ESG Global Vision

Environment, corporate governance

Varies between participating states 

CORSIA applies to airline operators who fulfil the following criteria:

• their annual CO2 emissions from international flights using aeroplanes with a take-off mass greater than 5,700kg exceed 10,000 tonnes (all major carriers meet this relatively low threshold);
• they are responsible for international flights (flights by state aircraft and humanitarian, medical, and firefighting flights, as well as flights before or after such flights which are carried out by the same aeroplane and are needed for these activities, are not included); and
• they are registered in one of the participating states (see the list as of 1 January 2026 here; notable omissions include India and China).

In 2010, the International Civil Aviation Organisation (ICAO), a United Nations Agency that sets global standards and regulations for international civil aviation, adopted a sectoral aspirational goal for carbon neutral growth from 2020 onwards. Whilst operational and technological improvements are seen as a key part of achieving this goal, the ICAO took the view that a market based scheme was required to fill the remaining emissions gap and to achieve carbon neutral growth. Accordingly, the International Standards and Recommended Practices for the implementation of CORSIA were adopted as an Annex to the Chicago Convention in 2016, to apply to all of ICAO’s 193 member states from 1 January 2019.

CORSIA is being implemented in three phases:

• The Pilot Phase (2021-2023) and the First Phase (2024-2026). During these phases participation by ICAO member states was voluntary. 126 member states participated, with flights between participating states subject to reporting and offsetting requirements.
• The Second Phase (2027-2035). During this phase, with some exemptions, such as for Least Developed Countries and Small Island Developing States, participation will become mandatory for all ICAO member states and all international flights will be subject to offsetting requirements. The Second Phase will be split into three-year compliance periods.

In scope airline operators are under the following obligations:

• To monitor and report emissions from international flights on an annual basis.
  • At the beginning of each 3-year compliance period, an operator is required to submit an Emissions Monitoring Plan to its administering state which, once approved, the operator will use for the entire compliance period.
  • Under the plan, the operator is required to monitor and record its fuel use for international flights over the course of each calendar year. The operator must then estimate their annual CO2 emissions and report them to the national authority of their administering state by 30 April the following year. To guarantee the accuracy of the data reported, operators will need their annual emissions report to be verified by an impartial third-party verification body prior to submission.
  • Aggregated emissions are required to be reported by each administering state to ICAO, which will publish the total emissions from individual operators.
• To offset their emissions.
  • Under the scheme, the administering state calculates the annual offsetting requirements for each operator by multiplying the operator’s CO2 emissions by a ‘Growth Factor’, which is calculated by the ICAO and represents the percentage growth of the aviation sector’s international CO2 emissions covered by CORSIA’s offsetting requirements in a given year compared to the sector’s baseline emissions (being 85% of 2019 emissions levels).
  • Upon completion of each 3-year compliance period, the operator will have to show they have met their offsetting requirements by purchasing and cancelling the appropriate number of certified CORSIA Eligible Emissions Units (“CEEUs”) (each representing a tonne of CO2). The price of these units varies considerably depending on the type of project ($0.50 to $45/tCO2e during 2020-2021 with a weighted average of $3.08/tCO2eq in 2021).
  • Operators can also reduce their offsetting requirements by using CORSIA Eligible Fuels (“CEFs”) that meet the CORSIA sustainability criteria, which includes fuels with at least 10% lower CO2e emissions on a life-cycle basis compared to a reference fossil fuel value of 89.1 gCO2e/MJ. It is worth noting that as the baseline for calculating emissions reduction targets is 85% of 2019 emissions levels, offsetting requirements will only cover the growth in emissions since 2019 and therefore it is anticipated that the percentage of their total emissions that operators will have to offset will remain modest for the first few years of implementation of the scheme.

For more information, please follow the link here.

Penalties and enforcement:

National aviation authorities of participating states determine the sanctions for non-compliance, so these vary between countries. In the UK, for example, typical civil penalties can include a £20,000 penalty with a further daily penalty of £500 for failing to: (i) apply or revise an emissions monitoring plan; (ii) monitor emissions properly; or (iii) submit emissions reports. In recent consultations, the UK government has indicated that the penalties for failing to cancel CEEUs on time in line with an airline’s offsetting requirements would be £100 for each uncancelled unit.

Corporate Governance Policy

In force

All companies/private individuals

The law aims to:

• Combat money-laundering practices
• Establish a legal framework that supports the authorities concerned with anti-money laundering and crimes related to money-laundering
• Counter the financing of terrorist operations and suspicious organisations.

The Decree-Law defines a perpetrator of a money-laundering offence as:

• Any person who is aware that the money was derived from a felony or misdemeanour, and intentionally commits one of the following acts:

1. 1. transferring or transporting proceeds of crime with intent to conceal or disguise its illicit origin
   2. concealing or disguising the true nature, origin, location, way of disposition, movement or rights related to any proceeds or the ownership thereof
   3. acquiring, possessing or using such proceeds
   4. assisting the perpetrator of the predicate offence to escape punishment.

The Law stipulates that money laundering is independent of the predicate crime and that the punishment of the person who has committed a predicate offence shall not protect him or her from being penalised for money laundering.

Corporate liability for money laundering offences can lead to fines of up to fifty million dirhams (AED 50,000,000), and compulsory liquidation where the offence is related to terrorist financing.

Corporate Governance Policy

In force

All companies/private individuals

Under the UAE Criminal Code, Bribery includes:

• the request, acceptance, offer of or making of any promise or gift (or other advantage) to a public official either directly or indirectly in order to abet that public officer or person to abuse his power, whether actual or presumed, in order to obtain, from a public department of authority, an unlawful benefit (arts. 234).
• The offering, promising, or giving of a bribe to another person who manages or is employed by a private sector legal entity (art. 236) or who is a public official.
• Knowingly assisting or abetting in the commission of a bribe.
• Acting as an intermediary for a bribery transaction (art. 237).
• Bribery of a foreign (non-UAE) public official or an employee of an international organization to fulfil or fail to fulfil his or her public official functions (art. 237).

Liability for bribery offenses can be up to five years imprisonment and a fine equal to the bribe but not less than AED 5,000 (art. 238).

Environment, corporate governance

Varies between participating states 

CORSIA applies to airline operators who fulfil the following criteria:

• their annual CO2 emissions from international flights using aeroplanes with a take-off mass greater than 5,700kg exceed 10,000 tonnes (all major carriers meet this relatively low threshold);
• they are responsible for international flights (flights by state aircraft and humanitarian, medical, and firefighting flights, as well as flights before or after such flights which are carried out by the same aeroplane and are needed for these activities, are not included); and
• they are registered in one of the participating states (see the list as of 1 January 2026 here; notable omissions include India and China).

In 2010, the International Civil Aviation Organisation (ICAO), a United Nations Agency that sets global standards and regulations for international civil aviation, adopted a sectoral aspirational goal for carbon neutral growth from 2020 onwards. Whilst operational and technological improvements are seen as a key part of achieving this goal, the ICAO took the view that a market based scheme was required to fill the remaining emissions gap and to achieve carbon neutral growth. Accordingly, the International Standards and Recommended Practices for the implementation of CORSIA were adopted as an Annex to the Chicago Convention in 2016, to apply to all of ICAO’s 193 member states from 1 January 2019.

CORSIA is being implemented in three phases:

• The Pilot Phase (2021-2023) and the First Phase (2024-2026). During these phases participation by ICAO member states was voluntary. 126 member states participated, with flights between participating states subject to reporting and offsetting requirements.
• The Second Phase (2027-2035). During this phase, with some exemptions, such as for Least Developed Countries and Small Island Developing States, participation will become mandatory for all ICAO member states and all international flights will be subject to offsetting requirements. The Second Phase will be split into three-year compliance periods.

In scope airline operators are under the following obligations:

• To monitor and report emissions from international flights on an annual basis.
  • At the beginning of each 3-year compliance period, an operator is required to submit an Emissions Monitoring Plan to its administering state which, once approved, the operator will use for the entire compliance period.
  • Under the plan, the operator is required to monitor and record its fuel use for international flights over the course of each calendar year. The operator must then estimate their annual CO2 emissions and report them to the national authority of their administering state by 30 April the following year. To guarantee the accuracy of the data reported, operators will need their annual emissions report to be verified by an impartial third-party verification body prior to submission.
  • Aggregated emissions are required to be reported by each administering state to ICAO, which will publish the total emissions from individual operators.
• To offset their emissions.
  • Under the scheme, the administering state calculates the annual offsetting requirements for each operator by multiplying the operator’s CO2 emissions by a ‘Growth Factor’, which is calculated by the ICAO and represents the percentage growth of the aviation sector’s international CO2 emissions covered by CORSIA’s offsetting requirements in a given year compared to the sector’s baseline emissions (being 85% of 2019 emissions levels).
  • Upon completion of each 3-year compliance period, the operator will have to show they have met their offsetting requirements by purchasing and cancelling the appropriate number of certified CORSIA Eligible Emissions Units (“CEEUs”) (each representing a tonne of CO2). The price of these units varies considerably depending on the type of project ($0.50 to $45/tCO2e during 2020-2021 with a weighted average of $3.08/tCO2eq in 2021).
  • Operators can also reduce their offsetting requirements by using CORSIA Eligible Fuels (“CEFs”) that meet the CORSIA sustainability criteria, which includes fuels with at least 10% lower CO2e emissions on a life-cycle basis compared to a reference fossil fuel value of 89.1 gCO2e/MJ. It is worth noting that as the baseline for calculating emissions reduction targets is 85% of 2019 emissions levels, offsetting requirements will only cover the growth in emissions since 2019 and therefore it is anticipated that the percentage of their total emissions that operators will have to offset will remain modest for the first few years of implementation of the scheme.

For more information, please follow the link here.

Penalties and enforcement:

National aviation authorities of participating states determine the sanctions for non-compliance, so these vary between countries. In the UK, for example, typical civil penalties can include a £20,000 penalty with a further daily penalty of £500 for failing to: (i) apply or revise an emissions monitoring plan; (ii) monitor emissions properly; or (iii) submit emissions reports. In recent consultations, the UK government has indicated that the penalties for failing to cancel CEEUs on time in line with an airline’s offsetting requirements would be £100 for each uncancelled unit.

Environmental Policy

In force

All companies/private individuals  

This is the primary legislation for environmental protection in the United Arab Emirates ("UAE").

Air Pollution

• No operator or entity is allowed to commence activities unless it has conducted a detailed study of their effects on the environment (Article 4, Environmental Law).
• Parties that violate any provisions concerning air pollution are liable to civil action and are responsible for all costs associated with any damage caused to the environment by their actions (Article 71, Environmental Law). Fines ranging from AED2,000 to AED20,000 can be imposed on offenders, as well as criminal liability, depending on the nature and extent of the pollution (Article 83, Environmental Law).

Environmental Impact Assessments ("EIA")

• An EIA must be undertaken for certain projects including fossil natural resources projects, non-fossil natural resources projects, industrial projects and agricultural projects among others. In Abu Dhabi,  the Environmental Agency of Abu Dhabi ("EAD") grants permits to carry out projects on the basis of EIAs. In Dubai, the Environment Planning and Studies Section ("EPSS") of Environment Department in Dubai Municipality issues permits.

Environmental Policy

In force

All companies/private individuals

This Resolution, consisting of 11 articles, provides for a unified tool to facilitate implementation of legislation relevant to environment, health and safety and for protection of human health and environment safety, and conservation of natural resources.

Environmental Policy

In force

All companies/private individuals

All industries in Abu Dhabi must obtain an environmental permit before beginning any project. The EAD provides permits for development and infrastructure projects, industrial facilities, and hazardous material stores.

The permit issued by the EAD is renewable every year to ensure that an operator or entity maintains compliance with the regulations and conditions and to also ensure that they conform with the most recent laws.

A permit that has been awarded to a company by the competent environmental authority cannot be transferred to a third party.

Non-compliance with EAD regulations attracts a fine of at least AED5,000.

Ministerial Decree 849 of 2010 on the amendment of Ministerial Decision No. 554 for 2009 concerning the prohibited and restricted use of pesticides.

Environmental Policy

In force

All companies/private individuals

The Federal Ministry of Climate Change and Environment bans companies from producing, manufacturing, formulating, circulating, importing and using certain pesticides.

Environmental Policy

In force

All companies/private individuals

Aims to ensure protection of public health and community safety in the Emirate of Dubai through the provision of specific requirements for the following:

• Health hazards
• Drinking water
• Fighting of Public Health Pest
• Public Safety
• Smoke Control
• Health and Safety of Buildings
• Public Cleanliness

Environmental Policy

In force

All companies that deal with asbestos

The EHS Regulatory Instrument sets out requirements for companies that deal with asbestos in the Emirate, including that they must:

• Identify potential asbestos materials by specialist consultants.
• Develop an asbestos management plan to reduce risks.
• Make all staff dealing with the material aware of the management plan.
• Provide prescribed tools and equipment to staff in order to reduce the risk of exposure.
• Dispose of the waste at the prescribed waste management site in Abu Dhabi.

Environmental Policy

In force

All companies/private individuals

The guidelines issued require anyone handling asbestos to (among other requirements):

• Enclose asbestos waste in the prescribed manner.
• Provide accurate labelling of all materials containing asbestos.
• Provide prescribed safety tools and equipment to staff removing or dealing with the material.
• Dispose of the waste material at the prescribed waste management site in Dubai.

Environmental Policy

In force

All companies/private individuals

The Dubai Supreme Council of Energy ("DSCE") was established in 2009 and oversees all aspects of energy in Dubai to ensure the efficient use of energy. According to this energy strategy, Dubai aims for a share of 15% of renewable energy in the total energy mix by 2030. Some targets set out in the strategy include the following:

• 27% clean energy by 2021 (UAE Vision 2021).
• 50% target for power generation from clean energy by 2050 (National Energy Strategy 2050).
• Abu Dhabi: 7% renewable energy target by 2020.
• Dubai: 7% renewable energy target by 2020, 25% by 2030 and 75% by 2050 (Dubai Clean Energy Strategy 2050).

Green building specifications and standards were issued in Dubai in 2014, according to which new buildings would have to adhere to such requirements from 2014 onwards. The DSCE oversees the Dubai Integrated Energy Strategy 2030 in order to ensure the efficient use of energy.

Consumer Protection Policy

In force

Entities listed on the Abu Dhabi Securities Exchange (ADX) or the Dubai Financial Market (DFM)

The SCA requires all public joint-stock companies listed in the UAE to comply with certain ESG metrics and to periodically report on these.

Article 76 of this decision requires the public joint-stock companies listed on the Abu Dhabi Securities Exchange (ADX) or the Dubai Financial Market (DFM) to publish a sustainability report annually.

Listed companies must submit their annual sustainability reports to SCA within 90 days from each financial year-end or before the date of the annual general assembly meeting, whichever is earlier. The report should reflect the company’s long-term strategy and its impact on the following areas:

• the environment – the impact of the company’s operations and decisions on the environment and the company's communities.
• society – how the company’s policies and operations contribute or could contribute to social justice, the well-being of workers and employees and the surrounding community.
• the economy and governance –how the company contributes to society's economic benefit and the impact of the company's operations on the local economy.

In addition, public joint-stock company's must comply with the Global Reporting Initiative (GRI) standards and any sustainability standards and requirements issued by the DFM or ADX, depending on which market the PJSC is listed on.

Social Policy

In force

All companies/private individuals

This law aims to protect everyone in the UAE, via a solid legislative ground for the environment of tolerance, co-existence and acceptance. The law fights discrimination against individuals or groups based on religion, caste, doctrine, race, colour or ethnic origin.

The provisions of the decree are applied to the internet, telecommunication networks, electronic websites and in audio-visual materials among others, thereby protecting individuals, including artists and cultural professionals from discrimination in the digital environment.

The law criminalises any acts that stoke religious hatred and/or which insult religion through any form of expression, be it speech or the written word, criminalise any acts that stoke religious hatred and/or which insult religion through any form of expression, be it speech or the written word, books, pamphlets or via online media.

The law also includes provisions for punishing anyone for terming other religious groups or individuals as infidels, or unbelievers any acts that stoke religious hatred and/or which insult religion through any form of expression, be it speech or the written word, books, pamphlets or via online media.

Penalties for violation of the various provisions of the law include jail-terms of six months to over 10 years and fines from AED50,000 to AED2 million.

Social Policy

In force

All employers

This law addresses issues related to harassment, bullying, physical violence and psychological abuse against employees. The law prohibits forced labour and discrimination on the basis of gender, race, colour, sex, religion, national or social origin or disability. It also spells out employers’ obligations towards employees and bans the employment of children below the age of 15.

Social Policy

In force

All companies/private individuals

In September 2017, the Gender Balance Council launched the Gender Balance Guide: Actions for UAE Organisations prepared by the Organisation for Economic Co-operation and Development (OECD). The guide recommends actions for organisations to:

1. Implement commitment and oversight for gender balance
2. Integrate gender into policies and programmes
3. Engage personnel towards gender balance
4. Implement gender balance in leadership positions
5. Implement gender sensitive communication.