The UAE's carbon credit register: what it means for projects and buyers

Karbuna

Sep 27

3 min read

Updated: 3 days ago

Aerial view of downtown Dubai with the Burj Khalifa

The UAE now has a legal home for carbon credits. Since 28 December 2024, a national register run by the Ministry of Climate Change and Environment has recorded who must report, who holds credits and what those credits represent. For anyone developing or buying credits with a Gulf connection, expectations on quality, documentation and traceability are becoming clearer.

What the register is

The National Register of Carbon Credits was created by Cabinet Resolution No. 67 of 2024. It was issued on 10 June 2024 and came into force on 28 December 2024. The Ministry of Climate Change and Environment (MOCCAE) administers it.

The resolution also treats carbon credits as tradable financial instruments, to be traded only through licensed platforms. The UAE's capital markets regulator has published draft rules for the operators of those platforms. A pilot trading platform run by the Dubai Financial Market was launched at COP28 in late 2023.

The register sits alongside the UAE's first federal climate law, Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects. The law took effect on 30 May 2025, and its first compliance deadline was 30 May 2026. It requires emissions measurement, reporting and verification, reduction plans and climate risk assessments. Fines for a first violation range from AED 50,000 to AED 2 million.

Who it applies to

Entities that emit 0.5 million tonnes of carbon dioxide equivalent or more a year must register. Smaller emitters can register voluntarily. Commentators expect the heaviest early obligations to fall on oil and gas, petrochemicals, energy and utilities, mining, steel and cement.

Registered entities prepare greenhouse gas inventories, have them verified by approved verifiers, and report through the ministry's electronic platform. Supporting data must be kept for at least five years.

What changes for buyers

The climate law allows companies to buy verified carbon credits from domestic or international projects that follow recognised good practice. Three things follow for buyers.

Evidence travels with the credit. When credits sit in a national system, buyers can expect more questions about what they hold and where it came from: the standard, the methodology, the verification and the retirement record.
Quality is no longer a matter of taste. A credit that cannot show independent verification and a clear registry trail is harder to defend in a regulated reporting cycle.
Trading has rules. Because credits are financial instruments, trading runs through licensed venues. That brings market conduct standards that did not apply to informal deals.

What it means for project owners

The register is about UAE entities, but demand from those entities can be met by projects anywhere. For project owners abroad, that means more UAE buyers asking sharper questions, earlier. The projects that answer them well tend to share a few features.

A clean chain from land to credit. Land tenure, carbon rights, the agreements between the parties and the registry account should line up and be documented.
A recognised standard and independent verification. These are the minimum a regulated buyer will expect.
Monitoring that will survive an audit. Field data, remote sensing and reporting cycles designed from the start, not assembled later.
A plan for permanence. Governance and funding that last as long as the project's obligations.

The Article 6 question

The UAE has said it intends to meet its climate commitments primarily through domestic efforts, while keeping the option of cooperation under Article 6 of the Paris Agreement. Its arrangements for authorising Article 6 transfers are still being put in place.

That matters for projects. A credit that a buyer wants to count towards a national target, or that another country wants to use, may need authorisation from the host country and a corresponding adjustment. Project owners who expect this kind of demand should plan for it from the design stage. We will return to Article 6 in a separate article.

Our view

Karbuna is headquartered in the Dubai International Financial Centre. We do not buy, sell or broker carbon credits. Our work is developing and managing projects for their owners, and making sure those projects can stand up to the level of scrutiny that regulated buyers now apply.

A national register raises the bar for evidence. That is good news for well-built projects, and it rewards the careful work done at the start of a project's life.

This article is general information only. It is not legal, financial or investment advice.