Who must register with the UAE's National Register for Carbon Credits, by when, and what the AED 2 million penalties cover — a primary-source guide for GCC institutions.
Cabinet Resolution No. 67 of 2024 created the UAE’s National Register for Carbon Credits and a trading regime that treats verified carbon credits as financial instruments. If your operations clear half a million tonnes of CO₂e a year, registration is not optional — and the penalties for getting it wrong reach AED 2 million.
Key Takeaways
- The threshold that matters: Entities emitting 0.5 million tCO₂e or more per year (Scope 1 and Scope 2 combined) are classified as “Huge Carbon Emission Entities” and were required to register with the National Register for Carbon Credits.
- The deadline has passed: The compliance window for large emitters closed on 28 June 2025. If you are over the threshold and not yet registered, you are already exposed.
- Free zones are in scope: The Resolution applies across the UAE, including financial and non-financial free zones. A Meydan, DMCC, or JAFZA address is not an exemption.
- Credits are financial instruments: Once verified, carbon credits are traded on platforms regulated by the Securities and Commodities Authority — a separate regulator with its own penalty powers.
What Cabinet Resolution 67 Actually Does
On 28 June 2024, the UAE Cabinet issued Cabinet Resolution No. 67 of 2024, establishing the National Register for Carbon Credits (NRCC). Under Article 19, it came into force six months after publication — 28 December 2024. Its stated objective is narrow and concrete: reduce greenhouse gas emissions toward the UAE’s 2050 climate-neutrality target, and regulate the registration and trading of carbon credits.
This is the market-facing half of the UAE’s climate architecture. It sits alongside Federal Decree-Law No. 11 of 2024 (the Climate Change Law), which handles the broader measurement-and-reporting mandate. The two are easy to conflate and should not be — they have different thresholds, different deadlines, and different triggers. This article covers the Resolution; the Decree-Law is covered separately.
Who Is Caught: The 500,000 Tonne Line
The Resolution divides the world into two groups.
Entities of Huge Carbon Emissions are those whose annual emissions equal or exceed 0.5 million metric tonnes of CO₂ equivalent, measured across Scope 1 (direct) and Scope 2 (indirect, purchased energy) within the State. For these entities, registration was mandatory. In practice this captures power generation, oil and gas, cement, steel, aluminium, aviation, and major utilities.
Participating Entities are those below the threshold. They may register voluntarily — and there is a reason to: registration lets an entity that outperforms its reduction targets generate verified credits and sell them.
Primary source — scope. Article 3 applies the Resolution across the State “including the financial and non-financial free zones.” There is no carve-out for free-zone entities. The 0.5 MtCO₂e threshold is defined in Article 1 and applies to Scope 1 and Scope 2 combined.
A point worth making to any board still treating this as a heavy-industry-only problem: the threshold is the line between mandatory and voluntary registration — not the line between “in scope” and “ignore it.” A mid-sized entity well under 500,000 tonnes still has obligations under the parallel Climate Change Law. The Resolution simply adds an accelerated, market-linked layer on top for the largest emitters.
The Compliance Obligations
For entities caught by the Resolution, the duties are specific.
Register with the NRCC. Submit a valid commercial or industrial licence, basic enterprise and facility data, and the procedures in place to reduce GHG emissions at each facility (Article 6).
Operate an MRV system. Maintain monitoring, reporting and verification covering the seven greenhouse gases named in the Resolution — CO₂, CH₄, N₂O, HFCs, PFCs, SF₆ and NF₃ (Article 4).
Get verified by an approved agency. Reduction reports must be audited against ISO 14065:2021, with the verifier holding scope approval under ISO 14064 or ISO 14067 and accreditation under ISO 17029 or 17065. Critically, the verifier must be authorised by the Ministry — a self-declared or generically accredited verifier is not sufficient (Article 4).
Report annually. GHG emission reports go to the Ministry and the competent authority in the relevant emirate every year.
Primary source — the reporting form. Annex No. 1 of the Resolution sets out the GHG inventory form. It requires Scope 1 and Scope 2 emissions broken down by gas (CO₂, CH₄, N₂O, HFCs, PFCs, SF₆), a declared baseline year, the consolidation approach used (operational control, financial control, or equity share), and a list of all legal entities or facilities in which the reporting company holds control or equity. Scope 3 disclosure is requested but optional.
An Unresolved Boundary Worth Watching
Annex No. 1 introduces a genuine ambiguity that the Resolution does not resolve. It permits consolidated submissions and requires emissions to be broken down by country, and asks for an organisational plan covering subsidiaries where the parent does not itself report. That structure hints at foreign-subsidiary inclusion — but the Resolution never explicitly mandates reporting emissions from operations outside the UAE.
For a GCC group with international operations, this is not academic. Whether NRCC reporting stops at the UAE border or follows the consolidated group is precisely the kind of question that determines the size of your inventory. The honest answer today: it is unsettled, and the implementing regulations meant to clarify it have not yet been published. Plan for the broader interpretation; confirm before you file.
Carbon Credits as Financial Instruments
This is where the Resolution becomes unusual. Under Article 9, carbon credits issued by the NRCC are treated as financial instruments when traded within the State. That pulls a second regulator into the picture.
The Securities and Commodities Authority (SCA) licenses and supervises the trading platforms, regulates listing, clearing, settlement and transfer of ownership, and investigates violations. Entities of huge carbon emissions may buy credits to offset their emissions; participating entities that hold approved credits may sell them — including, notably, inside financial free zones.
Every disposal must be logged: Article 11 requires a disposal statement recording the quantity of credits, the buyer, and the selling price, so the register stays accurate.
The Penalties
The Resolution carries two distinct enforcement tracks, and they stack.
Primary source — Annex No. 2 fines (Ministry track). For each of the three core violations — failure to measure GHG emissions, failure to deliver the annual report, and failure to meet Paris Agreement / IPCC reporting requirements — the fines are AED 2,000,000 (first offence), AED 1,000,000 (second), and AED 500,000 (third or more). A catch-all for “any other provisions” runs at AED 300,000 / 200,000 / 100,000.
Separately, under Article 12(3), the SCA may impose its own penalties for trading-related breaches: a warning, a fine of up to AED 1,000,000, suspension or cancellation of a listing, suspension of the trading platform, or suspension and cancellation of a licensed entity’s accreditation.
The two regimes are not alternatives. A large emitter that both fails to file its inventory and mishandles a credit transfer can face Ministry fines under Annex 2 and SCA penalties under Article 12 — on top of any heavier penalty available under other UAE law.
What Still Isn’t Published
Three things remain outstanding, and it is more credible to name them than to pretend the framework is complete:
- The list of Ministry-authorised verification agencies (deferred to a ministerial resolution under Article 16).
- The fee schedule for credit approval and trading (Article 15, deferred to a Cabinet resolution on the Finance Minister’s proposal).
- The detailed SCA platform-licensing criteria (Article 9 hands SCA the rule-making power; the rules themselves are still emerging).
Until these land, parts of the trading mechanism are operational in law but not yet fully operational in practice. That is a reason to prepare — not a reason to wait.
ESGweise Insight: Verification Is the Bottleneck
In our work with GCC emitters, the single most underestimated requirement is the verifier mandate. Boards assume that any ISO-accredited assurance provider will do. The Resolution is explicit that the verifier must be authorised by the Ministry specifically — and the authorised list is still being formalised. The entities that will struggle in the next reporting cycle are not the ones with weak data; they are the ones who left verifier engagement to the last quarter and discovered the approved-provider pool is thin.
If you are over the 0.5 MtCO₂e threshold, treat verifier selection as a procurement lead-time problem now, not a compliance formality later. And if you are below the threshold, the voluntary-registration route is worth modelling — for an entity that genuinely outperforms its reduction trajectory, the credits are a revenue line, not just a compliance cost.
Where This Sits in the Bigger Picture
Cabinet Resolution 67 is one of three layers UAE entities need to hold separately in mind. The federal Climate Change Law (Federal Decree-Law 11 of 2024) sets the universal measurement-and-reporting mandate with its own 30 May 2026 deadline. The National MRV system and the IEQT platform at mrv.ae is the federal tool through which emissions are actually reported. This Resolution adds the carbon-credit register and trading regime on top.
Getting the inventory, the verification, and the registration right across all three is where most of the practical risk lives.
Is your organisation over the 0.5 MtCO₂e threshold — or close enough that you need to know? ESGweise provides MOCCAE-aligned verification and assurance and GHG inventory and reporting support for GCC institutions. [email protected] for a scoping conversation.