Hydrogen law, regulations & strategy in the United Arab Emirates

Ambitions

The UAE has ambitious clean energy goals and increasing the country’s reliance on hydrogen as part of its national energy mix is seen as a key strategy to achieve them. So far, these ambitions have been reflected in summits, national strategies and the development of regulatory frameworks, alongside the advancement of hydrogen projects. The UAE’s aim is to establish a hydrogen industry that ranks among the top 10 producers globally by 2031.

It is commonly accepted that the key challenges in developing low-carbon hydrogen are

1. pricing, particularly when compared to grey hydrogen or traditional oil and gas; and
2. the infrastructure and transportation capacities needed. 

The UAE has several strengths it can leverage to secure a leading position in the hydrogen industry:

1.  Infrastructure: Existing energy infrastructure, export facilities and global trade agreements are already in place to accelerate the development of the hydrogen economy.
2. Oil and Gas Expertise: The UAE’s traditional oil and gas industry provides a foundation of engineering expertise, offtake connections, and experience in carbon capture and utilisation (“CCUS”).  The combination of CCUS expertise and the potential economic benefits of the use of blue hydrogen for enhanced oil recovery could help drive the growth of blue hydrogen. 
3. Natural Resources: The UAE’s abundant natural energy resources, particularly solar energy, will be utilised to drive down the cost of green hydrogen, positioning the country as a leader in this sector. 1

The UAE hopes to achieve its ambitions of developing low-cost, low-carbon hydrogen generation facilities by leveraging its advanced infrastructure and strategic location between Asia and Europe.

Current Status

The UAE’s primary focus in hydrogen projects has been on green, blue and pink hydrogen 2 , with over 20 low-carbon hydrogen projects currently underway. Notably, the progression of these projects is likely to be driven by state-owned entities, with blue hydrogen development – driven by the involvement of the Abu Dhabi National Oil Company (“ADNOC”) – viewed as a more cost-effective option.  Abu Dhabi Future Energy Company (“Masdar”) has also shown interest in advancing green hydrogen.

The UAE’s first green hydrogen plant, commissioned in Dubai in May 2021, was developed as a USD 14 million public-private partnership (“PPP”). Located at the Mohammed bin Rashid Al Maktoum Solar Park —a collection of solar independent power projects projected to reach a total capacity of 5GW by 2030 —this facility uses solar PV electricity from Phase 1 of the park to produce 20kg of hydrogen per hour. The hydrogen is stored and used by Dubai Electricity and Water Authority to help meet electricity generation demand. This plant was the first solar-driven green hydrogen producing facility in the Middle East and North Africa (“MENA”) region.

The UAE’s support and roadmap for hydrogen development are outlined in federal-level frameworks, including the UAE Energy Strategy 2050 (the “Energy Strategy”), the UAE National Hydrogen Strategy (the “Hydrogen Strategy”), and the Low-Carbon Hydrogen (“Low-Carbon Hydrogen Regulatory Framework”). 

The UAE’s ambitions for the hydrogen market have been highlighted by key events such as hosting COP28 in Dubai (November-December 2023) and the second Green Hydrogen Summit in Abu Dhabi (April 2024). However, to attract the significant investment needed to create bankable projects, the UAE must further develop and implement hydrogen-specific regulation to provide stakeholders with sufficient confidence in the viability of hydrogen projects in the region. For example, the Low-Carbon Hydrogen Regulatory Framework has remained in draft form since October 2022.

While the UAE’s strong foundational position offers opportunities to overcome industry-wide challenges such as pricing and infrastructure, realising these benefits will require strategic planning, particularly to ensure a reliable supply of hydrogen. This, in turn, will facilitate contractual commitments by offtakers and drive further investment into the UAE’s hydrogen market.

The UAE has demonstrated a commitment to integrating hydrogen into its future energy strategy. In July 2023, the Ministry of Energy and Infrastructure (“MoEI”), published the Hydrogen Strategy, outlining the country’s ambition to become one of the top ten global hydrogen producers, with a focus on both domestic use and hydrogen export. This strategy aims to create a clear policy and regulatory framework to inspire confidence in the business community, stimulate demand, attract foreign direct investment, and leverage the UAE’s industrial clusters.

Under the Hydrogen Strategy, the UAE targets producing 1.4 million tonnes per annum (“mtpa”) of hydrogen by 2031, with the ambition to reach 14.9 mtpa by 2050. The strategy also outlines plans to establish hydrogen oases – dedicated regions for hydrogen production and utilisation – starting with two by 2031 and expanding to five by 2050. Additionally, the strategy aims for a 25% reduction in emissions from hard-to-abate sectors by 2031, with the goal of achieving a 100% reduction by 2050.

The Hydrogen Strategy sets out 10 key areas for the development of the UAE’s hydrogen supply chain, each with implementation plans running through to 2031. These areas include global collaboration, resources and assets, enabling infrastructure, policy, regulation and standards, and finance and investments.

The Hydrogen Strategy highlights the importance of hydrogen networks in the UAE's hydrogen economy, leveraging existing resources such as oil and gas reserves, ports, and natural geography to rapidly develop transmission and distribution infrastructure. This, alongside storage infrastructure like depleted oil or gas fields, will be essential for creating low-cost transmission corridors and storage facilities. Pipelines, being the most cost-effective method for transporting high volumes of hydrogen, are a key focus. As of July 2023, the UAE already has four oil pipelines and ten natural gas pipelines used for regional distribution and export, including to Oman and Qatar. Repurposing these pipelines, especially to address embrittlement, will be vital. To connect production sites, domestic users, and export terminals, the UAE plans a dedicated hydrogen pipeline linking Jebel Ali, Ras Al-Khaimah, Al Ain, and Fujairah. This requires significant investment, clear legislation, and careful network planning. Additionally, road and rail transport are being explored to address infrastructure gaps for last-mile delivery, while shipping will benefit from the UAE’s 12 commercial trading ports. The strategy also outlines decarbonisation plans for each of these supply chains. Regarding storage, the UAE currently has above-ground hydrogen storage and is working towards developing underground storage, including using salt caverns—though this will require significant development before becoming feasible.

This Hydrogen Strategy aligns with the broader decarbonisation and net-zero goals of the UAE, positioning hydrogen as a critical element in achieving these objectives. For instance, the UAE's 2050 Net Zero Strategy, which aims to become the first MENA country to reach net-zero emissions by 2050, includes a "Diversify Scenario" as a key part of its decarbonisation pathway. This scenario involves scaling up low-carbon hydrogen production to support hard-to-abate sectors. The Net Zero 2050 model envisions a balanced long-term share of both green and blue hydrogen.

Nuclear energy, a topic of significant discussion during COP28, is also incorporated into this scenario. The Emirates Nuclear Energy Corporation (“ENEC”) is looking to develop electrolytic technology to produce zero-carbon hydrogen.

Additionally, the Hydrogen Strategy is integral to the UAE's Energy Strategy 2050, updated by the Ministry of Energy and Infrastructure (“MoEI”) in July 2023. This strategy places emphasis on public-private partnerships (PPP) and international cooperation. By advancing access to low-carbon hydrogen, the Hydrogen Strategy is set to contribute significantly to the overall goals of the UAE’s National Energy Strategy 2050.

Whilst these strategies are becoming more prominent and detailed, the key challenge will be translating them into practical action on the ground. This will require legislative and financial support to ensure successful implementation.

The UAE plans to build a pipeline of hydrogen projects aimed at positioning the country as a global leader in clean and low-carbon energy. Abu Dhabi National Oil Company’s blue 1 mtpa ammonia production facility in Ruwais, Abu Dhabi, was awarded to Tecnimont S.p.A (MAIRE Group) in May 2024, and it will be built at the new TA’ZIZ industrial ecosystem and chemicals hub in Ruwais. In November 2024, TA’ZIZ announced the awarding of engineering, procurement, and construction (EPC) contracts valued at more than $2 billion (AED7.34 billion) for the development of essential site infrastructure. A preliminary life cycle assessment study estimates that Phase 1 of the plant will produce ammonia with 50% lower carbon intensity compared to conventional methods. In its second stage, the plant will further reduce carbon emissions through carbon capture. The facility, developed in partnership with Fertiglobe, Mitsui & Co., Ltd., and GS Energy Corporation, will emphasise Abu Dhabi's position as a leader in low-carbon fuels and contribute to the shift to clean hydrogen.

Equally notable is the industrial-scale green hydrogen-to-ammonia project developed by TAQA and Abu Dhabi Ports. This project will feature a 2 GW solar PV power plant producing green hydrogen, which will then be converted into liquid ammonia. The ammonia will be used as bunker fuel for ships and exported via specialised gas carriers from Abu Dhabi Ports. The facility will also include a pipeline connection to Khalifa Port, enhancing its capacity to export ammonia to international markets, including Europe and East Asia. It has been reported that $1 billion is being invested into this solar farm, which is expected to produce 200,000 tpa of ammonia. Project construction is expected to commence in 2026, with commercial operations beginning in 2028.

The Low-Carbon Hydrogen Regulatory Framework (as mentioned above) sets out specific regulatory guidelines for the development of the Abu Dhabi hydrogen industry, in collaboration with the Abu Dhabi Department of Energy (“Abu Dhabi DoE”).

The framework proposes the creation of two key structures: (i) Hydrogen Valleys, which are geographical areas where multiple hydrogen applications are integrated into a cohesive hydrogen ecosystem aimed at improving the economics of hydrogen projects, and (ii) Clean Energy Clusters, which consist of one or more locations with clean electricity and/or desalinated water production plants connected by dedicated transmission networks. These clusters aim to optimise the cost of 'clean' electricity and water supplies for low-carbon hydrogen activities, facilitating the scaling up of related facilities.

The Abu Dhabi Department of Municipalities and Transport (“Abu Dhabi DMT”) will allocate land and public corridors for the Hydrogen Valleys and Clean Energy Clusters, with the Abu Dhabi DoE coordinating the designation of these Hydrogen Valleys in conjunction with the Abu Dhabi DMT.

Another crucial element of the framework is the introduction of the Cluster Consumer Supply Tariff, where each consumer will be charged a specific electricity and water tariff based on their requirements and commitments. The Emirates Water and Electricity Company (“EWEC”) will be responsible for procuring clean electricity and desalinated water plants through Power and Water Purchase Agreements (PWPAs). Abu Dhabi Transmission and Despatch Company (“TRANSCO”) will manage the construction, maintenance, and operation of electricity and water transmission lines between the production plants and cluster consumers. Low-carbon hydrogen production will be certified through Low-Carbon Hydrogen Certificates.

While the framework represents significant progress, as a regulatory framework, much remains to be finalised. Although general criteria are outlined, key processes, such as those concerning the responsibilities of EWEC, Abu Dhabi Distribution Company/Al Ain Distribution Company, and TRANSCO in land and public corridor allocation, still require further development. Additional methodologies must be devised, such as those related to the Abu Dhabi DoE’s development of the Cluster Consumer Supply Tariff. Furthermore, regulations and guidelines must be issued by the Abu Dhabi DoE to enable EWEC, TRANSCO, distribution companies, and consumers to carry out activities under the framework. It remains unclear whether the Abu Dhabi DoE will develop its own certification scheme or join an internationally recognised scheme to ensure that certifications are locally and globally acknowledged.