Does the UAE Climate Law Require Scope 3 Emissions?

Scope 3 questions usually arrive before the legal answer is clear. A customer asks for purchased-goods emissions, a bank requests financed or supply-chain data, an IFRS S2 or ESRS project is under way, and the climate-law team assumes the same categories belong in the Article 6 submission. That assumption can overstate the law, create an unmanageable supplier campaign and produce figures that do not match the regulated perimeter.

The opposite reaction is also risky. Value-chain emissions often dominate a company’s wider footprint and can affect reduction planning, procurement, products, logistics and access to finance. A proportionate screening exercise is useful even where no current authority instruction requires Scope 3. The key is to label the work correctly: “voluntary readiness screening” is not the same as “UAE Climate Law filing requirement”.

Figure 1. Confirm the authority requirement first; screen the value chain in parallel; keep regulated and voluntary outputs distinct. London Reporting Academy learning visual.

Article 6 applies to Sources determined by MOCCAE and the competent authority and requires regular measurement, an emissions inventory and periodic reports according to approved standards. The provision does not define Scope 1, Scope 2 or Scope 3 and does not reproduce the GHG Protocol category list. The practical reporting boundary therefore has to be found in the current designation, sector or facility guidance, methodology and form.

A verbal statement, consultant checklist, customer questionnaire or voluntary sustainability standard is not sufficient evidence that the competent authority requires all value-chain categories. Keep an authority-requirements register that records the exact source, version, reporting period, relevant field and named clarification contact. Where the instruction is ambiguous, ask a focused question and retain the response.

The purpose of first-year screening is to identify potentially significant categories, data owners, decision value and reporting exposure. It is not to create false precision across all 15 categories. A screening model can combine spend, physical quantities, sector factors, existing supplier data and qualitative relevance criteria. Record the method and uncertainty and avoid adding rough category estimates into a public total unless the output and methodology permit it.

Prioritisation should consider expected magnitude, exposure to reduction decisions, stakeholder or contractual demand, data availability, risk of double counting and whether the category is relevant to the business model. A low-spend item can be emissions-intensive; a high-spend professional service can be relatively low. Spend is a screening tool, not a universal proxy for importance.

Start with the reporting purpose, category, product or service, unit, period, geography and methodology needed.

Ask whether the figure is primary, estimated, verified, cradle-to-gate or another boundary, and which gases and GWPs it includes.

Request the calculation method and evidence needed to assess comparability, not confidential operational data that has no decision use.

Prioritise high-impact suppliers or products instead of sending one long questionnaire to the entire supplier base.

Provide a response hierarchy: supplier-specific figure, activity data, quantity/specification data, or confirmation that no figure is available.

Record supplier consent, confidentiality and permitted reuse; do not publish supplier-level information without authority or permission.

Maintain a response history so that data improvements and changes can be explained rather than overwritten.

A UAE group operates quarries, manufactures building materials and manages construction projects. Its current facility instruction covers direct emissions from specified industrial installations. A major customer also requests product and logistics emissions, while the bank requests a climate-data pack. The company cannot point to a current authority source requiring all 15 Scope 3 categories.

The group records the facility requirement as the regulated output and performs a voluntary Scope 3 screen for the corporate group. Purchased cementitious inputs, capital equipment, inbound logistics and use of sold products emerge as priority categories. Supplier-specific data are piloted for major materials; quantity-based factors are used elsewhere; spend estimates remain a screening layer. The sustainability report describes the voluntary boundary and limitations and does not state that the entire Scope 3 inventory was required by the UAE Climate Law.