UAE Climate Law: what Federal Decree-Law No. 11 of 2024 means for SMEs

For most UAE businesses, sustainability reporting used to be voluntary: something listed companies, government suppliers and multinationals did. Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects changed that. It turned measuring and reporting greenhouse gas (GHG) emissions into a legal obligation for a far wider group of organisations.

This guide explains what the law asks for and how a small or growing business can respond without building a large sustainability team.

The key dates

Who it applies to

The law applies to public and private entities whose activities release greenhouse gas emissions in the UAE. Advisers including PwC note that it covers organisations regardless of size or sector, and that free zone entities are included.

In practice, the detailed obligations (reporting thresholds, formats and deadlines) are being set through implementing regulations at federal and emirate level. As of April 2026, Abu Dhabi was the only emirate that had issued a reporting system with thresholds. That means the right first step is to confirm which rules apply in your emirate and sector, rather than waiting for certainty that may take time to arrive.

What the law requires

At its core, the law asks organisations to:

• Measure the emissions their activities produce, regularly and with a recognised method.
• Keep an emissions inventory and the records behind it, so figures can be checked.
• Report periodically, in the format the Ministry of Climate Change and Environment or the local authority specifies.
• Plan reductions, with measures to cut emissions over time.

The law also carries penalties for non-compliance, so treating it as a compliance obligation rather than a branding exercise is the sensible approach.

Where SMEs usually start

Most small and mid-sized businesses already hold the data they need. It is simply scattered across invoices, meter readings and supplier statements. A practical sequence looks like this:

1. Set your boundary. Decide which entities, sites and activities are in scope.
2. Collect Scope 1 and Scope 2 data. Fuel for vehicles and generators, refrigerant top-ups, and electricity and district cooling bills cover most of an SME’s direct footprint.
3. Calculate with recognised factors. Use the GHG Protocol method and documented emission factors so the result can be checked.
4. Assign ownership. Name who collects which data, how often, and who signs it off.
5. Keep the evidence. File the source documents behind every number. Advisers expect auditable record-keeping to be part of the requirement.
6. Agree first reduction actions. Pick a few realistic measures, such as energy efficiency, fleet changes or refrigerant management, and track them.

If you are new to emissions accounting, our guide to Scope 1 and Scope 2 emissions explains the basics.

Common mistakes to avoid

• Waiting for perfect rules. The data you collect now will be needed whatever the final format looks like.
• Estimating without evidence. A figure with no source document behind it is hard to defend.
• Making it one person’s side project. Reporting that depends on one individual stops when they are on leave.
• Treating it as a one-off. Reporting is periodic, so build a simple, repeatable process.

The goal is not a glossy report. It is a system that produces reliable numbers every year with reasonable effort.

How Recall helps

Recall helps organisations set their boundary, collect the right data, calculate Scope 1 and Scope 2 emissions, document the method and build the reporting routine around the business. If you want to understand where you stand, talk to us about an ESG baseline.

This article is general information, not legal advice. Check the current implementing regulations for your emirate and sector.