We’re getting a lot of enquiries about how to comply with UAE carbon reporting requirements ahead of May 2026.
The honest answer is: there is limited publicly available detail on exactly how this will work in practice.
Below we set out the situation as we understand it, and what we recommend doing now.
The two parts to this
There are effectively two pieces of regulation in play:
Cabinet Resolution No. 67 of 2024.
This applies to very large emitters (aviation, oil & gas, power, heavy industry, etc).
In practice, this means that:
emissions measurement and reporting is already being formalised
methodologies and pathways are being defined
engagement is already happening
If this applies to you, you will almost certainly already be dealing with it.
Second, Federal Decree-Law No. 11 of 2024.
This is the one that is likely relevant if you’re reading this.
It creates a legal requirement for organisations in the UAE to measure emissions, maintain records and report emissions when required by the relevant authority.
It also references mitigation and reduction, but does not set out a fully defined “transition planning” requirement.
What remains unclear in practice is likely still being worked through. This includes:
exactly who needs to report, and when
how reporting will be submitted
whether this will be handled centrally or at emirate / sector level
What we expect
The direction of travel is fairly clear:
requirements will be enforced over time
this will start with larger emitters and work down
calculation approaches will be standardised
reporting routes may differ by emirate or sector
There are also strong signals that the supporting systems are still being built out.
So what does May 2026 mean?
The law came into force in May 2025 and included a one-year adjustment period. So May 2026 does matter, but not in the way many consultants are suggesting.
It is a legal deadline — but in practice, it is not a clear, universal submission requirement
It is better understood as the point by which organisations should:
understand what is expected of them
have started aligning to it
not be starting from zero
Our view is that the first enforced submission date for many organisations is unlikely to be immediate, and will follow once requirements and systems are more clearly defined. Reporting is also likely to be retrospective, meaning organisations will need to have data available for the period prior to any submission requirement.
What should you actually do now?
At this stage, we do not recommend jumping straight into a full carbon footprint.
The reason is simple: the detail that drives how emissions are calculated (emissions factors, boundaries, methodology) is still likely to be clarified.
Instead, focus on getting ready.
Before May 2026, you should be able to answer three things:
Who owns this?
Who in your organisation is responsible for carbon reporting and compliance?
Where do your emissions come from?
What activities generate emissions, and how would you quantify them in practice?
Are you set up to do this properly?
What processes, systems, and resources do you need to:
gather data
calculate emissions
stay compliant over time
If you’d like a quick steer
If you’re reading this and thinking “fine, but what do I actually do next?” — that’s exactly where most organisations are.
At Axis Green we run a short Flash Diagnostic designed specifically for this stage.
completed in under two weeks
typically AED 40–50k
focused on giving you a clear, practical starting point
You’ll come out with:
a view of your exposure and where you stand
clarity on what actually matters (and what doesn’t)
a simple, structured plan for what to do next
No long programme, no over-engineering — just enough to get you on the front foot before this becomes enforced.
If you want to sense-check where you are and avoid wasting time going in the wrong direction, get in touch.
