Complete Guide: Completing Your UAE Carbon Footprint (UAE Climate Law + CSRD)
Federal Decree-Law No. 11 of 2024 has been in force since 30 May 2025. More than a year after coming into effect, and now that the first full compliance deadline (30 May 2026) has passed, French and European groups with subsidiaries in the United Arab Emirates face a concrete reality: managing two regulatory obligations simultaneously . the UAE Climate Law on the Emirati side, the CSRD on the European side . with overlapping timelines and local teams that are often starting from scratch.
This guide details the five steps to producing a carbon footprint that complies with both frameworks, covering the specificities of the Emirati context (energy mix, air conditioning, free zones) and the precise points where AI reduces workload without sacrificing traceability.
This guide draws on the official text of Federal Decree-Law No. 11 of 2024, MOCCAE guidelines, and the GHG Protocol and ISO 14064 standards. AI applications are based on documented production use cases, without generalisation beyond validated scope.
Step 1, Define the Scope: Who Is Covered and Key Deadlines
Who Is Within Scope of the UAE Climate Law?
Federal Decree-Law No. 11 of 2024 applies to all public and private entities that generate GHG emissions in the United Arab Emirates, with no size threshold or sectoral exemption. Explicitly included are:
For a European group with a subsidiary in Dubai or Abu Dhabi, whether in a free zone or on the mainland, that subsidiary falls within the scope of the obligation.
The Two Obligation Regimes
Standard regime (all covered entities):
Enhanced regime (entities ≥ 500,000 tCO₂e/year):
This threshold and the associated registration obligation stem from Cabinet Resolution No. 67 of 2024 on the National Register for Carbon Credits (NRCC), a distinct but complementary instrument to Federal Decree-Law No. 11 of 2024. For entities in scope:
For the vast majority of European group subsidiaries, regional offices, commercial entities, logistics hubs, the 500,000 tCO₂e/year threshold does not apply. Industrial subsidiaries (petrochemicals, aluminium, energy production) are, however, directly subject to this enhanced regime.
Timeline and Deadlines, Status as at 2 September 2026
Key point: the full compliance deadline for the first cycle (2025 data) was 30 May 2026, and has now passed. Entities that have not yet completed their GHG inventory are in active non-compliance and exposed to sanctions.
Scoping Checklist
Step 2, Collect Data: Local Sources and AI Time Savings
The Four Priority Emission Sources in the Emirati Context
Data collection is consistently the most time-consuming part of a carbon footprint, even more so for a foreign subsidiary where data does not automatically flow back to the group. In the Emirati context, four sources account for the bulk of emissions for non-industrial entities.
Source 1, Electricity (Scope 2)
Electricity is the primary emission source for offices, hotels, and commercial entities. The UAE energy mix is in transition: the solar share is growing (the Al Dhafra power plant in Abu Dhabi, at 1.5 GW, is among the largest installations in the world), but natural gas remains dominant in electricity generation in Dubai and the other Emirates. The UAE grid emission factor is published by MOCCAE directly in the IEQT. Do not substitute a generic "Middle East" factor.
Data source: DEWA invoices (Dubai) or ADDC/AADC invoices (Abu Dhabi), meter readings, utility APIs where available.
Source 2, Air Conditioning (Scope 1 Fugitive + Scope 2)
Air conditioning structurally accounts for up to 70% of commercial buildings' electricity consumption, according to Dubai Electricity and Water Authority (DEWA) data. Scope 2 emissions are covered through electricity consumption. Scope 1 fugitive emissions, refrigerant leaks from HVAC systems, are the most frequently missing item from first-time UAE carbon footprints produced without local knowledge.
Data source: HVAC maintenance logs (service records, refrigerant top-up quantities, refrigerant type).
Source 3, Air and Sea Freight (Scope 3)
For commercial and logistics subsidiaries, air freight to/from Dubai (DXB and DWC) and sea freight through Jebel Ali (the Middle East's largest port) represent material Scope 3 sources. Scope 3 is not yet mandatory under the UAE Climate Law, but CSRD requires it where these categories are material. Data collection must begin now to avoid gaps in 2027.
Data source: shipping documents, freight forwarder invoices, carrier data (tonne-kilometres by mode).
Source 4, Business Travel and Fleet (Scopes 1 and 3)
Vehicles running on compressed natural gas (CNG) or LPG are common in local transport fleets. Emission factors for these fuels must correspond to local specifications, calorific values and composition can differ from ADEME or DEFRA factors used for European subsidiaries.
Data source: fuel consumption logs, petrol station receipts, HR data for employee air travel.
Where AI Reduces Collection Time
Without a dedicated tool, data collection for a foreign subsidiary takes six to nine months: manual invoice consolidation, translations, supplier follow-ups, file reformatting. With a tool offering automated import and AI mapping capabilities, this timeline falls to a matter of weeks.
In practice, AI addresses three specific friction points:
Automated import and mapping of invoices and supplier files. Uploading CSV or Excel files (DEWA readings, freight invoices, ERP exports) with AI mapping to emission categories eliminates the manual reformatting step.
Automated supplier follow-ups. Rather than manually chasing suppliers for their Scope 3 emission data, an automated follow-up system centralises and tracks exchanges, with response rate monitoring.
Real-time anomaly detection. As data is entered, an anomaly detection engine flags outliers, an unusually high electricity invoice in a given month, an inconsistent emission factor, a missing data point for a site.
Step 3, Calculate: Scope 1/2/3, Local vs Standard Emission Factors, AI Quality Control
Applicable Scopes and Their Treatment
Scope 1, Direct Emissions
Includes emissions from diesel generators (common in industrial zones or as backup power), natural gas consumption for heating and production, HVAC refrigerant leaks, and fuel consumption from owned fleet vehicles.
Scope 2, Indirect Energy-Related Emissions
Two approaches coexist depending on the reporting recipient:
These two factors may differ. This divergence must be documented and justified in the ESRS E1 report. Kabaun allows separate emission factors to be configured per entity, resolving the issue without maintaining two separate inventories.
Scope 3, Indirect Value Chain Emissions
Not yet mandatory under the UAE Climate Law, but required by CSRD where categories are material. The most frequently material categories for Emirati subsidiaries:
Specific Methodological Gaps in the UAE Context
Emission factors for free zones: some free zones have their own electricity grid or specific supply agreements. The national grid emission factor may not reflect the entity's actual energy mix. Check with the relevant free zone authority whether a specific, documented factor is available.
CNG and LPG in fleet: emission factors for these fuels must correspond to local specifications (calorific value, actual composition), which may differ from standard ADEME or DEFRA factors. Use the ADEME Base Carbone as a starting point, then adjust if local specifications justify it and document the adjustment.
How AI Improves Calculation Reliability
Applying the GHG Protocol to a foreign subsidiary involves recurring error risks: wrong emission factor applied to a site, unconverted unit of measurement (kWh vs MWh, tonnes vs m³), double counting between Scope 1 and Scope 2 for certain sources. Uncertainty analysis quantifies the impact of these errors on the final result. Anomaly detection flags inter-period or inter-site inconsistencies in real time, before the inventory is submitted to the IEQT or sent to the group consolidation team.
Step 4, Report: Dual Format for UAE Climate Law + CSRD
What Each Framework Requires
UAE Climate Law: Scope 3 not mandatory (expected 2027); IEQT platform (mrv.ae) for submission; third-party verification mandatory for large emitters (≥ 500 ktCO₂e); MOCCAE factors from IEQT; Arabic and English via IEQT.
CSRD / ESRS E1: Scope 3 mandatory if material; integrated report (no single platform); limited assurance (then reasonable assurance by 2028); group factor (ADEME, DEFRA, IEA per policy); per consolidation rules (FR/EN).
The Operational Approach to Avoid Duplication of Work
Registering on the IEQT: Practical Points
The IEQT platform (mrv.ae) requires an administrator designation and validation by the competent Emirati authority (DECCA for Dubai, EAD for Abu Dhabi). This validation process can take several weeks. For European groups, the designated IEQT contact must be UAE-resident, confirm with local teams before submitting the access request.
Generating the Two Deliverables
Kabaun generates PDF and Excel reports configured to the required output format, with integrated CSRD/ESRS E1 mapping. For the IEQT declaration, GHG inventory data is exported in the format expected by the platform. Klem, Kabaun's conversational AI assistant, supports local teams in verifying data before submission and flags missing or inconsistent fields.
Step 5, Plan Reductions and Ensure Ongoing Monitoring
What the Law Requires on the Reduction Plan
The UAE Climate Law does not impose a specific reduction framework (SBTi, sectoral net-zero pathway, etc.). It requires a formalised action plan with, for each action: a named owner, a timeline with milestones, and an estimated impact in tCO₂e. This plan must be submitted via the IEQT and updated at each reporting cycle.
Identifying Priority Reduction Levers in the Emirati Context
Building energy efficiency: thermal insulation, high-efficiency HVAC systems, smart controls. The Gulf's climate context makes these investments fast-payback, given structurally high air conditioning consumption, even a marginal improvement in HVAC coefficient of performance (COP) generates significant CO₂ savings.
Renewable energy procurement: the UAE has one of the most intense solar resources in the world (global horizontal irradiance > 2,000 kWh/m²/year). Power Purchase Agreements (PPAs) with local solar producers and UAE renewable energy certificates (I-RECs) are concrete options for reducing Scope 2 emissions.
Freight optimisation: for logistics subsidiaries, a partial shift from air to sea freight, load factor optimisation, and selecting freight forwarders with verified offset programmes are Scope 3 levers worth pursuing.
Ongoing Monitoring: From Annual Exercise to Monthly Management
A carbon footprint produced once a year solely to satisfy the IEQT generates no management value. Monthly or quarterly tracking of key indicators, electricity consumption per site, freight tonnes by mode, detected refrigerant leaks, allows deviations to be caught before they affect the annual result.
Kabaun includes an interactive dashboard and reduction target tracking with configurable alerts on thresholds defined in the reduction plan. Predictive analytics projects the emissions trajectory based on current data, enabling teams to anticipate variances against targets before the year-end close.
AI as a Compliance Accelerator, Summary of Gains
Without an appropriate tool, a carbon footprint for a foreign subsidiary takes six to nine months of work, mobilises two to three internal resources, and produces an inventory with limited traceability.
With a tool that offers AI capabilities suited to this context, the same results are achieved in a matter of weeks, with higher data quality and full audit-ready traceability.
What AI does not replace: validation of local emission factors (which requires methodological expertise), negotiating with suppliers to obtain their primary data, and final inventory sign-off by an expert before submission.
Common Mistakes to Avoid
1. Using a generic emission factor for UAE electricity. The UAE grid factor published by MOCCAE in the IEQT differs from the generic "Middle East" regional factors found in some databases.
2. Omitting refrigerant leaks. Air conditioning is the Scope 1 fugitive source most frequently absent from first-time UAE carbon footprints. Maintenance records are the data source, obtain them before starting the collection phase.
3. Building two separate inventories for the IEQT and CSRD. The GHG Protocol is the common foundation for both frameworks. One inventory, two output formats, this is the only scalable approach.
4. Failing to allow for IEQT validation lead times. Registering on the IEQT platform requires administrative validation by DECCA or EAD, which can take several weeks. The compliance window for the first cycle closed on 30 May 2026: entities that have not yet started this process are already behind and should act immediately to limit their exposure to sanctions.
5. Overlooking free zone specificities. Some free zones have their own electricity grid or specific supply agreements that make the national UAE grid factor inappropriate.
6. Treating Scope 3 as an option to defer. MOCCAE has indicated that Scope 3 will be required from 2027. Retrospectively reconstructing two years of supplier data in 2027 will be significantly more costly than integrating this collection into the current 2025-2026 cycle.
FAQ, Carbon Footprint in the UAE
Does the UAE Climate Law apply to companies in free zones?
Yes. Federal Decree-Law No. 11 of 2024 explicitly covers all entities operating in UAE free zones, without exception. DIFC, JAFZA, Abu Dhabi Global Market, and all other free zones are within scope.
Does a UAE subsidiary of a CSRD-subject group need to produce two separate carbon footprints?
No, provided the organisation is structured correctly. The GHG Protocol is the common framework for both obligations. A single GHG inventory per entity, with emission factors adapted by recipient, avoids duplication of work and year-end figure discrepancies.
Which Scope 3 emissions must be declared in the UAE?
As at September 2026, Scope 3 is not mandatory under the UAE Climate Law. Scopes 1 and 2 constitute the current obligation. MOCCAE has indicated that Scope 3 will be required from 2027, without formal decree at this stage.
Which emission factor should be used for electricity in the UAE?
Use the UAE grid factor published by MOCCAE in the IEQT platform for local reporting. For group CSRD consolidation, document the factor retained by group policy and justify any variance in the ESRS E1 report. Do not apply a generic "Middle East" factor in place of the official MOCCAE factor.
What are the penalties for non-compliance?
Fines range from AED 50,000 to AED 2,000,000 for a first offence. UAE authorities have indicated that enforcement will be strict, with a risk of escalated sanctions for repeat or persistent non-compliance, though no official scale for repeat offences has been made public to date. MOCCAE may also publish the identities of non-compliant entities . a significant reputational risk for listed groups or those active in international trade.
How does air conditioning affect a UAE subsidiary's carbon footprint?
Air conditioning generates emissions at two levels: Scope 2 through HVAC electricity consumption (up to 70% of commercial buildings' electricity use), and Scope 1 fugitive through refrigerant leaks. HVAC maintenance records, refrigerant top-up quantities, fluid type, are the priority data source to obtain.
How long does it take to produce a compliant UAE carbon footprint?
Without an appropriate tool, between six and nine months for a mid-sized subsidiary starting from scratch. With a tool offering automated import and AI mapping capabilities, four to eight weeks for data collection and calculation.
Can AI automatically generate the IEQT report?
AI accelerates collection, mapping, quality control, and output file generation in the required format. Methodological validation, factor selection, scope justification, remains a human step. The report submitted to the IEQT is generated from the centralised inventory in the tool, but signature and responsibility for the declaration rest with the designated responsible officer within the entity.
Conclusion
The full compliance deadline for the first UAE Climate Law cycle, 30 May 2026, has now passed. Groups that have not yet completed their GHG inventory for their Emirati subsidiaries are in active non-compliance and should regularise without delay, factoring in IEQT validation delays and the inevitable data back-and-forth with local teams.
The good news: the GHG Protocol as the common foundation for both the UAE Climate Law and CSRD makes it possible to build a single inventory that serves both obligations. Dual compliance does not require double the work, provided the right tool is in place and emission factors are configured by recipient from the outset.
AI accelerates every stage of the process, local data import, mapping, quality control, deliverable generation, without changing the methodological responsibility that remains with the team. The difference between six to nine months of manual work and a matter of weeks with an appropriate tool essentially comes down to this automation layer.
Kabaun is built to manage both frameworks simultaneously within a single carbon footprint: GHG Protocol engine, multi-entity and multi-site management, entity-level emission factor customisation, integrated CSRD/ESRS E1 reports, multi-format exports, immutable audit trail, and Klem to support local teams in verifying data before submission.
Managing UAE subsidiaries and looking to reconcile UAE Climate Law and CSRD in a single tool? Book a call: kabaun.com/contact
Last updated: 2 September 2026.
