Federal Law No. 11 of 2024: A New Era of Climate Responsibility in the UAE
Climate, Energy & Utilities Focus
Andrea Tithecott Partner, Head of Regulatory and Healthcare
Clive DsouzaAssociate,Corporate Commercial
Over the past few years, the UAE has been making significant strides in addressing the global challenge of climate change with the announcement of various initiatives, projects, and hosting of key global conferences such as the COP28 in furtherance of this mission. The latest significant initiative that the country has made in regard to this matter is the issuance of Federal Law No. 11 of 2024 on the Reduction of Climate Change Effects. Through this, the UAE continues to reinforce its commitment to mitigating the adverse impacts of climate change and achieving climate neutrality in furtherance of its Net Zero by 2050 strategy. This law forms part of the country’s broader strategy to meet international climate commitments and strengthen the resilience of its economic and environmental sectors. Central to these efforts are provisions designed to reduce greenhouse gas (GHG) emissions, promote the use of carbon capture technologies, and promote innovation through research and development (R&D).
Federal Law No. 11 of 2024 is a comprehensive framework aimed at reducing the UAE's contribution to global climate change while adapting to its impacts. The law defines key concepts, including climate neutrality, carbon capture, and emissions inventories, creating a foundation for regulating and mitigating GHG emissions. As outlined in Article 2, the law’s objectives include managing national emissions, enhancing ecosystem resilience, promoting sustainable economic practices, and ensuring compliance with international climate change mitigation efforts.
The law also emphasizes the role of the private sector in achieving these goals, encouraging the use of clean technologies and innovative methods to reduce emissions across various industries.
At the core of the law’s strategy for reducing emissions is the introduction of several climate change mitigation mechanisms under Article 4. These include:
Improving Energy Efficiency: Companies are encouraged to adopt practices that enhance energy use efficiency, thereby lowering emissions.
Carbon Capture, Use, and Storage (CCUS): The law specifically promotes and encourages CCUS as a key technology in separating, capturing, and storing CO2 emissions from industrial processes.
Use of Clean Energy: Companies are incentivized to shift to renewable energy sources to power their operations, thereby reducing their carbon footprint.
These strategies are designed to assist various sectors, including industry, energy, and transportation, in achieving the broader goal of climate neutrality.
The law mandates a stringent framework for measuring, reporting, and verifying emissions. Under Article 6, industries must regularly measure their emissions, maintain detailed records, and submit reports to relevant authorities such as the UAE Ministry of Climate Change and the Environment (“MOCCAE”) and relevant local emirate level authorities such as the Environment Agency Abu Dhabi and the Dubai Municipality. This creates transparency but also ensures that companies are held accountable for their climate impact. The MOCCAE, alongside local authorities, will oversee the establishment of an electronic system to track emissions and facilitate compliance across sectors.
Additionally, businesses are required to provide detailed data on their climate mitigation efforts, ensuring that emissions reductions are measurable and verifiable. This stringent reporting mechanism underpins the law's enforcement efforts, ensuring that industries remain committed to their climate obligations.
Federal Law No. 11 of 2024 also introduces a framework for carbon offsetting and emissions trading. As per Article 10, the UAE will establish a National Carbon Credit Registry to track carbon credits and offset projects. This mechanism will allow companies to invest in projects that either reduce or avoid emissions, thereby compensating for their own carbon footprint.
By facilitating carbon offsetting activities, the law encourages industries to take an active role in climate mitigation while providing them with financial incentives to innovate and reduce their emissions.
One of the key pillars of the UAE’s climate strategy is the promotion of research and development (R&D) in climate technologies. Article 2 of the law highlights the need for supporting innovation and developing modern technologies to meet climate change goals. The government aims to encourage private sector participation in this effort, offering incentives for companies that invest in sustainable technologies, particularly in the fields of energy efficiency, carbon capture, and renewable energy.
By fostering a culture of innovation, the law seeks to further improve the UAE’s position as a leader in sustainable development and green technology, further enhancing its competitive edge on the global stage.
In addition to mitigation, the law also focuses on adapting to the inevitable impacts of climate change. Article 7 requires the development of adaptation plans across key sectors, including infrastructure, energy, and health. These plans will assess climate-related risks and outline measures to respond to these risks, ensuring the resilience of the UAE’s economy and infrastructure.
Moreover, the law mandates regular reporting on adaptation efforts, ensuring that all sectors are taking proactive steps to manage climate risks and protect vulnerable communities and ecosystems.
The law includes strict provisions for enforcing compliance. Article 15 outlines penalties for entities that fail to meet the requirements, with fines ranging from AED 50,000 to AED 2 million, depending on the severity of the violation. Additionally, companies that repeatedly violate the law within a two-year period may face doubled penalties under Article 16. These stringent penalties ensure that industries take their climate responsibilities seriously, and that non-compliance carries significant financial consequences.
The UAE’s efforts toward achieving its Net Zero by 2050 strategy are demonstrated through a series of large-scale projects focusing on carbon capture, renewable energy, energy efficiency, and sustainable transportation. ADNOC’s Al Reyadah CCUS Facility captures 800,000 tonnes of CO2 annually and aims to increase this to 5 million tonnes by 2030. The UAE is also exploring Direct Air Capture technologies, further reflecting its ambition to remove CO2 from the atmosphere. In parallel, the government promotes electric vehicle (EV) adoption by offering incentives such as free parking and toll exemptions, reducing emissions from the transportation sector while improving air quality. The Al Dhafra Solar PV project, one of the world’s largest solar plants, will generate 2 GW of renewable energy, supplying electricity to approximately 160,000 households. These initiatives align with the objectives of Federal Law No. 11 of 2024, reinforcing the country’s commitment to climate mitigation.
Energy efficiency is another cornerstone of the UAE’s strategy. Both Abu Dhabi and Dubai have implemented Green Building Regulations, ensuring that new developments meet high energy efficiency standards. Abu Dhabi’s Estidama program focuses on reducing energy and water use, while Dubai’s Al Sa'fat Green Building Standards aim to lower the environmental impact of buildings. Waste-to-energy projects further complement these efforts by addressing landfill waste and generating renewable energy. For example, the Dubai Waste Management Centre will process 1.9 million tonnes of waste annually, generating 200 MW of electricity. These initiatives, supported by the new climate law, create a framework for sustainable development across multiple sectors.
Research and development (R&D) play a pivotal role in driving innovation for long-term climate goals. Institutions like Masdar and Khalifa University lead efforts in developing clean technologies such as hydrogen energy, carbon capture improvements, and solar power advancements. Their research in CO2 mineralization, renewable energy integration, and other sustainable technologies ensures the UAE remains at the forefront of green innovation. By encouraging collaboration between public and private sectors, the UAE aims to scale up these technologies and maintain a competitive edge in the global transition to a low-carbon economy.
Through Federal Law No. 11 of 2024, the UAE has formalized its climate strategy, aligning policy with ongoing initiatives to reduce emissions, promote renewable energy, and improve energy efficiency. The law’s strict reporting requirements and enforcement mechanisms ensure accountability across industries, supporting the broader transition to climate neutrality. With a focus on innovation, strategic investments, and sustainable practices, the UAE is well-positioned to lead the region in environmental stewardship while achieving economic growth. These efforts collectively chart a path toward a future where economic development and environmental responsibility coexist.
For further information,please contact Andrea Tithecott and Clive DSouza.
Published in December 2024
