UAE · Maritime & Shipping

GHG reporting under UAE maritime regulations

UAE shipping companies report greenhouse-gas emissions under Federal Decree-Law No. 11 of 2024 (the Climate Law), which adopts the GHG Protocol’s three-scope framework on top of IMO requirements. Here’s how Scope 1, 2 and 3 are defined — and what each means for a vessel operator.

Start reporting Maritime Scope 3

The three scopes, defined

The UAE Climate Law follows the GHG Protocol — the same Scope 1 / 2 / 3 split used worldwide, applied to the maritime value chain.

Scope 1

Direct emissions

GHG from sources the entity owns or controls.

Maritime

Vessel fuel combustion — the Tank-to-Wake (TTW) portion of bunker burn.

Scope 2

Purchased energy

Emissions from generating the electricity, steam, heat or cooling you purchase.

Maritime

Shore-power and terminal electricity drawn at berth.

Scope 3

Value-chain emissions

All other indirect emissions across the up- and down-stream value chain (15 categories).

Maritime

Fuel upstream (Well-to-Tank), chartered vessels, cargo handling, logistics.

Scope 1 vs 2 vs 3 — side by side

How the three scopes differ across the dimensions that matter for a UAE shipping operator.

Attribute	Scope 1 · Direct	Scope 2 · Energy	Scope 3 · Value chain
Definition	Direct GHG from sources owned or controlled by the entity	Emissions from generation of purchased electricity, steam, heating, cooling	All other indirect emissions across the value chain
Who emits	You, on your own assets	The utility / power plant, on your behalf	Third parties — suppliers, customers, logistics
Control	Direct operational control	You buy it; emitted off-site	Outside your direct control
Typical sources	Fuel combustion (boilers, vehicles, vessels), process emissions, fugitive leaks	Purchased grid electricity, district heating / cooling, purchased steam	Purchased goods, capital goods, upstream fuel (WTT), travel, transport, sold-product use
Maritime example	Vessel fuel burned — Tank-to-Wake (TTW)	Shore-power / terminal electricity purchased	Fuel upstream — Well-to-Tank (WTT), chartered vessels, cargo handling
Reporting basis	Mandatory, core inventory	Mandatory; location-based & market-based methods	Activity-based preferred; spend-based fallback
Relative size	Small–medium	Usually small	Usually the largest (70–90%+ for shipping)

1Scope 1 · Direct

Definition: Direct GHG from sources owned or controlled by the entity
Who emits: You, on your own assets
Control: Direct operational control
Typical sources: Fuel combustion (boilers, vehicles, vessels), process emissions, fugitive leaks
Maritime example: Vessel fuel burned — Tank-to-Wake (TTW)
Reporting basis: Mandatory, core inventory
Relative size: Small–medium

2Scope 2 · Purchased energy

Definition: Emissions from generation of purchased electricity, steam, heating, cooling
Who emits: The utility / power plant, on your behalf
Control: You buy it; emitted off-site
Typical sources: Purchased grid electricity, district heating / cooling, purchased steam
Maritime example: Shore-power / terminal electricity purchased
Reporting basis: Mandatory; location-based & market-based methods
Relative size: Usually small

3Scope 3 · Value chain

Definition: All other indirect emissions across the value chain
Who emits: Third parties — suppliers, customers, logistics
Control: Outside your direct control
Typical sources: Purchased goods, capital goods, upstream fuel (WTT), travel, transport, sold-product use
Maritime example: Fuel upstream — Well-to-Tank (WTT), chartered vessels, cargo handling
Reporting basis: Activity-based preferred; spend-based fallback
Relative size: Usually the largest (70–90%+ for shipping)

The bunker-fuel split

One fuel quantity, two scopes

For shipping, the same bunker fuel lands in two scopes at once. Its combustion onboard (Tank-to-Wake) is Scope 1; its upstream extraction, refining and delivery (Well-to-Tank) is Scope 3, category 3. Carbon Zero’s emission-factor catalogue stores a WTT + TTW split per fuel so a single bunker entry populates both correctly.

TTW combustion → Scope 1 (your direct inventory)
WTT upstream → Scope 3, category 3 (fuel & energy-related)
IMO DCS / CII / EEXI measure the Scope 1 (TTW) fuel-burn CO₂
Per-fuel factors: HFO, VLSFO, MGO, LNG, methanol, biofuel, ammonia

One tonne of bunker fuel splits as

Tank-to-Wake (TTW)Scope 1

Combustion in the vessel’s engines — your direct emissions.

Well-to-Tank (WTT)Scope 3 · Cat 3

Extraction, refining and delivery of the fuel — upstream value chain.

The regulatory stack

UAE law meets IMO standards

A UAE shipping group reports against the national Climate Law and the IMO’s maritime decarbonisation instruments together.

Federal Decree-Law No. 11 of 2024

UAE Climate Law

The UAE Climate Law (in force 30 May 2025) requires in-scope entities to measure, report and reduce their GHG emissions, adopting the GHG Protocol three-scope split.

IMO DCS

Data Collection System

Mandatory fuel-oil consumption reporting for ships ≥ 5,000 GT — a direct measure of a vessel’s Scope 1 (Tank-to-Wake) emissions.

IMO CII / EEXI

Carbon intensity

Operational Carbon Intensity Indicator and Energy Efficiency Existing-ship Index rate a ship’s real fuel-burn CO₂ against efficiency thresholds.

Poseidon Principles

Finance alignment

Climate-alignment framework for ship finance, mirroring IMO decarbonisation trajectories for lenders and lessors.

This page is an informational summary, not legal advice. Confirm reporting obligations and thresholds against the official text of Federal Decree-Law No. 11 of 2024 and the relevant IMO instruments for your fleet.

Report UAE maritime emissions with confidence

Map Scope 1, 2 and 3 across your fleet — with the WTT / TTW split CSRD and the UAE Climate Law expect.

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