope 1 and Scope 2 inventory when a regulator, a lender, a listed customer or an EU importer asks for one. Most will ask before the ministry does.

Much of the market, this site included, described 30 May 2026 as the first compliance deadline under the climate law. That is not what the law says. The Decree-Law gave existing sources one year from its entry into force to adjust their position; 30 May 2026 was the end of that transitional year. It was not a universal annual filing date, and its passing did not create a retroactive reporting obligation for companies that have not been designated.

What the date did do is close the grace period. From here on, a company that is designated as a source is expected to be ready, and a Tier 1 emitter that has not registered on the NRCC is late by more than a year. The correct question for any UAE company now is not “did we miss May 2026” but “which authority designates us, on what cycle, and can we evidence our inventory when it does.”

• Climate Change Law: administrative fines from AED 50,000 to AED 2,000,000 per violation, doubled for a repeat within two years, in addition to any other penalty in other laws.
• NRCC resolution: fines of up to AED 500,000 for a first violation, AED 1,000,000 for a second and AED 2,000,000 thereafter; a trading platform's registration may be suspended or cancelled.
• Records: emissions records must be retained for at least five years and produced on request.

1. Establish which tier you are in, in writing

Compute combined Scope 1 and 2 against the 500,000 tCO2e line; check whether any facility sits in an emirate scheme; ask your free-zone authority whether it has designated sources. Record the answer and its date.

2. Build a Scope 1 and 2 inventory that a verifier would accept

Twelve months of fuel, fleet, refrigerant and process data for Scope 1; metered electricity and cooling for Scope 2; GHG Protocol boundaries; a named owner. The IEQT is the national tool for submission, and its structure is a reasonable template for the inventory itself.

3. Line up an accredited verifier before you need one

Tier 1 reporting is verified by law and emirate schemes are moving the same way. Verifier capacity in the UAE is finite and the first cycle will be crowded.

4. Write the reduction plan the law asks for

The Decree-Law expects sources to implement reduction measures and to report the ones planned and their expected results. Energy efficiency and clean-energy procurement come first; offsetting is a listed measure, not a substitute for the plan.

5. If you buy credits, buy evidence with them

Registry, methodology, vintage, quality rating and a retirement certificate in your organisation's name are what a verifier, an auditor or a customer will ask for. Credits without that trail are a liability on a compliance file.

We do not file reports with MOCCAE, and we are not a verifier. MOCCAE's own guidance and your designating authority's instructions control what you report and when. What we do is supply the part of the compliance file that a register expects to be clean: verified carbon credits from recognised standards, compliance-eligibility mapping on every listing, retirement certificates on demand, and a Carbon Management workspace in which emissions, targets, credits and obligations sit in one place.