Sustainability as legal structure.
ESG legal advisory for companies, investors and family offices operating across the United Arab Emirates, Italy and the EU, and China. One team, three legal systems, three working languages.
ESG obligations become concrete in the documents we draft every day: articles of association, shareholders’ agreements, supply and EPC contracts, due diligence reports and internal policies.
Paoletti has advised international businesses for over twenty years, from Rome and, since 2014, from the Abu Dhabi Global Market, Dubai, Milan and Shanghai. We help clients understand which sustainability rules actually apply to them, turn them into governance and contracts, and document compliance in a way that stands up to regulators, investors, banks and customers.
We work alongside technical consultants and emissions verifiers. The firm covers the legal and governance side, our partners the measurement. The client keeps a single point of contact.
Our own commitment. We apply to ourselves what we recommend to clients: an internal code of conduct and whistleblowing procedure, digital document processes, ongoing team training on sustainability regulation and an annual account of our own impact.
The regulatory landscape has changed.
Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects, in force since 30 May 2025, requires public and private entities, including those in free zones, to measure, report and reduce greenhouse gas emissions and keep records for five years. Fines range from AED 50,000 to AED 2 million.
ESG Disclosures Guidance of the ADGM Registration Authority, under sections 399A–399D of the ADGM Companies Regulations 2020, introduces a “comply or explain” disclosure regime for ADGM-registered companies.
SCA Governance Guide (Decision No. 3/R.M. of 2020, art. 76): PJSCs listed on ADX and DFM publish an annual sustainability report under GRI standards.
Directive (EU) 2026/470 (“Omnibus I”), in force since 18 March 2026, narrows the CSRD to companies with over 1,000 employees and €450 million turnover, and the CSDDD to groups with over 5,000 employees and €1.5 billion turnover.
The cascade effect remains. Businesses outside these thresholds still receive ESG questionnaires, contract clauses and data requests from customers, lenders and investors, including on major Gulf projects such as those in the Kingdom of Saudi Arabia.
Six practice areas, one point of contact across three jurisdictions.
UAE climate compliance
- Applicability review under Federal Decree-Law No. 11/2024
- Internal governance for emissions measurement and reporting
- Contracts with MRV consultants and verifiers
- Carbon credits and the National Register
ADGM and market ESG disclosure
- Gap analysis against the ADGM ESG Disclosures Guidance
- Legal support for SCA / GRI sustainability reports
- “Comply or explain” policies and board resolutions
Sustainable governance and family offices
- ESG committees, board roles and responsibilities
- Articles, shareholders’ agreements and foundation charters with sustainability objectives
- Italian benefit companies (società benefit)
- Responsible investment policies
Contracts and supply chain
- ESG and climate clauses in supply, EPC, distribution and JV agreements, sales agreements and bids
- Supplier codes of conduct and audit rights
- Responses to ESG questionnaires from EU customers
- CSRD/CSDDD cascade on SME suppliers
ESG in corporate transactions
- ESG legal due diligence in M&A and investments
- ESG representations, warranties and indemnities
- Structuring sustainable vehicles and funds in ADGM and DIFC
Social, people and anti-greenwashing
- Employee handbooks, codes of conduct, whistleblowing procedures
- Employment and human rights compliance
- Legal review of environmental claims and communications
- ESG dispute management
Clients operating between two regulatory worlds.
ESG Legal Check, in four phases.
Our latest ESG analysis.
Read our Sustainability Insights newsletter and our publications on ESG regulation in the UAE and Italy.
Let’s discuss your ESG strategy.
An initial meeting to understand which obligations apply to you and where to start. Abu Dhabi · Dubai · Rome · Milan · Shanghai.
This page is for information purposes only and does not constitute legal advice. Regulatory framework current as of October 2026; some implementing measures are still being issued. Legal services are provided by Paoletti Legal Consultants LLP, ADGM Licence No. 000003526, regulated by the ADGM Registration Authority.
