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Governance

The rules that bind a UAE hydrogen project

Federal climate law in force since May 2025, the free zone tax regime as the legislation itself writes it, and the European rules that decide whether a Gulf molecule can be sold into Europe.

Last verified:

Timeline

What came into force, and when

The regulatory milestones that can be dated to a published source. Note the absence: there is still no hydrogen-specific legislation in the UAE.

  1. 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 BARQ
  2. Cabinet approves the National Hydrogen Strategy

    Still in force unrevised as of August 2026.

    UAE Cabinet
  3. Abu 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 Office
  4. Federal 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 Legislation
  5. Cabinet Resolution 67/2024 — National Carbon Credit Registry

    Registration duties for emitters above the threshold, and carbon credits treated as financial instruments.

    UAE Legislation
  6. The climate law enters into force

    Applies to sources across the UAE, free zones included (Article 3). Measurement and reporting duties begin.

    UAE Legislation
  7. ISO 19870-1:2026 published

    Replaces the 2023 technical specification for quantifying the greenhouse gas footprint of hydrogen.

    ISO
  8. Transition period ends for regulated sources

    Article 18 gave regulated sources twelve months from entry into force to comply.

    UAE Legislation

15 entries

Federal climate law

Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects

Confidence: High

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

Entry into force mechanism (Article 21)

Confidence: High

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

Scope of the climate law (Article 3)

Confidence: High

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

Emissions reduction, monitoring and reporting duties (Articles 4-8)

Confidence: High

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

Transition period for regulated sources (Article 18)

Confidence: High

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

Carbon market mechanisms and National Carbon Credit Registry (Article 10)

Confidence: High

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

Penalties under the climate law (Article 15)

Confidence: High

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

Doubling of penalties for repeat offences (Article 16)

Confidence: High

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

Cabinet Resolution No. 67 of 2024 - National Register for Carbon Credits

Confidence: High

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

Scope of the National Register for Carbon Credits

Confidence: High

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

Mandatory registration threshold for carbon emitters

Confidence: High

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

Regularisation deadline for the carbon register

Confidence: High

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

Monitoring, reporting and verification requirements

Confidence: High

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

Carbon credits treated as financial instruments

Confidence: High

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

Administrative fines under the carbon register regime

Confidence: Medium

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

7 entries

Hydrogen-specific regulation

Absence of hydrogen-specific legislation in the UAE

Confidence: High

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

UAE National Hydrogen Strategy targets

Confidence: High

1.4million tonnes per year by 2031

In force 2023

The Cabinet-approved National Hydrogen Strategy, presented by the Ministry of Energy and Infrastructure on 4 July 2023, targets 1.4 million tonnes per year of low-carbon hydrogen by 2031 (1.0 green plus 0.4 blue), 7.5 million tonnes per year by 2040 and 15 million tonnes per year by 2050, alongside a 25% cut in hard-to-abate emissions by 2031 and 100% by 2050. It also proposes to "establish two hydrogen oases and explore three future ones".

Caveat: The strategy is non-binding policy, not legislation.

Source: Ministry of Energy and Infrastructure (MOEI) / UAE Cabinet · u.ae · 4 July 2023

Certification and standards identified as outstanding work

Confidence: High

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

Abu Dhabi DoE Low-Carbon Hydrogen Policy and Regulatory Framework

Confidence: High

In force 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

Abu Dhabi DoE licensing regime

Confidence: High

28days minimum objection period

In force 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. No processing timeframes are published.

Source: Abu Dhabi Department of Energy · doe.gov.ae

DEWA green hydrogen pilot project, Dubai

Confidence: High

20kg H2 per hour

In force May 2021

DEWA operates a green hydrogen pilot at the Mohammed bin Rashid Al Maktoum Solar Park, developed with Expo 2020 Dubai and Siemens Energy, producing approximately 20 kg of hydrogen per hour with storage for up to 12 hours and an approximately 300 kW generator. No Dubai-specific hydrogen regulation, certification standard or governance framework is stated on the source page.

Source: Dubai Electricity and Water Authority (DEWA) · dewa.gov.ae

Technical regulation on hydrogen and fuel-cell vehicles

Confidence: Medium

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

8 entries

Certification and hydrogen standards

Absence of a UAE low-carbon hydrogen certification scheme

Confidence: High

No UAE national low-carbon hydrogen certification scheme is in force. No UAE scheme appears in the IEA policy database of hydrogen certification schemes; the "Clean Hydrogen Certification Scheme" listed there is Korea's. Abu Dhabi's certificates remain a draft proposal and the national strategy lists a guarantee-of-origin scheme as still to be developed.

Caveat: Corroborated by CMS (11 Feb 2025) and A&O Shearman; the IEA entry itself concerns Korea's scheme, and is cited as evidence of the absence of a UAE entry.

Source: International Energy Agency (IEA) · iea.org

COP28 UAE Declaration of Intent on Hydrogen and Derivatives

Confidence: High

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

UAE entry in the IPHE country pages

Confidence: Medium

1million tonnes per year target in 2031

The IPHE country page for the UAE lists a target of "1 mtpa in 2031". The page does not state a membership date or a lead agency and shows no deployment data.

Caveat: IPHE membership is not explicitly confirmed on the page.

Source: International Partnership for Hydrogen and Fuel Cells in the Economy (IPHE) · iphe.net

ISCC PLUS

Confidence: Medium

11,000companies certified (ISCC/ISCC PLUS)

In force 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: ISCC (private scheme) · dqsglobal.com

EU-recognised voluntary schemes for RFNBOs

Confidence: High

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

CertifHy low-carbon scope

Confidence: High

In force 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

TÜV SÜD Standard CMS 70 "GreenHydrogen"

Confidence: High

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

CORSIA Eligible Fuels (ICAO)

Confidence: High

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

3 entries

International standards referenced

ISO/TS 19870:2023

Confidence: High

In force November 2023

"Hydrogen technologies - Methodology for determining the greenhouse gas emissions associated with the production, conditioning and transport of hydrogen to consumption gate." Published November 2023 by ISO/TC 197/SC 1. It has since been superseded.

Caveat: Superseded by ISO 19870-1:2026.

Source: International Organization for Standardization (ISO) · iso.org

ISO 19870-1:2026

Confidence: High

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

ISO 14067:2018

Confidence: High

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

10 entries

Corporate tax and free zones

UAE corporate tax rates (Article 3(1))

Confidence: High

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

Corporate tax 0% threshold

Confidence: High

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

Qualifying Free Zone Person rate (Article 3(2))

Confidence: High

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

Conditions for Qualifying Free Zone Person status (Article 18(1))

Confidence: High

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

Consequences of losing Qualifying Free Zone Person status (Article 18(2))

Confidence: High

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

De minimis rule for non-qualifying revenue

Confidence: High

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

Duration of the free zone 0% corporate tax regime

Confidence: High

In force 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

Qualifying Income and Qualifying Activities

Confidence: High

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% Domestic Minimum Top-up Tax

Confidence: High

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: UAE Cabinet · ey.com

Free zone customs treatment as advertised by JAFZA

Confidence: High

0% import or re-export duties (as advertised)

In force Current

The Jebel Ali Free Zone Authority advertises "0% import or re-export duties" and "0% corporate tax for 50 years with renewable concession".

Caveat: This is a statement by the free zone authority about its own zone, not a federal customs instrument. The UAE's standard GCC common external tariff rate could not be verified from an official UAE government source.

Source: Jebel Ali Free Zone Authority (JAFZA) · jafza.ae

15 entries

Investment protection and dispute resolution

Status of a UAE sustainable finance taxonomy

Confidence: High

In force 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

Composition of the UAE Sustainable Finance Working Group

Confidence: High

In force 5 December 2023

The taxonomy work is not a Ministry of Finance or Central Bank instrument. The Working Group comprises the Ministry of Finance, the Ministry of Economy, MOCCAE, the Office of the UAE Special Envoy for Climate Change, the Central Bank of the UAE, the SCA, ADGM FSRA, the DFSA, ADX, DFM and Nasdaq Dubai.

Source: UAE Sustainable Finance Working Group · dfsa.ae · 5 December 2023

Whether hydrogen is covered by a UAE taxonomy

Confidence: High

No published activity list exists, so hydrogen is neither included in nor excluded from a UAE taxonomy. Neither the Third nor the Fourth Public Statement names sectors or activities.

Source: UAE Sustainable Finance Working Group (coordinated by ADGM FSRA) · adgm.com · 18 December 2025

External corroboration on the absence of a UAE taxonomy

Confidence: High

The Climate Bonds Initiative's "World of Taxonomies" tracker, which covers more than 50 jurisdictions, has no UAE entry.

Source: Climate Bonds Initiative · climatebonds.net

100% foreign ownership of mainland commercial companies

Confidence: Medium

100% foreign ownership (subject to conditions)

In force 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

Current Commercial Companies Law

Confidence: Medium

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: UAE Federal Government · leap.unep.org

Bilateral investment treaties - official UAE figure

Confidence: High

over 100signed BITs

In force Current

The Ministry of Finance states that "the UAE has signed over 100 Bilateral Investment Treaties (BITs) with key trade and investment partners worldwide". No in-force figure is given.

Caveat: This is a count of treaties signed, not treaties in force.

Source: UAE Ministry of Finance · mof.gov.ae

Bilateral investment treaties - UNCTAD count

Confidence: Medium

126BITs listed

In force Data current to early 2026

UNCTAD's Country Navigator lists 126 BITs and 44 TIPs for the UAE. In the IIA Navigator table of the 74 most recent UAE BITs, 25 are marked "Signed (not in force)", reflecting a large 2024-2026 signing wave including Canada, Sri Lanka, Ecuador, Trinidad and Tobago, Türkiye, Barbados, Tonga, Guyana and Mozambique.

Caveat: The UNCTAD table is paginated and its header totals are global rather than UAE-specific, so an exact in-force count cannot be derived from it.

Source: UNCTAD · investmentpolicy.unctad.org

Bilateral investment treaties - practitioner figure

Confidence: Medium

111signed BITs (approximately 71 in force)

A practitioner guide states that "the UAE has signed approximately 111 Bilateral Investment Treaties (38 of which are not currently in force, and 2 which have been terminated) most of which are subject to Investor-State Dispute Settlement (ISDS) arbitration", implying roughly 71 in force.

Caveat: No publication date is shown on the source page, and in-force counts change frequently.

Source: Legal 500 Country Comparative Guide, UAE International Arbitration · legal500.com

New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards

Confidence: High

172States parties

In force 19 November 2006

The Convention has 172 States parties. The UAE acceded on 21 August 2006, and it entered into force for the UAE on 19 November 2006, with no reservations.

Caveat: Enforcement runs through each state's own courts on Convention grounds; it is not automatic.

Source: UNCITRAL · uncitral.un.org

DIFC Courts

Confidence: High

In force 2004 / 2011

The DIFC Courts were established by Dubai Law No. 12 of 2004 (as amended by Dubai Law No. 16 of 2011) and DIFC Law No. 10 of 2004. They are described as "a unique common law, English language jurisdiction, which governs commercial and civil disputes, national, regionally, and worldwide". Law No. 16 of 2011 extends jurisdiction to "disputes which have no relation to the DIFC, but where the parties agree in writing to opt for the Courts jurisdiction". Jurisdiction covers civil and commercial matters only, with no criminal jurisdiction.

Source: DIFC Courts · difccourts.ae

DIFC Courts judicial memoranda

Confidence: Medium

In force Ongoing

The DIFC Courts publish judicial Memoranda of Understanding and Memoranda of Guidance. The listing page shows arrangements with, among others, the High Court of Hong Kong SAR, the Federal Court of Malaysia, the High Court of Zambia, the National Court Administration of the Supreme Court of Korea, the Shanghai High People's Court, the Hangzhou Arbitration Commission and the Abu Dhabi Judicial Department. These are guidance or understanding instruments, of the order of a dozen, and are not treaties and do not create direct enforceability.

Caveat: The listing page is paginated, so the count is a floor rather than a total.

Source: DIFC Courts · difccourts.ae

Direct application of English common law in ADGM

Confidence: High

In force 2015

The Application of English Law Regulations 2015 "make English Common Law (including the rules and principles of equity) directly applicable in ADGM", supported by the ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015. ADGM describes itself as the first jurisdiction in the Middle East to adopt an approach similar to Singapore and Hong Kong, with judges drawn from senior judiciary of leading common law jurisdictions.

Source: Abu Dhabi Global Market (ADGM) · adgm.com

WJP Rule of Law Index 2024 - UAE

Confidence: High

39of 142 countries

In force 2024

The 2024 country factsheet states that the UAE "ranks 39th out of 142 countries worldwide" and "ranks 1st out of 9 countries in the Middle East and North Africa".

Caveat: Superseded by the 2025 edition; cite the edition year explicitly if used.

Source: World Justice Project · worldjusticeproject.org

WJP Rule of Law Index 2025 - UAE

Confidence: High

37of 143 countries

In force 2025

The 2025 country factsheet states that the UAE "ranks 37th out of 143 countries worldwide" and that "regionally, the United Arab Emirates ranks 1st out of 10 countries in the Middle East and North Africa".

Source: World Justice Project · worldjusticeproject.org

9 entries

EU rules that govern any export

Delegated Regulation (EU) 2023/1184 - RFNBO production methodology

Confidence: High

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

Delegated Regulation (EU) 2023/1185 - GHG saving threshold

Confidence: High

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

RED III - Directive (EU) 2023/2413

Confidence: High

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

CBAM - Regulation (EU) 2023/956

Confidence: High

In force 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

CBAM Omnibus - Regulation (EU) 2025/2083

Confidence: High

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: European Union · ey.com

Delegated Regulation (EU) 2025/2359 - low-carbon fuels methodology

Confidence: High

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

European Hydrogen Bank

Confidence: High

In force 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

Auctions-as-a-Service

Confidence: High

In force December 2024 onwards

Auctions-as-a-Service allows individual Member States to top up EU auction budgets with national funding while using the EU auction process. It was announced jointly by the Commission, Spain, Lithuania and Austria; the Commission's hydrogen bank page also lists Germany.

Source: European Commission and participating Member States · ec.europa.eu

IF25 hydrogen auction terms

Confidence: High

1.1EUR billion budget

In force 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

Marketing claims that do not survive the statute

These phrasings circulate widely in sector material about the Emirates. Each is checked against the instrument it purports to describe.

  1. Partly true

    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.

    Source: Ministry of Finance / Federal Tax Authority (FTA) · mof.gov.ae

  2. Unsupported

    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.

    Source: Abu Dhabi Department of Energy · doe.gov.ae

  3. Unsupported

    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.

    Source: CMS (Expert Guide to Hydrogen, UAE chapter) · cms.law

  4. Unsupported

    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.

    Source: UAE Ministry of Finance · mof.gov.ae

  5. False

    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.

    Source: UNCITRAL · uncitral.un.org

  6. Confirmed

    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.

    Source: World Justice Project · worldjusticeproject.org

  7. Unsupported

    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.

    Source: European Commission · energy.ec.europa.eu

  8. False

    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.

    Source: International Civil Aviation Organization (ICAO) · icao.int

Method

Accurate phrasings

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.

Investment protection and dispute resolution

The UAE has signed over 100 bilateral investment treaties, according to the Ministry of Finance, most of which provide for investor-State arbitration. The UAE acceded to the New York Convention in 2006 without reservation, so arbitral awards are enforceable across its 172 States parties. The DIFC Courts and ADGM Courts are English-language common law jurisdictions: ADGM applies English common law directly under its Application of English Law Regulations 2015, and both accept opt-in jurisdiction by written agreement of the parties.

Rule of law

The UAE ranked 37th of 143 countries, and 1st of 10 in the Middle East and North Africa, in the World Justice Project's 2025 Rule of Law Index.

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.