ADGM Carbon Reporting:
Complete Compliance Guide
Navigate adgm carbon reporting requirements for Abu Dhabi Global Market companies. Understand Federal Decree-Law No. 11 of 2024 obligations, FSRA sustainability disclosure rules, and dual reporting for financial institutions on Al Maryah Island.
Does ADGM Need to Comply with UAE Carbon Reporting?
Yes. ADGM companies meeting emissions thresholds must comply with UAE federal carbon reporting requirements.
While ADGM operates under English common law with its own regulatory framework, federal environmental laws including Federal Decree-Law No. 11 of 2024 apply to all entities operating within the UAE. This includes banks, asset managers, insurance companies, and fintech firms registered in ADGM.
Abu Dhabi Global Market (ADGM) is the Middle East and Africa region's leading international financial centre. Companies operating within this jurisdiction must navigate both the Financial Services Regulatory Authority (FSRA) sustainability disclosure requirements and UAE federal carbon reporting obligations.
ADGM Specific Requirements for Carbon Reporting
ADGM has positioned itself as a leader in sustainable finance in the region, with the FSRA implementing comprehensive sustainability disclosure requirements that complement federal carbon reporting obligations.
ADGM Sustainable Finance Initiatives
ADGM has established itself as a hub for sustainable finance in the region, launching initiatives that support green and sukuk bond listings, ESG-focused funds, and climate-related financial products. These initiatives create additional expectations for carbon transparency among ADGM entities.
Dual Reporting: Federal + ADGM Authority
ADGM companies must navigate a dual reporting framework, satisfying both UAE federal requirements through MOCCAE and FSRA sustainability disclosure obligations. The good news is that these frameworks are increasingly aligned, allowing for efficient integrated reporting.
Federal (MOCCAE) Reporting Stream
IEQT Platform Registration
Register entity with MOCCAE using ADGM commercial license
Annual Emissions Report
Submit Scope 1, 2, and material Scope 3 emissions data
Third-Party Verification
MOCCAE-accredited verification for entities >100,000 tCO₂e
ADGM (FSRA) Reporting Stream
FSRA Sustainability Disclosure
TCFD-aligned climate disclosures in regulatory submissions
Climate Risk Integration
Incorporate into ICAAP, ORSA, and governance frameworks
ADGM Sustainability Portal
Voluntary ESG reporting and best practice sharing
Integrated Reporting Opportunity
ADGM and MOCCAE have worked to align their requirements, creating opportunities for integrated reporting. Emissions data collected for IEQT can be repurposed for FSRA disclosures with additional narrative on climate strategy, governance, and risk management. Consider implementing a unified sustainability data management system.
Registration Steps for ADGM Companies
Determine Applicability
Calculate your organization's total annual emissions including office operations at Al Maryah Island or Al Reem Island, data center usage, business travel, employee commuting, and financed emissions (Scope 3, Category 15) for financial institutions. Check FSRA disclosure applicability based on your regulatory category.
Gather Documentation
- •ADGM commercial license
- •FSRA reference number and regulatory category
- •Emirates IDs of authorized signatories
- •Office facility information
- •Previous emissions data if available
- •Organizational chart and governance structure
IEQT Platform Registration
Visit ieqt.moccae.gov.ae and create an organizational account. Select "Financial Services" as your sector classification and specify ADGM as your operating jurisdiction. Include your FSRA reference number for regulatory coordination.
FSRA Notification
Notify the FSRA of your IEQT registration and federal compliance status through your usual supervisory channels. This helps ensure coordinated regulatory oversight and may streamline your FSRA sustainability disclosures.
Complete FSRA Disclosures
Integrate your emissions data into FSRA sustainability disclosures with TCFD-aligned narrative on governance, strategy, risk management, and metrics/targets. Submit through the FSRA's regulatory reporting systems.
ADGM Local Resources and Contacts
Additional ADGM Resources
- FSRA Sustainability Disclosure Framework - Available on ADGM website
- ADGM Sustainable Finance Guiding Principles - Green bond and sukuk framework
- ADGM Climate Risk Management Guidance - TCFD implementation support