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Governance
Federal climate law in force since May 2025, the free zone tax regime as the legislation itself writes it, and and the EU rules relevant to RFNBO claims and EU market access.
Last verified:
Timeline
The regulatory milestones that can be dated to a published source. Note the absence: no hydrogen-specific legislation has been identified, and the entries below record what applies instead.
Hydrogen Leadership Roadmap launched at COP26
Sets export ambition. Widely misquoted as a 25% global market share target; the text says export markets and gives no year.
MOEI / UAE BARQCabinet approves the National Hydrogen Strategy
Still in force unrevised as of August 2026.
UAE CabinetAbu Dhabi Low-Carbon Hydrogen Policy
Issued by the Supreme Council for Financial and Economic Affairs. The DoE's implementing regulatory framework was still not enacted as of February 2025.
Abu Dhabi Media OfficeFederal Decree-Law 11/2024 on climate change issued
Published in Official Gazette No. 782 on 30 August 2024, with a nine-month delay before entry into force.
UAE LegislationCabinet Resolution 67/2024 — National Carbon Credit Registry
Registration duties for emitters above the threshold, and carbon credits treated as financial instruments.
UAE LegislationThe climate law enters into force
Applies to sources across the UAE, free zones included (Article 3). Measurement and reporting duties begin.
UAE LegislationISO 19870-1:2026 published
Replaces the 2023 technical specification for quantifying the greenhouse gas footprint of hydrogen.
ISOTransition period ends for regulated sources
Article 18 gave regulated sources twelve months from entry into force to comply.
UAE Legislation17 entries
In force 30 May 2025
The Decree-Law was issued on 28 August 2024 and published in Official Gazette No. 782 of 30 August 2024. The official legislation portal lists its status as "Active" and records entry into force on 30 May 2025.
Source: UAE Federal Government / Ministry of Climate Change and Environment (MOCCAE) · uaelegislation.gov.ae · 30 August 2024
9months after publication
In force 30 May 2025
Article 21 provides that the Decree-Law "shall ... enter into force nine (9) months after the date of publishing thereof", which produced an effective date of 30 May 2025.
Source: UAE Federal Government / MOCCAE · uaelegislation.gov.ae
In force 30 May 2025
Article 3 states that "the provisions of the present Decree-Law shall apply to sources in the State, including free zones".
Source: UAE Federal Government / MOCCAE · uaelegislation.gov.ae
5years of record retention
In force 30 May 2025
Sources must reduce emissions through energy efficiency, clean energy, carbon sinks, CCUS, waste management or carbon offsetting; measure emissions regularly, keep records for five years and submit periodic reports with activity data. Article 5 requires monitoring and reporting in accordance with methodologies approved by MOCCAE, Article 6(3) mandates verification of the accuracy of emissions data, and Articles 6-7 require climate-risk assessment and adaptation plans.
Source: MOCCAE · uaelegislation.gov.ae
1year from entry into force
In force 30 May 2026
Article 18 requires sources subject to the Decree-Law to adjust their status "within (1) one year from the date of entry into force", giving a compliance deadline of 30 May 2026.
Caveat: Corroborated by PwC Middle East at https://www.pwc.com/m1/en/services/assurance/manage-risk-in-business/uae-climate-change-law.html
Source: MOCCAE · uaelegislation.gov.ae
In force 30 May 2025
Article 10(1) authorises incentive mechanisms including emissions trading and shadow carbon pricing. Article 10(3) states that "the Ministry shall establish and manage the National Carbon Credit Registry".
Source: MOCCAE · uaelegislation.gov.ae
50,000-2,000,000AED
In force 30 May 2025
Article 15 provides that a violation "shall be punished by a fine of not less than AED 50,000 and not more than AED 2,000,000".
Source: MOCCAE · uaelegislation.gov.ae
doubled
In force 30 May 2025
Article 16 provides that the penalties "shall be doubled in case of repeating the same action within a period not exceeding (2) two years".
Source: MOCCAE · uaelegislation.gov.ae
In force 28 December 2024
The Resolution was issued on 10 June 2024 and published in Official Gazette No. 778 of 28 June 2024. It entered into force on 28 December 2024, "after (6) six months from the date of its publication".
Source: UAE Cabinet · uaelegislation.gov.ae · 28 June 2024
In force 28 December 2024
The Resolution applies across the UAE, including financial and non-financial free zones.
Caveat: Corroborated by Reed Smith at https://www.reedsmith.com/en/perspectives/2024/12/new-carbon-credit-law-register-reporting-verification-trading-regime
Source: UAE Cabinet / MOCCAE · uaelegislation.gov.ae
0.5million metric tonnes CO₂e per year
In force 28 December 2024
"Entities of Huge Carbon Emissions" are defined as those whose annual CO₂e emissions "equal to or exceed (0.5) million metric tons annually in the State" (Scope 1 and 2), in both the public and private sectors. Entities below that threshold may register voluntarily as "Participating Entities".
Source: MOCCAE · uaelegislation.gov.ae
6months from enforcement date
In force 28 June 2025
Entities have "six months as of the enforcement date" to regularise their position, giving a deadline of approximately 28 June 2025.
Source: MOCCAE · uaelegislation.gov.ae
2019earliest baseline year
In force 28 December 2024
Monitoring must use IPCC methodologies with a baseline year of 2019 or later. Registered entities submit an annual greenhouse gas report to the Ministry and the competent authority, subject to third-party verification by Ministry-authorised bodies accredited to ISO 14065:2021, ISO 14064/14067 and ISO 17029/17065.
Source: MOCCAE · uaelegislation.gov.ae
In force 28 December 2024
Credits issued by the National Register are "deemed financial instruments traded via carbon credits trading platform in the case trading is in the State", and the Securities and Commodities Authority (SCA) licenses and supervises those trading platforms.
Source: UAE Cabinet / Securities and Commodities Authority (SCA) · uaelegislation.gov.ae
2,000,000AED maximum administrative fine
In force 28 December 2024
Annex 2 sets out administrative fines, with the top tier at AED 2,000,000 for failure to measure greenhouse gas emissions, failure to deliver the annual greenhouse gas report, or non-compliance with Paris Agreement reporting. Other violations attract AED 100,000 to AED 300,000. The SCA may separately impose fines of up to AED 1 million, suspend trading or cancel licences.
Caveat: The first/second/third-offence escalation ordering in Annex 2 could not be reliably confirmed; cite the AED 2 million ceiling rather than an offence-by-offence schedule.
Source: MOCCAE / SCA · uaelegislation.gov.ae
28days minimum objection period
Current
The DoE licensing regime rests on Law No. 11 of 2018 establishing the DoE and Article 84 of Law No. 2 of 1998. Licensable activities are electricity generation, transmission, distribution, supply and storage, water desalination, wastewater, district cooling, petroleum products trading, and renewable and nuclear energy. No hydrogen licence category is listed. Before issuing a licence the DoE must publish notice and allow "a period of not less than 28 days" for objections. The published licensing pages state no processing timeframe.
Source: Abu Dhabi Department of Energy · doe.gov.ae
In force 2021
The UAE issued what it describes as the region's first technical regulation on hydrogen and fuel-cell vehicles, through ESMA, now part of the Ministry of Industry and Advanced Technology. It covers vehicles only, not production, storage or transport infrastructure.
Caveat: The regulation number is not stated on the source page; the date is taken from the page itself.
Source: Ministry of Industry and Advanced Technology (MOIAT) / ESMA · moiat.gov.ae
6 entries
As reported in February 2025, "the UAE lacks comprehensive hydrogen-specific legislation. The Low-Carbon Hydrogen Regulatory Framework remains in draft form since October 2022 and has not been formally enacted into law."
Source: CMS (Expert Guide to Hydrogen, UAE chapter) · cms.law · 11 February 2025
Not enacted as of February 2025
Announced on 22 August 2022, the framework is intended to "define policies, regulations, standards and certifications" and proposes Hydrogen Valleys, Clean Energy Clusters, Low-Carbon Hydrogen Certificates, land allocation by DMT, EWEC procurement, TRANSCO transmission and a Cluster Consumer Supply Tariff. It remained a draft as of February 2025, and it is unclear whether the Abu Dhabi DoE will develop its own certification scheme or join an internationally recognised one.
Caveat: Every element of this framework is a draft proposal; describing Hydrogen Valleys, Clean Energy Clusters or Low-Carbon Hydrogen Certificates as operating today would misstate the legal position.
Source: Abu Dhabi Department of Energy · mediaoffice.abudhabi · 22 August 2022
A published analysis of the strategy records as its ninth key takeaway that a "guarantee of origin certification scheme" and associated technical standards "require further development", with governance sitting with a Federal Hydrogen Committee.
Source: A&O Shearman · aoshearman.com · 21 November 2023
No UAE national low-carbon hydrogen certification scheme has been identified as in force. CMS and A&O Shearman both report that certification is not yet regulated in the UAE, and the IEA policy database contains no UAE hydrogen certification entry.
Caveat: A negative finding: it records that no scheme was located, not that none can exist.
Source: CMS, Expert Guide to Hydrogen (UAE chapter) · cms.law
Pending recognition
CertifHy states that "the Low-Carbon scope of the CertifHy EU Voluntary Scheme is not yet available to the public, as it is currently undergoing recognition by the European Commission". It will apply the methodology of Commission Delegated Regulation (EU) 2025/2359.
Source: CertifHy · certifhy.eu
Principles 2023; taxonomy still in design as of December 2025
There is no binding UAE green taxonomy in force. The UAE Sustainable Finance Working Group issued a "Summary of General Principles for the UAE Sustainable Finance Taxonomy" in 2023 and, in its Fourth Public Statement of 18 December 2025, said it "continues to evaluate the strategic design of a taxonomy tailored to UAE market needs", using a colour-coded (traffic light) system and minimum social safeguards, with emphasis on international interoperability.
Source: UAE Sustainable Finance Working Group (coordinated by ADGM FSRA) · adgm.com · 18 December 2025
11 entries
100% foreign ownership (subject to conditions)
Amendments effective 31 March 2021; positive lists issued by each emirate
Federal Decree-Law No. 26 of 2020, amending Federal Law No. 2 of 2015 on Commercial Companies, "annuls the requirement for commercial companies to have a major Emirati shareholder or agent". The rule is not universal: activities of strategic impact are excluded and require conditions set by the Cabinet, with a Cabinet committee proposing the strategic-impact list. Abu Dhabi identified 1,105 qualifying activities and Dubai permits more than 1,000, excluding seven strategic-impact sectors.
Caveat: Content is well supported, but the cited page still attributes the reform to Federal Decree-Law No. 26 of 2020; the Commercial Companies Law was later reissued as Federal Decree-Law No. 32 of 2021.
Source: UAE Federal Government · u.ae
In force 2021
The Commercial Companies Law was reissued as Federal Decree-Law No. 32 of 2021 on Commercial Companies. Citing only Federal Decree-Law No. 26 of 2020 cites a superseded amending instrument.
Caveat: Verified through third-party legal databases (UNEP LEAP and FAO FAOLEX) rather than an official UAE portal.
Source: UNEP LEAP, citing Federal Decree-Law 32/2021 · leap.unep.org
9%
In force 1 June 2023
Federal Decree-Law No. 47 of 2022 imposes "0% ... on the portion of the Taxable Income not exceeding the amount specified in a decision issued by the Cabinet" and "9% ... on Taxable Income that exceeds" it.
Source: UAE Federal Government / Federal Tax Authority (FTA) · tax.gov.ae
375,000AED
In force January 2023
Cabinet Decision No. 116 of 2022, Article 2(1), provides that "the portion of a Taxable Person's Taxable Income not exceeding 375,000 ... dirhams shall be subject to a 0% Corporate Tax rate". It took effect 15 days after publication on 30 December 2022.
Source: UAE Cabinet · mof.gov.ae · 30 December 2022
0% on Qualifying Income; 9% otherwise
In force 1 June 2023
Article 3(2) applies "0% ... on Qualifying Income" and "9% ... on Taxable Income that is not Qualifying Income under Article 18".
Source: Federal Tax Authority (FTA) · tax.gov.ae
5cumulative conditions
In force 1 June 2023
A Qualifying Free Zone Person must maintain adequate substance in the State, derive Qualifying Income, not have elected standard corporate tax under Article 19, and comply with Article 34 (arm's length) and Article 55 (transfer pricing documentation). The Ministry of Finance adds a requirement to "prepare and maintain audited financial statements".
Caveat: The audited financial statements requirement is stated in Ministry of Finance guidance at https://mof.gov.ae/corporate-tax-faq/ rather than in Article 18(1) itself.
Source: Federal Tax Authority (FTA) / Ministry of Finance · tax.gov.ae
5tax periods at 9%
In force 1 June 2023
Article 18(2) states that a Qualifying Free Zone Person that fails to meet any of the Clause 1 conditions "at any particular time during a Tax Period shall cease to be a Qualifying Free Zone Person from the beginning of that Tax Period". FTA guidance adds "and the four subsequent Tax Periods", so a breach means five tax periods taxed at 9%.
Source: Federal Tax Authority (FTA) · tax.gov.ae · 20 May 2024
5% of total revenue or AED 5,000,000, whichever is lower
In force 1 June 2023
The de minimis requirement is "satisfied where the non-qualifying Revenue ... does not exceed the lower of: 5% of the total Revenue ... or AED 5,000,000".
Source: Federal Tax Authority (FTA) · tax.gov.ae · 20 May 2024
Current
The Ministry of Finance states that "the benefits of the Free Zone Corporate Tax regime expire by no later than the end of the tax incentive period stated in the legislation of the relevant Free Zone, unless such period is extended by means of a Cabinet Decision issued in accordance with Article 18 of the Corporate Tax Law". The FTA states that "the 0% Corporate Tax rate applies for the remainder of the tax incentive period stipulated in the legislation of the Free Zone in which the QFZP is registered".
Source: Ministry of Finance / Federal Tax Authority (FTA) · mof.gov.ae
In force 1 June 2023
Cabinet Decision No. 100 of 2023, which repeals Cabinet Decision No. 55 of 2023 and takes effect from 1 June 2023, defines Qualifying Income. Ministerial Decision No. 229 of 2025, issued 28 August 2025, repeals Ministerial Decision No. 265 of 2023 and re-states the Qualifying Activities list, which includes "manufacturing of goods or materials" and "processing of goods or materials", as well as distribution in or from a Designated Zone and logistics services.
Caveat: Cabinet Decision No. 100 of 2023 is published at https://mof.gov.ae/wp-content/uploads/2023/11/Cabinet-Decision-No.-100-of-2023-on-Determining-Qualifying-Income-for-the-Qualifying-Free-Zone-Person.pdf
Source: UAE Cabinet / Ministry of Finance · mof.gov.ae · 28 August 2025
15%
In force 1 January 2025
Cabinet Decision No. 142 of 2024 introduces a 15% minimum effective tax rate for multinational enterprise groups with consolidated annual revenues of EUR 750 million or more in two of the last four fiscal years, applying to fiscal years starting on or after 1 January 2025. It is a material qualifier on any claim of a 0% tax rate for large groups.
Caveat: Sourced from a professional-services tax alert rather than the official decision text.
Source: EY, citing UAE Cabinet Decision 142/2024 · ey.com
7 entries
3recognised schemes
In force 19 December 2024
Only three voluntary schemes are recognised by the European Commission to certify compliance for renewable fuels of non-biological origin: CertifHy (Commission Decision of 19 December 2024, 2024/3180), ISCC EU (Decision of 12 April 2022 as amended on 19 December 2024, 2024/3176) and REDcert (Decision of 19 December 2024, 2024/3194). All three have global geographic scope, and recognition decisions run for five years.
Source: European Commission · energy.ec.europa.eu · 19 December 2024
10% minimum net GHG reduction
In force 1 January 2024
CORSIA Eligible Fuels comprise sustainable aviation fuel ("a renewable or waste-derived aviation fuel that meets the CORSIA Sustainability Criteria") and lower-carbon aviation fuel ("a fossil-based aviation fuel that meets the CORSIA Sustainability Criteria"). Eligibility requires certification by a Sustainability Certification Scheme approved by the ICAO Council, currently ISCC, RSB and ClassNK. The criteria (4th edition, June 2025) require net greenhouse gas reductions of at least 10% against the baseline plus 13 further sustainability themes. Scheme applications open annually from 1 February to 15 March, with evaluation by the CAEP SCSEG taking around six months.
Caveat: ICAO does not pre-approve fuels by country; certification attaches to individual fuel producers and batches. Default life-cycle emission values are at the 8th edition (November 2025).
Source: International Civil Aviation Organization (ICAO) · icao.int · June 2025
46participants
In force December 2023
Forty-six participants including the UAE declared an intent to work toward mutual recognition of certification schemes, cooperate through IPHE and the Hydrogen TCP, nominate government experts, consider the ISO methodology for determining greenhouse gas emissions associated with the production and transport of hydrogen, and monitor progress annually.
Caveat: This is a declaration of intent. It is not a certification scheme and is not binding.
Source: COP28 Presidency (UAE) · cop28.com · December 2023
In force 13 April 2026
"Hydrogen technologies - Methodology for determining the greenhouse gas emissions associated with the hydrogen supply chain - Part 1: Emissions associated with the production of hydrogen up to the production gate." Published April 2026 at stage 60.60, 126 pages, by ISO/TC 197/SC 1. It replaces ISO/TS 19870:2023 and builds on ISO 14067 and ISO 14044.
Caveat: Parts 2, 3 and 4 remain at DIS stage.
Source: International Organization for Standardization (ISO) · iso.org · 13 April 2026
In force August 2018
"Greenhouse gases - Carbon footprint of products - Requirements and guidelines for quantification", from ISO/TC 207/SC 7. It is a quantification methodology rather than a certification scheme, and states that "carbon offsetting and communication of CFP ... are outside the scope of this document".
Caveat: Currently flagged "to be revised" (stage 90.92).
Source: International Organization for Standardization (ISO) · iso.org
11,000companies certified (ISCC/ISCC PLUS)
Current
ISCC PLUS is a voluntary certification system for the sustainable origin of bio-based and/or circular feedstocks in food, packaging, feed and chemical supply chains, explicitly for biomass not affected by the Renewable Energy Directive. It is distinct from ISCC EU, which is the RED-compliance scheme. More than 11,000 companies in over 100 countries hold ISCC or ISCC PLUS certification.
Caveat: ISCC's own pages are robots-blocked; this description is taken from an accredited certification body rather than from the scheme owner.
Source: DQS, on the ISCC PLUS scheme · dqsglobal.com
70% minimum GHG reduction
In force 1 June 2024
A private, voluntary standard (Version 07/2024, effective 1 June 2024) covering hydrogen and derivatives - synthetic methane, ammonia and methanol - from electrolysis, biomass gasification and biogas reforming. It requires renewable electricity or gas evidenced by guarantees of origin or I-REC, at least 70% greenhouse gas reduction (no more than 28.2 gCO₂eq/MJ for mobility and material use, 24 gCO₂eq/MJ for heating and cooling), and mass-balance or book-and-claim traceability. From 1 January 2026, government-subsidised electricity is ineligible unless obtained through regulated auctions.
Caveat: TÜV SÜD is a conformity-assessment body, not a regulator, and CMS 70 is not an EU-recognised voluntary scheme.
Source: TÜV SÜD (private conformity-assessment body) · tuvsud.com · July 2024
8 entries
18gCO₂eq/MJ grid emission-intensity threshold
In force 10 July 2023
Adopted 10 February 2023, published in the Official Journal on 20 June 2023 and in force from 10 July 2023, it establishes the Union methodology for renewable liquid and gaseous transport fuels of non-biological origin. Article 3 covers direct connection to a renewable installation that came into operation no earlier than 36 months before the fuel facility. Article 4 allows grid electricity to count as fully renewable where the bidding zone's renewable share "exceeded 90% in the previous calendar year", or the zone's emission intensity is "lower than 18 gCO₂eq/MJ" and the producer holds matching PPAs meeting temporal and geographic correlation, or during redispatching-down periods. Article 5 sets additionality rules. Article 6 requires temporal correlation within the same calendar month until 31 December 2029 and the same one-hour period from 1 January 2030, with Member States able to bring the hourly rule forward to 1 July 2027 and a waiver where electricity prices are at or below EUR 20 per MWh or below 0.36 times the allowance price. Article 7 requires geographic correlation. Article 11 exempts installations operating before 1 January 2028 from additionality until 1 January 2038.
Source: European Commission · eur-lex.europa.eu · 20 June 2023
70% minimum GHG saving
In force 10 July 2023
Adopted 10 February 2023, published in the Official Journal on 20 June 2023 and in force from 10 July 2023, it sets a minimum greenhouse gas saving of 70% against a fossil comparator of 94 gCO₂eq/MJ, equivalent to no more than approximately 28.2 gCO₂eq/MJ. The life-cycle scope covers input supply, processing, transport and distribution and combustion, less CCS credits, and excludes machinery manufacture.
Source: European Commission · eur-lex.europa.eu · 20 June 2023
42% RFNBO share of industrial hydrogen by 2030
In force 20 November 2023
RED III raises the binding 2030 EU renewable target to "a minimum of 42.5%" with a collective aspiration of 45%. It requires that "42% of the hydrogen used in industry from 2030 onwards must be in the form of RFNBOs" and 60% of hydrogen consumed in industry by 2035. In transport it sets a 1% RFNBO share of energy supplied by 2030 within a 5.5% combined advanced-biofuel and RFNBO sub-target. It entered into force on 20 November 2023 with a transposition deadline of May 2025.
Source: European Union / European Commission · energy.ec.europa.eu · 20 November 2023
Definitive regime from 1 January 2026
Hydrogen is within the scope of the EU Carbon Border Adjustment Mechanism. Recital 37 states that "the inclusion of hydrogen in the scope of the CBAM is the appropriate means to further foster the decarbonisation of hydrogen". Covered sectors are iron and steel, refineries, cement, aluminium, organic basic chemicals, hydrogen, fertilisers and electricity. The transitional reporting-only period ran to the end of 2025, and the first CBAM declaration, "in respect of the calendar year 2026, should be submitted by 31 May 2027".
Source: European Union · eur-lex.europa.eu
50tonnes annual de minimis (named sectors)
In force 20 October 2025
Adopted 8 October 2025 and in force from 20 October 2025, it introduces a 50-tonne annual mass-based de minimis for iron, steel, aluminium and fertilisers/chemicals, removes the EUR 150 per-consignment threshold, postpones certificate surrender to February 2027 while financial obligations begin on 1 January 2026, allows non-EU importers to designate CBAM representatives, and recognises carbon prices paid in third countries. Electricity and hydrogen carry separate authorisation requirements.
Caveat: It is unclear whether hydrogen benefits from the 50-tonne de minimis; the source does not list hydrogen among the four sectors named. Sourced from a professional-services tax alert rather than the official text.
Source: EY, citing Regulation (EU) 2025/2083 · ey.com
In force 11 December 2025
Adopted 8 July 2025 and in force from 11 December 2025, it supplements Directive (EU) 2024/1788 by specifying a methodology for assessing greenhouse gas emissions savings from low-carbon fuels. It is the EU's low-carbon methodology, as distinct from the renewable (RFNBO) methodology.
Source: European Commission · eur-lex.europa.eu · 8 July 2025
Ongoing
The European Hydrogen Bank is a financing instrument rather than an institution. Its domestic pillar pays a fixed premium per kilogram of certified RFNBO hydrogen produced within the EEA. The international pillar, intended to attract imports, is still being designed: the Commission commissioned studies on import auction models, published in August 2025, and no import auction has launched. A Hydrogen Mechanism for market matching and transparency between European and international suppliers launched in July 2025.
Source: European Commission · energy.ec.europa.eu
1.1EUR billion budget
Auction launched 4 December 2025
Projects must be "located in the EEA" and bidders from third countries cannot participate. The budget is up to EUR 1.1 billion across three topics (EUR 400 million, EUR 400 million and EUR 200 million for maritime), with a bid ceiling of EUR 4/kg, a completion guarantee of 8% of the maximum grant, financial close within 2.5 years and operation within 5 years. By the end of the implementation period, "the total volume of hydrogen produced during the support period achieves at least 70% GHG savings", certified by a third party.
Caveat: Terms and conditions are in draft form; results were expected in Q2 2026.
Source: European Commission / CINEA · climate.ec.europa.eu · 4 December 2025
Figures in circulation, checked
These phrasings circulate widely in sector material about the Emirates. Each is checked against the instrument it purports to describe.
Claim in circulation: “0% Corporate Tax for qualifying entities in free zones for up to 50 years”
What the source actually says: Qualifying Free Zone Persons pay 0% corporate tax on qualifying income and 9% on the rest, subject to substance, transfer-pricing, audit and de minimis conditions. The relief runs for the tax incentive period set in the relevant free zone's own legislation - 50 years, renewable, in some zones - and large multinational groups are separately subject to the 15% Domestic Minimum Top-up Tax from 2025.
Checked against: Ministry of Finance / Federal Tax Authority (FTA) · mof.gov.ae
Claim in circulation: “Licensing procedures for production, storage and transport in 60-90 days”
What the source actually says: No UAE authority publishes a 60-90 day service standard for hydrogen production, storage or transport licensing, and the Abu Dhabi DoE's published licensing regime contains no hydrogen licence category at all. The only published timing rule requires public notice and "a period of not less than 28 days" for objections before a licence is issued.
Checked against: Abu Dhabi Department of Energy · doe.gov.ae
Claim in circulation: “Fast-track permitting for projects >100 MW with guaranteed timelines”
What the source actually says: No UAE federal or emirate instrument creates a fast-track permitting track for hydrogen or renewables above any MW threshold, and no guaranteed-timeline commitment exists. The Abu Dhabi Low-Carbon Hydrogen Policy and Regulatory Framework that would house such a mechanism has been in draft since October 2022. Binding permitting deadlines exist under the EU's RED III, which does not apply in the UAE.
Checked against: CMS (Expert Guide to Hydrogen, UAE chapter) · cms.law
Claim in circulation: “Over 78 Bilateral Investment Treaties in force”
What the source actually says: No reachable source states 78 BITs in force. The Ministry of Finance says the UAE has signed over 100 BITs, without an in-force figure; a practitioner guide gives approximately 111 signed with 38 not in force (about 71 in force); UNCTAD lists 126, a large share of them signed but not in force. Use the signed figure attributed to the Ministry of Finance and avoid stating an in-force count without a dated source.
Checked against: UAE Ministry of Finance · mof.gov.ae
Claim in circulation: “Direct enforceability in 71 jurisdictions”
What the source actually says: Arbitral awards seated in the UAE are enforceable in the 172 states party to the New York Convention, to which the UAE acceded in 2006 without reservation, and enforcement runs through each state's own courts rather than automatically. DIFC and ADGM judgments are supported abroad by non-binding Memoranda of Guidance or Understanding, of the order of a dozen, which provide guidance rather than direct enforceability.
Checked against: UNCITRAL · uncitral.un.org
Claim in circulation: “UAE ranks 39th globally and 1st in MENA in the 2024 Rule of Law Index”
What the source actually says: The 2024 WJP factsheet does state 39th of 142 worldwide and 1st of 9 in the Middle East and North Africa, but the figures are out of date. The current 2025 edition ranks the UAE 37th of 143 worldwide and 1st of 10 in the region; cite the edition year explicitly.
Checked against: World Justice Project · worldjusticeproject.org
Claim in circulation: “Pre-certification under Delegated Act (EU) 2023/1184, pioneers in MENA”
What the source actually says: EU law contains no pre-certification, pre-approval or provisional status under Delegated Regulation (EU) 2023/1184, which sets substantive production criteria only. RFNBO compliance is demonstrable solely through one of the three Commission-recognised voluntary schemes - CertifHy, ISCC EU and REDcert - so a credible claim must name the scheme, the certificate and the certification body. Delegated Regulation (EU) 2023/1185 additionally imposes a 70% greenhouse gas saving against a 94 gCO₂eq/MJ comparator, and the "pioneers in MENA" superlative could not be verified from any source.
Checked against: European Commission · energy.ec.europa.eu
Claim in circulation: “UAE e-fuels pre-approved as sustainable aviation fuel under CORSIA”
What the source actually says: ICAO does not approve fuels by country and operates no pre-approval mechanism. A fuel becomes a CORSIA Eligible Fuel only when a specific producer's specific fuel is certified against the CORSIA Sustainability Criteria by a Sustainability Certification Scheme approved by the ICAO Council - currently ISCC, RSB and ClassNK - with eligibility attaching to producers and batches and tracked on ICAO's certified-fuels register.
Checked against: International Civil Aviation Organization (ICAO) · icao.int
Method
If you need to describe these rules in your own material, these sentences are defensible against the underlying sources.
Climate law
The UAE's Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects came into force on 30 May 2025 and applies to emissions sources across the UAE, including free zones (Article 3). Entities must measure and report greenhouse gas emissions using methodologies approved by the Ministry of Climate Change and Environment, keep records for five years, and had until 30 May 2026 to bring their operations into compliance (Article 18). Fines range from AED 50,000 to AED 2 million (Article 15), doubling for a repeat of the same violation within two years (Article 16).
Carbon credits
Cabinet Resolution No. 67 of 2024 established the UAE's National Register for Carbon Credits, in force since 28 December 2024. Entities emitting 0.5 million tonnes of CO₂e or more per year must register; smaller entities may join voluntarily. Annual emissions reports must be verified by bodies authorised by the Ministry and accredited to standards including ISO 14065 and ISO 14064. Carbon credit trading platforms are regulated by the Securities and Commodities Authority.
Hydrogen regulation
The UAE does not yet have dedicated hydrogen legislation. The National Hydrogen Strategy, approved by the UAE Cabinet in 2023, targets 1.4 million tonnes of low-carbon hydrogen per year by 2031 and 15 million tonnes by 2050, and identifies the development of a regulatory framework and a guarantee-of-origin certification scheme as work still to be done. Abu Dhabi's Department of Energy has been developing a Low-Carbon Hydrogen Policy and Regulatory Framework, including a proposed low-carbon hydrogen certificate, since 2022; it has not yet been enacted. Projects are therefore permitted under the existing energy, environmental, land and free zone regimes.
Certification
There is currently no UAE national low-carbon hydrogen certification scheme in force. UAE producers seeking to serve EU buyers can be certified under one of the three voluntary schemes the European Commission recognises for renewable fuels of non-biological origin — CertifHy, ISCC EU and REDcert — all of which have global geographic scope. At COP28 in Dubai, 46 participants including the UAE signed a Declaration of Intent to work toward mutual recognition of hydrogen certification schemes and to consider the ISO methodology for hydrogen production emissions.
Standards
ISO 19870-1:2026 is the international methodology for determining greenhouse gas emissions associated with hydrogen production up to the production gate, published in April 2026 and replacing ISO/TS 19870:2023. ISO 14067 is a methodology for quantifying the carbon footprint of a product — it is a calculation standard, not a certification scheme. ISCC EU is the European Commission-recognised scheme for demonstrating compliance with the Renewable Energy Directive; ISCC PLUS is a separate voluntary scheme for bio-based and circular feedstocks outside the Directive's scope. CORSIA is ICAO's scheme for international aviation, under which fuels qualify only when a specific producer is certified by an ICAO Council-approved certification scheme (currently ISCC, RSB and ClassNK). TÜV SÜD is an independent conformity-assessment body whose CMS 70 GreenHydrogen standard is a private, voluntary certification requiring at least 70% greenhouse gas savings.
Taxonomy
The UAE Sustainable Finance Working Group — which includes the Ministry of Finance, the Central Bank of the UAE, the Securities and Commodities Authority, ADGM's FSRA and the DFSA — published general principles for a UAE Sustainable Finance Taxonomy in 2023 and confirmed in December 2025 that it continues to develop the taxonomy's design. No binding UAE taxonomy has been issued, and no list of eligible activities has been published.
Ownership and tax
Since the 2020 reform of the Commercial Companies Law, 100% foreign ownership is permitted for most mainland commercial activities, subject to each emirate's list of permitted activities and to conditions set by the Cabinet for activities of strategic impact. Free zone companies that qualify as Qualifying Free Zone Persons pay 0% UAE corporate tax on qualifying income — which includes manufacturing and processing of goods or materials — and 9% on other taxable income, subject to substance, transfer-pricing, audit and de minimis conditions. The relief lasts for the tax incentive period set out in the relevant free zone's legislation. Multinational groups with consolidated revenue of €750 million or more are subject to a 15% Domestic Minimum Top-up Tax for financial years beginning on or after 1 January 2025.
EU market access
Hydrogen exported to the EU as a renewable fuel of non-biological origin must meet Commission Delegated Regulation (EU) 2023/1184 — covering additionality, temporal correlation (monthly matching until end-2029, hourly from 1 January 2030) and geographic correlation — and achieve at least 70% greenhouse gas savings against a 94 gCO₂eq/MJ comparator under Delegated Regulation (EU) 2023/1185. Under RED III, 42% of hydrogen used in EU industry must be RFNBO by 2030, rising to 60% by 2035. Hydrogen is within the scope of the EU Carbon Border Adjustment Mechanism, whose definitive regime began on 1 January 2026. European Hydrogen Bank auctions are currently open only to projects located in the European Economic Area; the Commission is still designing the international pillar and has not launched import auctions.