Quick Guide: Key Sustainability Disclosure Regimes: Sustainability disclosure regime in the UAE

The UAE has various regulators involved in regulating disclosures on sustainability-related matters, in line with the UAE’s sustainability goals.

The UAE’s Climate Change Law (Federal Decree-Law No.11 of 2024) is a key element of the UAE's Net Zero 2050 Strategy, aiming to drastically reduce greenhouse gas ("GHG") emissions. The Climate Change Law introduces a sector-based framework that mandates businesses to measure, report, and reduce their emissions.

Implementing regulations are expected to be made to supplement the Climate Change Law.

The Ministry of Climate Change and Environment is tasked with establishing a sector-based, national pathway to climate neutrality, under which the Ministry, the Cabinet and relevant local authorities will determine annual targets for emissions reduction. The Ministry is expected to issue regulations regarding sectoral adaptation plans for the infrastructure, energy, environment, health and insurance sectors (together with other sectors that may be identified by the Ministry in the future). 

Companies in the UAE engaged in activities that result in GHG emissions.

This includes public companies (whether listed or unlisted) and private companies operating onshore in the UAE and in the free zones. 

Government-owned companies are also within scope. 

There is no exemption for small and medium sized enterprises, and there is no de minimis emissions threshold.

The Climate Change Law came into force on 30 May 2025, and businesses affected by the Climate Change Law must comply with their obligations by 30 May 2026, marking the end of the one-year transition period. 

The Government retains the discretion to extend this transition period by an additional year.

For the first time, businesses have mandatory legal obligations to reduce emissions using the following means (the Government may add other means in the future):

• 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

Businesses must regularly measure and report on their emissions, current and planned emission reduction measures and their expected results via a new online platform to be set up by the Ministry of Climate Change and Environment. 

Under new record keeping obligations, businesses must hold records of emissions measurements for a period of five years from the date of analysis.