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The Federal decree has a nationwide scope, affecting governmental, public and private entities, including those within free zones. Under the Cabinet Resolution, entities with a GHG inventory exceeding 0.5 MtCO₂e for Scope 1 and 2 emissions must report their annual GHG emissions, emission reductions and progress in implementing their emission reduction plans. For entities below this threshold, compliance is voluntary.
Businesses are required to establish a GHG Emissions Monitoring and Reporting System, mandating the accounting, reporting and monitoring of their GHG emissions. The new legislation aims to foster the development of GHG management systems in line with international standards such as the GHG Protocol and ISO 14064, as well as the decree’s Monitoring, Reporting and Verification (MRV) framework. Businesses must include at least Scope 1 and Scope 2 emissions, with the intention to eventually report on Scope 3 emissions.
Businesses must act now to develop decarbonization strategies and emission reduction plans, set science-based emission reduction targets, and regularly monitor and report progress to the relevant authorities. These strategies and targets must be in line with the UAE 2050 Net Zero Target and national climate change mitigation plans.
The establishment of a National Carbon Registry, in accordance with Article 6 of the Paris Agreement, enables organizations to register their carbon emission reductions and engage in domestic or international carbon trading. This provides an opportunity to generate revenue, supporting their decarbonization and sustainability initiatives. Moreover, the registry allows high-emitting entities to offset their emissions by purchasing verified carbon credits.
Businesses are required to integrate climate risk assessments and scenario modeling into their decision-making, aligning with global frameworks that advocate for enhanced climate-related financial disclosures to identify and mitigate climate-related risks.
Challenges in the business landscape of the UAE
Noncompliance with the Federal Decree and the Cabinet Resolution will result in administrative fines and penalties for repeated violations. Key penalties include fines for failure to measure GHG emissions, submit annual emissions reports, comply with Paris Agreement reporting requirements and other violations related to the National Register for Carbon Credits.
Beyond the direct penalties, delays in transitioning to low-emission practices pose broader financial and operational risks. These include increased capital costs, reduced competitiveness, indirect financial risks and investor pressure. Non-compliance and delays in adopting low-emission practices carry severe consequences, including escalating fines, increased operational costs, reputational damage and potential loss of market share. Proactive measures to align with federal regulations and sustainable practices are crucial to safeguarding financial stability, ensuring regulatory compliance and maintaining a competitive edge in a rapidly evolving business landscape.
How we can help
EY professionals’ insights in sustainability and climate change will assist entities in MENA to align with the new climate change decree while accelerating their transition to a more sustainable and green business model. The EY CCaSS team in MENA provides tailored solutions to address unique challenges and opportunities, regardless of where the organizations are on their sustainability journey. Leveraging advanced analytics, innovative technologies, and regulatory insights, EY teams help businesses reduce carbon footprints, enhance resilience and achieve long-term sustainability goals.