GHG Reporting in Abu Dhabi: The Complete MRV Guide Under UAE Federal Law No. 11 of 2024
By Danushka Prabhad, Senior Sustainability Consultant | Published March 2026
Introduction
The regulatory landscape for businesses operating in the UAE has fundamentally shifted. On 30 May 2025, Federal Decree-Law No. (11) of 2024 came into force, making the UAE the first country in the MENA region to enforce climate-related corporate accountability through legislation. This is not a distant compliance exercise — it is an active legal obligation with teeth.
For companies in Abu Dhabi, the stakes are particularly high. The emirate has moved ahead of the federal curve by launching its own dedicated Measurement, Reporting, and Verification (MRV) system, administered by the Environment Agency – Abu Dhabi (EAD). Understanding how these two frameworks interact — and acting on that understanding before deadlines arrive — is now a board-level priority.
This guide breaks down everything your business needs to know about GHG reporting in Abu Dhabi: the legal foundations, who is covered, how the MRV system works, and what compliance looks like in practice.
What Is the Abu Dhabi MRV System?
The Environment Agency – Abu Dhabi (EAD) has launched an international standard carbon Measurement, Reporting, and Verification (MRV) programme as a pivotal step towards addressing carbon emissions in the emirate.
The MRV system is a structured, facility-level framework that requires covered industrial operators to monitor their greenhouse gas emissions throughout the year, compile those figures into a standardised report, and submit that report for independent third-party verification. As Dr. Shaikha Al Dhaheri, Secretary-General of EAD, has stated, the programme integrates new mandatory MRV efforts into Abu Dhabi’s broader carbon accounting framework as part of national pathways towards Net Zero by 2050.
The system is designed to standardise and strengthen the reporting of greenhouse gas (GHG) emissions across Abu Dhabi’s industrial and energy sectors, aligning local efforts with global best practices, to drive international competitiveness, manage long-term GHGs, and foster technical innovation at the forefront of the global climate change agenda in the region.
Critically, the Abu Dhabi MRV programme is also designed as a stepping stone toward a domestic carbon pricing mechanism — meaning the data you report today will likely inform future financial obligations.
UAE Federal Decree-Law No. 11 of 2024: An Overview
This legislation positions the UAE as the first country in the Middle East and North Africa region to establish a binding legal framework for climate action, aligning with its Net-Zero by 2050 Strategic Initiative and its commitments under the Paris Agreement.
The law’s core obligations are clear and non-negotiable: all public and private sector entities must measure, report, and actively manage their greenhouse gas emissions. The Climate Change Law was issued on 28 August 2024, came into force on 30 May 2025, and requires full compliance with its provisions by 30 May 2026.
The law establishes a system of financial and administrative penalties for non-compliance. Entities failing to meet the reporting requirements or implement mandated strategies may face fines ranging from AED 50,000 to AED 2,000,000. Repeat violations within a two-year period may result in the doubling of penalties.
In parallel, the government issued UAE Cabinet Decision No. 67 of 2024 concerning the National Carbon Credit Registry, further clarifying programme thresholds, verification procedures, and the scope of carbon credit eligibility.
Who Needs to Report?
One of the most important — and sometimes misunderstood — aspects of the law is its breadth.
Federal Decree-Law No. (11) of 2024 covers all GHG-emitting entities across the public and private sectors, including those operating within free zones, and establishes mandatory obligations for emissions measurement, reporting, reduction, and participation in national climate mechanisms.
At the federal level, this means every business in the UAE has an obligation. At the Abu Dhabi level, the EAD MRV system operates at the facility level within covered sectors. According to the EAD Technical Guidance published via the facilitymrv.ead.ae platform, reporting is obligatory at the Facility level operating in a Covered Sector. The obligation to monitor and report greenhouse gas (GHG) emissions falls on the Operator of the Reporting Facility.
Covered sectors under the Abu Dhabi MRV programme include power generation, oil and gas, industry, and transport. In its first year, the programme collected emissions data representing approximately 90 million tonnes of Abu Dhabi’s CO₂ emissions — the bulk of emissions from major regulated activities across the emirate.
For entities with very high emissions, additional obligations apply at the federal level: large emitters (≥ 0.5 million metric tons CO₂e per year) face accelerated obligations and must register with the new National Register for Carbon Credits (NRCC).
Emission Thresholds and Applicability
Under the Abu Dhabi MRV framework, applicability is determined by a combination of sector classification and facility-level emissions thresholds. Operators whose facilities fall within the covered sectors and breach the relevant thresholds are legally obligated to register, monitor, report, and arrange third-party verification. The EAD Technical Guidance (available via facilitymrv.ead.ae) specifies these thresholds in detail, and the EAD worked closely with public and private stakeholders to calibrate sector-specific requirements before the programme launched.
At the federal level, entities emitting 0.5 million metric tonnes of CO₂ equivalent or more per year are subject to the most immediate obligations under the National Register for Carbon Credits framework.
Businesses uncertain about whether they cross applicable thresholds should conduct a preliminary GHG inventory as a first step — regardless of where they believe they sit relative to thresholds.
Step-by-Step MRV Reporting Process
Understanding the process end-to-end is essential for planning your compliance timeline. Here is how Abu Dhabi’s facility-level MRV reporting works in practice:
Step 1 - Register Your Facility
Operators within covered sectors must register on the EAD’s MRV platform at facilitymrv.ead.ae. Registration captures facility details, sector classification, and key contact information. This is the gateway to all subsequent reporting obligations.
Step 2 - Develop a Monitoring Plan
Before reporting can begin, facilities must establish a documented monitoring plan. This plan identifies all emission sources, the monitoring methodologies to be used (calculation-based or measurement-based), and the data gathering points for each source stream. The EAD Technical Guidance notes that operators should select their monitoring approach and include relevant information for each method, tracing data to facility-level schematics.
Step 3 - Collect Emissions Data
Throughout the calendar year (January to December), operators must collect data on all Scope 1 direct emissions from their facility. This includes fuel combustion, process emissions, and fugitive sources. Emission factors must align with methodologies approved under the Abu Dhabi MRV technical guidance.
Step 4 - Complete the Reporting Template
The EAD provides a standard Excel-based reporting format, available directly from the agency. Operators populate the template with verified activity data, emission factors, and calculated CO₂ equivalent figures for each source stream.
Step 5 - Submit the Emissions Report
Facilities within scope are required to submit emissions data for the January–December 2025 reporting period by 31 March 2026, in accordance with the MRV Technical Guidance issued by the Environment Agency – Abu Dhabi. Current submissions are made via the EAD’s designated channel, with a digital platform under development to streamline future cycles.
Step 6 - Third Party Verification
The MRV emissions programme will require the large carbon emitting facilities to monitor, report and verify by third parties their emissions on an annual basis, with the first reports due in 2026. Verification must be conducted by an accredited third-party body, which independently assesses the accuracy and completeness of the submitted data before it is formally accepted by EAD.
Data Collection and Templates
Accurate data collection is the backbone of any defensible GHG report. Under the Abu Dhabi MRV framework, data quality is non-negotiable — reported figures must be traceable, consistent, and verifiable.
Businesses should establish internal data management systems that capture fuel consumption, electricity usage, process inputs, and fugitive emissions on a continuous basis. Relying on year-end estimates or reconstructed data creates compliance risk and undermines the credibility of your report during third-party verification.
The standard reporting template is available from EAD via the facilitymrv.ead.ae portal. The template is structured to align with the monitoring approaches outlined in the Technical Guidance, and facilities are expected to complete all mandatory fields for each covered emission source.
Importantly, businesses must maintain complete data traceability with detailed documentation of emission factors, calculation methodologies, and data sources. Every figure in your report must be backed by contemporaneous evidence.
Submission and Verification Process
Once the annual report is compiled, the submission and verification process follows a defined sequence. The operator submits the completed report to EAD by the published deadline. An accredited third-party verifier then conducts an independent assessment, reviewing source data, methodology application, and internal controls. Any material discrepancies or data gaps identified during verification must be resolved before the report is formally accepted.
The verification process aligns with internationally recognised standards, including the GHG Protocol and ISO 14064, ensuring that Abu Dhabi’s reported data meets the requirements of the UNFCCC’s Enhanced Transparency Framework under the Paris Agreement. All reported emissions data must undergo accredited third-party verification before submission to regulatory authorities.
Common Challenges in GHG Reporting
Even experienced compliance teams encounter recurring obstacles when implementing GHG reporting for the first time in the UAE context:
Fragmented data systems. Many facilities track fuel, electricity, and process inputs across different departments or software platforms. Consolidating this data into a single, auditable record requires upfront investment in data governance.
Uncertainty around emission factors. The Abu Dhabi MRV Technical Guidance specifies which emission factors to apply, and these may differ from IPCC defaults or international databases. Using incorrect factors — even inadvertently — can result in material misstatements.
Scope of coverage. Determining which emission sources are in scope, particularly for complex industrial sites with multiple process streams, requires careful interpretation of the Technical Guidance and, in some cases, direct engagement with EAD.
Verification readiness. Businesses that have not structured their data collection to support third-party verification often face significant rework during the verification stage. Building verification readiness into the monitoring plan from the outset saves time and reduces cost.
Meeting deadlines under a new system. With the first formal reporting cycle now active, facilities that delayed registration or monitoring plan development are under significant time pressure.
Best Practices for Compliance
Businesses that build their GHG reporting capability systematically — rather than reactively — will navigate this regulatory environment far more effectively. Based on the Abu Dhabi MRV framework and alignment with Federal Law No. 11 requirements, the following practices are strongly recommended:
Conduct a gap assessment early. Map all emission sources against the covered sectors and thresholds before committing to a monitoring plan. This prevents scope errors that are costly to correct post-submission.
Align with recognised international standards. The law consolidates earlier climate, energy efficiency, and sustainability policies into one integrated framework, backed by enforcement mechanisms and aligned with international standards including GHG Protocol, ISO 14064, ISSB, and GRI. Structuring your internal reporting to these frameworks ensures compatibility with both Abu Dhabi and federal requirements.
Appoint a dedicated emissions data manager. A single accountable point of ownership for GHG data collection, quality control, and reporting significantly reduces the risk of errors and gaps.
Engage a third-party verifier early. Do not wait until the report is finalised to involve your verifier. Early engagement allows verifiers to flag methodological issues before they become problems in the submitted report.
Document everything. Maintain records of data sources, measurement instruments, calibration logs, calculation spreadsheets, and any assumptions made. Strong documentation is your first line of defence if your report is queried.
Need Expert Support with GHG Reporting in Abu Dhabi?
Navigating the Abu Dhabi MRV system and ensuring full compliance with UAE Federal Law No. 11 of 2024 requires technical precision, regulatory knowledge, and practical experience. Whether you are building your first GHG inventory, preparing for third-party verification, or developing an emissions reduction strategy, working with specialists who understand the local regulatory environment can make the difference between compliance and costly penalties.
If your business needs professional guidance on carbon emissions reporting UAE requirements, GHG inventory development, or MRV system registration, consider engaging a qualified ESG advisory firm with demonstrated expertise in Abu Dhabi’s regulatory landscape. The compliance deadline is approaching — now is the time to act.
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