Federal Decree-Law No. 11/2024 represents the most significant environmental legislation in UAE history. Every mainland company meeting specific thresholds must now report greenhouse gas emissions annually—and the first deadline is approaching fast. This guide breaks down exactly what you need to know and do.
Critical Deadline: May 30, 2026
All eligible UAE entities must submit their 2025 emissions data (Scope 1 + Scope 2) through the MOCCAE Federal Environment Portal by May 30, 2026. No extensions will be granted except for extraordinary circumstances.
What Is Federal Decree-Law No. 11/2024?
Enacted on May 30, 2024, and effective from May 30, 2025, Federal Decree-Law No. 11/2024 establishes the legal framework for climate action across the UAE. It mandates annual greenhouse gas reporting, sets the foundation for future carbon pricing mechanisms, and creates enforcement powers with substantial penalties for non-compliance.
The law aligns with UAE Net-Zero by 2050 Strategic Initiative and positions the Emirates as a regional leader in climate transparency following COP28 Dubai. Unlike voluntary guidelines, this is binding federal law with serious consequences for those who ignore it.
Who Must Report? The Quick Test
Answer YES to ANY of these questions and you must report:
- Do you have 100 or more employees (industrial/manufacturing) or 250+ employees (services/trading)?
- Is your annual revenue AED 5 million or more?
- Do you operate a facility 5,000 square meters or larger?
- Do you run a school with 500+ students?
- Do you operate a hospital with 100+ beds?
- Do you use diesel generators regularly?
- Do you manage hazardous waste or refrigerants?
- Is your contracted power load 15 MW or more?
Important Note
Free zone entities are exempt UNLESS they have mainland operations, waste exceeding 10 tonnes annually, hazardous materials handling, or MOCCAE environmental permits.
What You Must Report: Scope 1 and Scope 2 Emissions
The law requires reporting of two emission categories:
Scope 1: Direct Emissions from Sources You Control
- Company vehicles: Cars, trucks, vans, delivery vehicles burning petrol or diesel
- Diesel generators: Backup power systems and continuous-use generators
- Natural gas combustion: Boilers, heaters, industrial processes
- Refrigerant leaks: HVAC system top-ups (R-410A, R-134a, R-32)
- LPG usage: Cooking equipment, heating, industrial processes
Scope 2: Indirect Emissions from Purchased Energy
- Grid electricity: All power consumed from DEWA, ADDC, SEWA, FEWA
- District cooling: Chilled water and cooling services (convert RT to kWh)
- Purchased steam or heat: From external suppliers (rare but must report if applicable)
What’s NOT required for 2026: Scope 3 emissions (employee commuting, business travel, purchased goods, waste) are NOT mandatory for most organizations in the first reporting cycle. Focus your effort on Scope 1 and 2 only.
Penalties for Non-Compliance
The law establishes severe financial consequences for violations:
| Violation Type | Fine Range | Additional Consequences |
|---|---|---|
| Missed deadline | AED 50,000 base fine | Mandatory resubmission, audit risk elevation |
| Incomplete/rejected submission | AED 50,000–150,000 | Escalated regulatory scrutiny |
| False or misleading data | AED 200,000–500,000 | Potential license suspension |
| Repeat violations | Up to AED 2,000,000 | Third offense triggers license review |
Beyond fines: Non-compliant organizations face indirect costs including higher bank interest rates (0.5–1.2% premium), disqualification from government tenders, loss of supplier qualification with major corporates, increased insurance premiums, and reputational damage.
Your Exact Submission Checklist
Follow these seven steps to ensure compliant submission by May 30, 2026:
Step 1: Register on the Federal Environment Portal (January 2026)
Access the MOCCAE portal at eservices.moccae.gov.ae and complete entity registration. You’ll need your Trade License number, Tax Registration Number (TRN), and authorized signatory details. Registration takes 2-3 business days for approval.
Step 2: Gather 12 Months of Energy Data (February 2026)
Collect all 2025 utility bills showing:
- Electricity consumption in kWh from DEWA, ADDC, SEWA, or FEWA
- District cooling consumption in refrigeration tonnes (RT) or kWh
- Fuel purchase records for diesel generators and company vehicles (litres)
- Natural gas consumption if applicable (cubic meters)
- Refrigerant top-up records from HVAC service logs (kilograms by type)
Step 3: Calculate Scope 1 Emissions Using MOCCAE Factors (March 2026)
Use official MOCCAE v2.2 emission factors (never use global factors):
| Fuel Type | Emission Factor | Unit |
|---|---|---|
| Diesel | 2.683 | kg CO₂e per litre |
| Petrol/Gasoline | 2.392 | kg CO₂e per litre |
| Natural Gas | 1.922 | kg CO₂e per m³ |
| LPG | 1.524 | kg CO₂e per litre |
Calculation example: If you used 5,000 litres of diesel in 2025, your Scope 1 emissions from diesel = 5,000 L × 2.683 kg CO₂e/L = 13,415 kg CO₂e = 13.42 tonnes CO₂e.
Step 4: Calculate Scope 2 Emissions Using UAE Grid Factors (March 2026)
Apply emirate-specific electricity emission factors:
| Utility Provider | Emission Factor |
|---|---|
| DEWA (Dubai) | 0.398 kg CO₂e per kWh |
| ADDC (Abu Dhabi) | 0.392 kg CO₂e per kWh |
| SEWA (Sharjah) | 0.405 kg CO₂e per kWh |
| FEWA (Northern Emirates) | 0.412 kg CO₂e per kWh |
Calculation example: Dubai office consuming 450,000 kWh annually: 450,000 kWh × 0.398 kg CO₂e/kWh = 179,100 kg CO₂e = 179.1 tonnes CO₂e.
Step 5: Download and Complete the Correct Template (April 2026)
MOCCAE provides different templates based on organization type:
- Full Template: Industrial, manufacturing, large commercial (100+ employees)
- SME_Lite: Trading, services, logistics (250+ employees or AED 50M+ revenue)
- Schools_Lite: Educational institutions (500+ students)
Templates are Excel-based with built-in formulas. Input your raw data (kWh, litres, etc.) and the template calculates emissions automatically using correct factors.
Step 6: Upload Supporting Documentation (April 2026)
Scan and upload proof documents including all 12 months of utility bills, fuel purchase invoices, HVAC service records showing refrigerant top-ups, and vehicle registration documents. Files must be PDF format, clearly labeled, and total size under 50MB.
Step 7: Submit Before Deadline (By May 15, 2026)
Submit through the Federal Environment Portal at least 2 weeks before the May 30 deadline to allow time for corrections if rejected. You’ll receive automated email confirmation immediately. MOCCAE reviews submissions within 5-7 business days and issues acceptance or rejection notice with specific reasons.
Common Mistakes That Cause Rejection
Based on 2025 reporting cycle data, these errors account for 78% of rejections:
| Mistake | Why It Happens | How to Avoid |
|---|---|---|
| Electricity data mismatch | Reported kWh doesn’t match utility database | Use exact totals from bills, verify meter numbers |
| Wrong emission factors | Using 2024 or global factors instead of MOCCAE v2.2 | Download latest factors from MOCCAE portal |
| Missing documentation | Incomplete 12-month bill coverage | Request historical bills from utility 2 months before deadline |
| Incomplete entity info | TRN or license number errors | Copy exactly from official documents, no typos |
Time Requirements and Resource Planning
Manual submission timeline:
- Data collection: 6-8 hours
- Emissions calculations: 3-4 hours
- Template completion: 2-3 hours
- Documentation preparation: 1-2 hours
- Total: 12-17 hours
Automated platform timeline: Organizations using purpose-built tools like SafiZero reduce submission time to 2-4 hours through automated bill extraction, pre-populated templates with current MOCCAE factors, and built-in validation that prevents common errors.
What Happens After You Submit?
MOCCAE processes submissions in three stages:
Stage 1: Automated Validation (24 hours). System checks for completeness, verifies calculations, and cross-references electricity data with utility databases. You receive immediate email if basic errors detected.
Stage 2: Technical Review (5-7 business days). MOCCAE specialists examine your submission for accuracy, consistency, and compliance with methodology. They may request clarifications or additional documentation.
Stage 3: Acceptance or Rejection (7-10 business days). You receive official notice. If accepted, you’re compliant for 2026. If rejected, you get specific reasons and 14 days to correct and resubmit without additional fines.
Federal Decree-Law No. 11/2024 marks the beginning of UAE’s transition to comprehensive climate accountability. Organizations that approach the May 30, 2026 deadline proactively—gathering data early, using correct emission factors, and validating calculations—will avoid penalties while building the foundation for future reporting cycles. The law isn’t going away, and requirements will only expand. Start your preparation now to ensure first-time compliance and position your organization as a sustainability leader in the UAE market.
