Preparing for UAE Cop 28: Gulf Countries’ Net-zero and Climate Action Roadmaps

Morgan Lewis

Morgan Lewis

At the end of 2023, the United Arab Emirates (UAE) will host the Conference of the Parties (COP), the decision-making body responsible for monitoring and reviewing the implementation of the United Nations Framework Convention on Climate Change (UNFCCC) (UAE COP 28).

COPs are aimed at fostering a sense of shared responsibility and setting a path for nations to tackle climate change collectively. The Paris Agreement, the breakthrough accord reached in 2016 following COP 21, set goals to hold “the increase in the global average temperature to well below 2°C above pre-industrial levels” and to pursue efforts “to limit the temperature increase to 1.5°C above pre-industrial levels.”

The understanding set out in the Paris Agreement is that in order to limit the global warming to 1.5°C, greenhouse gas (GHG) emissions must peak before 2025 at the latest and decline 43% by 2030. Each nation that ratifies the Paris Agreement pledges its own nationally determined contribution (NDC), which is to be revised on a five-year schedule, to reduce GHG emissions and to adapt to the effects of climate change.

UAE COP 28 is seen as a halfway point between the Paris Agreement and the 2030 deadline for GHG emissions to decline.

With the Middle East in the spotlight for UAE COP 28, the Gulf Cooperation Council (GCC) nations have reaffirmed their full support for UAE COP 28 and emphasized its importance in tackling climate change following a ministerial meeting in June 2023.


The UAE as well as all other GCC members adhered to the UNFCCC and ratified the Paris Agreement. Their status under the Paris Agreement is that of “Non-Annex I Parties” in recognition that they are countries that rely heavily on proceeds from fossil fuel production and commerce. (The UNFCCC divides countries into three main groups according to differing commitments.)

Even as Non-Annex I Parties, several of the GCC countries pledged ambitious NDCs and have begun undertaking various net-zero initiatives, signaling a significant step by the GCC countries toward acknowledging and addressing climate issues.

The UAE was among the first Middle Eastern nations to ratify the Paris Agreement and even submitted its intended NDC in 2015 ahead of COP 21 in Paris.

See Annex I for a high-level summary of the GCC countries’ commitments under the Paris Agreement.


In addition to their Paris Agreement commitments, many GCC countries have been working on carbon-reduction initiatives and the diversification and expansion of their sustainable energy practices.

The GCC countries’ plans for the transition of the energy sector are primarily based on three pillars of equal importance: (1) ensuring energy security, (2) promoting economic prosperity for all countries, and (3) reducing GHG emissions. The GCC countries have specific and sometimes different regional drivers economically, socially, and environmentally. Their primary focus in terms of net-zero and climate change actions has predominantly been on phasing out emissions rather than reducing the production of fossil fuels.

Notably, Saudi Arabia, the UAE, and Oman have announced net-zero and decarbonization strategies that rely on a mix of traditional initiatives (such as the increased use of renewable energy and a focus on energy efficiency implementation), with forward-looking low-carbon solutions (such as hydrogen and carbon capture and storage projects) being developed.

See Annex II for highlights on the net-zero and climate change initiatives being implemented in the GCC countries.


UAE Net Zero by 2050 is a strategic initiative, aligned with the Paris Agreement, to achieve net-zero emissions by 2050. The Ministry of Climate Change and Environment (MOCCAE) is leading the efforts to implement UAE Net Zero by 2050.

The whole of 2023 has been declared the “Year of Sustainability” for the UAE, with a yearlong series of initiatives and events focused on sustainable development.

Ahead of UAE COP 28, the UAE updated the UAE Energy Strategy 2050 by setting goals for 2030 and energy strategies to achieve net zero by 2050. In addition, Abu Dhabi National Oil Company (ADNOC) recently announced its intention to accelerate its net-zero emissions target to 2045 instead of its previous commitment for 2050.

In July, the UAE submitted its Third Update of Second NDC, setting absolute emission reduction targets (compared to 2019 as the base year) and replacing the previous commitment to reduce emissions with reference to the business-as-usual (BAU) scenario. Further, 2030 net GHG emissions will be reduced from an expected 208 MtCO2e, as previously announced in the Updated Second NDC in 2022, to 182 MtCO2e. This represents an absolute emissions reduction of 19% by 2030, compared to the 2019 base year level. If expressed in terms comparable to BAU, this represents a 40% decrease from estimated 2030 emissions.

The Third Update of the Second NDC comes in line with a number of targeted policies and strategies, such as the UAE Hydrogen Leadership Roadmap, a comprehensive national blueprint to support domestic, low-carbon industries, contribute to the country’s net-zero ambition, and establish the country as a competitive exporter of hydrogen. Another example is the Abu Dhabi Climate Change Strategy, which is focused on two pillars: (1) mitigation, involving reducing climate emissions while maintaining economic growth, and (2) adaptation, which refers to enhancing the resilience and agility of key economic sectors against climate risks.

Further, the Abu Dhabi Global Market (ADGM), the international financial center in Abu Dhabi, has partnered with AirCarbon Exchange (ACX) to create the world’s first fully regulated carbon trading exchange and carbon clearing house in Abu Dhabi. The ADGM also announced the implementation of one of the first sustainable finance frameworks in the region, which will help channel capital into projects and activities that advance the country’s transition to net zero. For more information, refer to our LawFlash, Sustainable Finance: A Strategic Priority for the UAE.

In support of green infrastructure and clean energy projects around the world, the UAE has invested in renewable energy ventures worth approximately $16.8 billion in 70 countries. It has also provided more than $400 million in aid and soft loans for clean energy projects.


With UAE COP 28 on the horizon, expectations are high for further commitments and progressive actions. The "COP 28 effect"—which represents an opportunity for a paradigm shift—is already noticeable in the region. The GCC countries are ramping up their climate efforts, reflecting both an understanding of the urgency and the opportunity that UAE COP 28 presents.

As discussed above, the UAE, as the host of the preparatory meetings for UAE COP 28, is showcasing its commitment to facilitating a global climate dialogue and championing sustainable development. Other GCC countries, too, are strengthening their climate ambitions.

The eyes of the world will be on the UAE and other GCC countries as UAE COP 28 approaches. While the challenges are substantial, so too are the opportunities. Increased investment in renewable energy, further development of low-carbon solutions in hydrocarbon extraction and refining, and greater regional cooperation could position the GCC as a leader in climate action.

The COP 28 effect is more than an impetus for change; it is also an opportunity for the GCC countries to step into a global energy leadership role and to write a more sustainable narrative for the region.

For an overview of the GCC countries’ commitments under the Paris Agreement and their current net-zero and climate change initiatives, see these annexes.

Intern Mohammed Alhammadi and paralegal Hussein Al Fahel co-authored this article.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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