Sustainable Infrastructure in the UAE – Top 8 before COP28 mini series

Middle East

Sustainable and energy efficient infrastructure is essential for achieving ambitious carbon neutrality goals on a global scale. In 2018, the buildings and construction sector accounted for 36% of final energy use and 39% of energy and process-related CO2 emissions.[1] The United Nations Environment Programme’s 2022 Global Status Report for Buildings and Construction highlights that, although there has been an increase around the world in investment and resultant success at lowering the energy intensity of buildings, the energy consumption and CO2 emissions in the buildings and construction sector increased in 2021 to above pre-COVID-19 pandemic levels; reaching an all-time high for buildings energy demand and CO2 emissions. The report concludes that the buildings and construction sector is not on track to achieve decarbonisation by 2050.[2]

It is therefore unequivocal that this is a core area of focus moving into COP28, which has a thematic day in Dubai on 6th December 2023 dedicated to multilevel action, urbanization and the built environment / transport, including targeted sessions on:

  1. the ‘Ministerial Meeting on Urbanization and Climate Change’;
  2. ‘The Built Environment: A Catalyst for a Real-World Response to the Global Stocktake’;
  3. the ‘Council on Competitiveness & Global Federation of Competitiveness Councils (GFCC) Innovation Arena: Bridging University-Industry-Society to Advance Sustainability’; and
  4. ‘Nature-Positive Cities, Regions and Built Environment’.

Many of the key sustainability infrastructure related issues around the world are also present in the UAE, in particular: the additional pressure of the UAE’s high energy consumption alongside expanding its population and economic growth, a climate necessitating year-round use of air conditioning, the difficulty in retrofitting inefficient older buildings, and the desire for ‘signature buildings’ in major cities.

It is worth noting that there has been a shift in focus to change building techniques, adapt design and construction, and ensure that the building is energy efficient once complete. At a policy and legislative level, there has certainly been progress from the intended decarbonisation of construction techniques through to extensive regulations regarding how a building must be designed and constructed. However, with regards to the operation of such buildings, there remain questions marks around how successful the implementation of sustainable infrastructure has been to date. Therefore, pro-active steps must be taken at COP28 to bridge the gap, so that the operation of buildings in an energy efficient manner matches the strides made in design and construction.

Federal progress over the last decade

Improvements and progress

Over the course of the last decade, the UAE has looked to improve its sustainable building reputation, having previously been labelled as the “bad boys of energy consumption.”[3] In 2004, an academic paper considered the issue of high energy consumption in office tower buildings, and its subsequent adverse impact on the environment, to be “alarming and must be considered by decision makers in any future planning.”[4] 14 years later, a 2018 study indicated that buildings in the UAE consumed 70% of the UAE’s electricity generated.[5]

There have been developments in respect of sustainable infrastructure which demonstrate progress. For example, in July 2014, the Ministry of Energy and Infrastructure in the UAE established a new department for energy conservation and energy efficiency, partly aimed at establishing an energy consumption database which is split by sectors across the UAE, in order to compare the performance of establishments within a sector. Thereafter, the 2021 edition of the National Green Building Regulation sets out mandatory minimum levels for water and electricity consumption efficiency standards for new buildings across the UAE through the design and construction phases.[6] This is in support of the UAE Energy Strategy 2050 (“Energy Strategy 2050”), discussed further below.

The 2019 inauguration of the HSBC tower in Downtown Dubai demonstrates practical progress. This is considered one of the most sustainable buildings in the world as it notably received the coveted LEED Gold Standard from the U.S. Green Building Council. More broadly, in 2021, the UAE was ranked 14th in the world in relation to the highest concentration of sustainable buildings and is the leading country in the region in this respect.[7]

Federal policies

In addition, there have been federal policies, initiatives and targets focusing on energy efficiency. In 2014, Sheikh Mohammed launched a seven-year National Agenda leading to Vision 2021, with one of the six key national priorities being ‘Sustainable Environment and Infrastructure’. More recently, the Energy Strategy 2050 was updated in July 2023, moving the UAE towards its aim of reaching net zero emissions by 2050. Energy efficiency is a key aspect of the Energy Strategy 2050, with a focus on improving the energy efficiency of energy and water consumption in highly intensive sectors in line with the National Water and Energy Demand Management Program. For example, there are a number of steps which the UAE is taking to ensure effective measures are in place to decarbonise the building sector including: (i) retrofitting existing buildings, (ii) implementing green building codes, (iii) enhancing the implementation of energy efficiency standards and rating systems for household appliances and equipment, (iv) raising public awareness of methods for conserving energy and water resources, and (v) increasing efficiency and reliance on recycled wastewater. Among the 2050 targets, there is one to reduce energy consumption by 40% and water use by 20% from the UAE’s building sector, an aim for 50% recycling of construction waste, and the saving of AED 17 billion by 2050 through energy and water consumption reduction and recycling policies.[8]

The UAE must consolidate this progress. There has clearly been a policy shift in the desire to tackle the issue of sustainable infrastructure and energy efficiency, however, effective regulation and legislation driving the public and private sectors to do so must be in place. By way of example at a federal level illustrating this change, in December 2022, the UAE Cabinet approved the National Building Regulations and Standards to decarbonise construction by a 5% reduction in carbon footprint. However, the issue remains that there has been little tangible progress in the past year to action this into legislation.

Emirate level progress

At an emirate level, in recent years one particular area of focus is on the introduction of regulations and guidance in respect of sustainable infrastructure practices, such as green building.

Emirate strategies

Parallel to the federal level policy developments, there have been strategies launched by individual emirates looking at energy efficiency. By way of example, in 2019 Ras Al Khaimah launched Barjeel: the Green Building Regulations, which establish minimum sustainability standards for new buildings. The intention is that buildings within the system will consume 30% less energy and water versus a ‘typical’ building in the emirate. From January 2020, this became a mandatory system. This is part of the broader Ras Al Khaimah Energy Efficiency and Renewables Strategy 2040 which contains nine programmes, including a focus on: building retrofits, energy management, and efficiency appliances. A further example of an emirate implementing sustainable infrastructure development plans is the Dubai Integrated Energy Strategy 2030 which, among other broader energy strategies, looks to enhance the efficiency of water and power in the emirate.

However, the key developments are the Abu Dhabi Pearl Rating System (“Pearl Rating System”) and the Al Sa’fat Dubai Green Building System (“Al Sa’fat System”).

Abu Dhabi’s Pearl Rating System

As part of the Abu Dhabi Vision 2030, Estidama (the Arabic word for ‘sustainability’) is a programme focusing on building design methodology in respect of construction and operation of buildings. The Pearl Rating System is a green building rating system which is part of Estidama and has been incorporated into the wider Abu Dhabi emirate building codes. The Pearl Rating System is applicable to every new building with over 50 metres2 of gross air-conditioned floor area. 

The Pearl Rating System looks to improve water, energy and waste usage, and improve supply chains for sustainable and recycled materials and products. This is to be done using practical measures which set out what is and is not permitted to attain credits, ranging from sustainable buildings, light pollution mitigation and requirements regarding water features. This system is split into: (i) a Pearl Design Rating, (ii) a Pearl Construction Rating, and (iii) a Pearl Operational Rating, each of which has mandatory and optional credits. Compliance is required to be able to receive a building permit and a certificate of completion, with all buildings requiring a minimum of a 1 Pearl Rating (unless it is government-funded, in which case a 2 Pearl Rating is required), out of a maximum of 5 Pearls. This is supported by the International Building Codes in the Emirate of Abu Dhabi, including the Abu Dhabi International Energy Conservation Code.

However, it is important to note that although there has been an increase in robust stipulations regarding the design and construction of buildings in Abu Dhabi, there is arguably a gap that, once constructed, these buildings are not required to actually be operated in a sustainable manner. For example, the Pearl Operational Rating document remains unreleased.

Dubai’s Al Sa’fat System

In Dubai, the 2010 Green Building Regulations and Specifications were replaced by the Al Sa’fat System in 2020. The Al Sa’fat System second edition was released in January 2023. The intention of this system is to construct a sustainable environment moving forwards; all new buildings are mandated to obtain a Silver Sa’fa, and there are additional requirements whereby a Golden or Platinum Sa’fa can be awarded. The Al Sa’fat system contains an array of design measures intended to increase energy efficiency, such as in respect of escalator auto shut off, lighting power density and thermal transmittance.

As with the Pearl Rating System, particularly with the latest update of the Al Sa’fat System containing heavier reliance on the Dubai Building Code 2021, there are carefully established requirements in respect of building design. However, operational requirements are lacking and remain an area that must be further specified and enforced.

Looking forwards

It is clear that the UAE is seeking to combat its historic significant energy inefficiencies in the buildings and construction sector through ambitious targets combined with the establishment of regulations and guidance. However, it should be considered that beyond the construction and design of buildings, there must be sufficient enforceable regulations and legislation in place, at both a federal and emirate level, to ensure that the operation of these buildings is conducted sustainably.

Further to this, each relevant authority must ensure firm compliance with such regulations by strict implementation of procedural requirements. Additionally, the standards that a building must attain to be compliant could arguably be heightened, for example, by requiring an additional number of Pearls under the Pearl Rating System or buildings being mandated to achieve a Golden Sa’fa award.

Although the issue of sustainable infrastructure is of global concern, it is particularly prevalent in the UAE with rapidly expanding cities, an increasing population, a very significant construction projects pipeline, and the desire of its two largest cities to build unique, tall buildings in a hot climate. Consequently, the built environment lends itself to being energy intense.

The finances behind energy efficiency will be critical to the success of future UAE sustainable infrastructure. On a governmental level the allure of financial savings, such as the target of potentially saving AED 226 billion by 2050 through lower consumption of energy and water[9] and the expansion of the green economy, may drive forward sustainable infrastructure. On the other hand, individual end users will also need to be encouraged further into efficient energy usage. Whilst there have been government attempts to improve end user energy efficiencies, such as through the Department of Energy’s introduction of the consumption tariff and the Dubai Electricity and Water Authority’s application of a slab tariff and fuel surcharge, there remains low consumption costs to push consumers into substantial energy efficiency savings.

As COP28 aims to bring the international community together in the UAE to accelerate climate progress, the country must take this opportunity to constructively tackle these sustainability issues and drive solutions which put effective regulation at the foundation of fulfilling the ambitious and progressive development goals that have been set.

Article co-authored by Abbas Yusuf, Trainee Solicitor at Dubai.



[1] Global Alliance for Buildings and Construction, International Energy Agency and the United Nations Environment Programme (2019): 2019 global status report for buildings and construction: Towards a zero-emission, efficient and resilient buildings and construction sector.

[2] United Nations Environment Programme (2022). 2022 Global Status Report for Buildings and Construction: Towards a Zero‑emission, Efficient and Resilient Buildings and Construction Sector. Nairobi.

[3] The bad boys of energy consumption | Property – Gulf News

[4] 1521-tower-buildings-in-dubai-are-they-sustainable.pdf (

[5] Min Lin, Afshin Afshari, Elie Azar, A data-driven analysis of building energy use with emphasis on operation and maintenance: A case study from the UAE, Journal of Cleaner Production, Volume 192, 2018, Pages 169-178, ISSN 0959-6526, (


[7] UAE ranks 14th worldwide for highest concentration of sustainable buildings (

[8] UAE Energy Strategy 2050 (updated July 2023)

[9] UAE Energy Strategy 2050 (updated July 2023)