Sustainability Services

UAE sustainability compliance, built around real deadlines

Sustainability in the UAE has moved from voluntary CSR to binding regulation — and it isn't just one law. Two separate compliance frames apply depending on what kind of entity you are, and they can both apply to the same organization at once: one binds every entity in the UAE through federal climate law, the other binds listed and regulated entities through capital-markets ESG disclosure rules.

RSM Dahman's Sustainability Services team helps you work out which frame or frames apply to your organization, builds the services to close each gap, and gives you a self-assessment checklist to track your own readiness against real deadlines.

Independent Firms
0+
Countries
0
Max Climate Law Penalty
AED 2M
Local Presence
UAE

Note: the AED 2M figure is the upper end of the fine range under Federal Decree-Law No. 11 of 2024 for non-compliance with UAE GHG reporting requirements — a regulatory figure, not an RSM fee or estimate.

Regulatory Frames

Two ESG Compliance Frames Under UAE Law

UAE sustainability regulation isn't a single law — it's two separate compliance frames that can both apply to the same organization at once. Frame 1 binds every entity in the UAE outright. Frame 2 layers on top of it for listed and regulated entities. Knowing which frame(s) apply to you is the first step; the services below are built around exactly what each one requires.

Frame 1All Entities

Law

Federal Decree-Law No. 11 of 2024 (UAE Climate Change Law)

Applies to

Every public and private entity in the UAE, including free zones — regardless of size or sector

Requires

GHG measurement & reporting, emissions reduction plans, 5-year recordkeeping, alignment with MOCCAE's annual targets

Key dates

Effective 30 May 2025 · full compliance required 30 May 2026

Penalty

AED 50,000–2,000,000, escalating for repeat or evasive non-compliance

Our services for this frame

■     GHG inventory and measurement

■     MOCCAE-aligned emissions reduction plans, including sector-aligned decarbonization roadmaps under Net Zero 2050

■     Five-year recordkeeping systems

■     Readiness assessment ahead of the 30 May 2026 deadline

■     Support liaising with MOCCAE's reporting platform

Frame 2Listed & Regulated Entities

Rules

SCA ESG Disclosure Guidance; ADX & DFM listing rules; ADGM Sustainable Finance / ESG Disclosures Framework

Applies to

Companies listed on ADX or DFM; ADGM entities with turnover over $68M, or FSRA-licensed fund managers with AUM over $6B

Requires

Annual sustainability report (GRI/SASB-aligned) covering E, S & G metrics and climate risk; board/governance disclosure

Key dates

ADX/DFM — within 90 days of year-end or before the AGM, whichever is earlier · ADGM — from year 3 of incorporation

Consequence

Enforcement action by the relevant exchange or regulator — specific fine schedule not itemized publicly the way the Climate Law's is

Our services for this frame

■     Annual sustainability report preparation (GRI/SASB-aligned) for ADX/DFM-listed entities

■     Filing within the 90-day/AGM disclosure window

■     ADGM ESG Disclosures Framework compliance for qualifying entities

■     Board and governance disclosure support

■     Climate-risk assessment and ESG ratings/investor-narrative readiness

Compliance Checklist

Build Your UAE ESG Compliance Assessment

Start with the checklist for the frame(s) that apply to you. Anything you can't tick confidently is where an assessment should start.

Frame 1 — All Entities

UAE Climate Change Law (Federal Decree-Law No. 11 of 2024)

☐     Do you know which of your operations and free-zone entities fall under the Climate Law? (All of them do — there's no size or sector exemption.)

☐     Have you started measuring your organization's greenhouse gas emissions, at minimum Scope 1 and 2?

☐     Do you have a documented emissions reduction plan aligned with MOCCAE's annual targets?

☐     Is there a system in place to retain GHG records for at least five years?

☐     Has someone inside the organization been assigned ownership of Climate Law compliance?

☐     Are you on track to be fully compliant before 30 May 2026?

☐     Do you understand your exposure under the AED 50,000–2,000,000 penalty range if you're not?

Frame 2 — Listed & Regulated Entities

SCA / ADX / DFM / ADGM disclosure rules

☐     Is your company listed on ADX or DFM, or registered with ADGM above the relevant turnover/AUM thresholds?

☐     Do you currently publish an annual sustainability report?

☐     Is that report aligned with a recognized framework such as GRI or SASB?

☐     Does it cover environmental, social, AND governance metrics — not just one?

☐     Do you file within 90 days of year-end or before your AGM, whichever is earlier?

☐     (ADGM entities) Are you preparing for ESG Disclosures Framework obligations starting your third year of incorporation?

☐     Does your board formally review and sign off on ESG disclosures before filing?

How to Use This Checklist
Any item you can't answer with a confident "yes" is a gap worth closing before your next filing or the 30 May 2026 deadline. Treat the unchecked items as a punch list — then get in touch and we'll turn it into a scoped readiness assessment.
Why RSM

Why Choose RSM UAE?

RSM Dahman combines regulatory fluency with practical, on-the-ground experience helping UAE organizations meet real compliance deadlines. Expand each reason below.

Direct experience with the UAE Climate Law. Why it matters —
We help clients build GHG measurement and reduction-plan processes ahead of the 30 May 2026 compliance deadline, so the shift from voluntary to mandatory reporting doesn't catch you off guard.
Fluency across SCA, ADX, DFM, and ADGM disclosure regimes. Why it matters —
Whether you're a listed entity filing within the 90-day window or an ADGM-registered fund manager meeting the ESG Disclosures Framework, we know which rules apply to you and when.
Sector-specific knowledge across all six Net Zero 2050 focus areas. Why it matters —
Power, industry, transport, buildings, waste, and agriculture each carry different decarbonization levers — we tailor our advice to the sector you actually operate in, not a generic checklist.
Practical support to avoid penalties. Why it matters —
Climate Law non-compliance carries fines of AED 50,000 to AED 2,000,000, with escalation for repeat or evasive offenses — we help you get ahead of the deadline rather than react to it.
Not sure where you stand? Start with the checklist —
Use our self-assessment checklist for both compliance frames to see where the gaps are, then jump to the checklist → or go straight to contact us for a full readiness review.
Get in Touch

Let's get your UAE sustainability compliance on track before the deadlines hit.

Reach our Sustainability Services team directly, or send us a message using the enquiry form below.

Phone

+971 4 554 7423

Email

esg-inquiry@rsm.ae

Location

United Arab Emirates