Saudi Arabia, UAE and Qatar: Sustainability Reporting Signals to Watch in the Gulf

The Gulf is often discussed as a single ESG market. It is not. Qatar has already made ISSB aligned reporting mandatory for its regulated financial sector. The UAE has a federal climate law that reaches every entity in the country, including free zones, with a compliance deadline that passed in May. Saudi Arabia, the largest economy of the three, still has no mandatory sustainability reporting requirement for most listed companies at all.

Three neighbouring states, three different speeds. What makes the picture manageable is that they are converging on the same destination, which is the ISSB standards, and that a shared regional baseline already exists beneath the national rules.

For companies operating across the Gulf, the question is not whether to prepare but which signal to act on first. Here is what each market has actually done, and what the region's largest investors expect regardless of what the rulebooks say.

The Regional Floor Almost Nobody Mentions

Before the national frameworks, there is a common starting point. On 9 January 2023 the GCC Exchanges Committee, chaired by the Saudi Exchange, published a unified set of 29 ESG disclosure metrics, comprising 10 environmental, 10 social and 9 governance indicators, aligned with the World Federation of Exchanges and the Sustainable Stock Exchanges Initiative. The Committee brings together seven exchanges across the six member states: the Saudi Exchange, Abu Dhabi Securities Exchange, Dubai Financial Market, Qatar Stock Exchange, Bahrain Bourse, Boursa Kuwait and Muscat Stock Exchange.

Two qualifications matter. The metrics are voluntary. And they do not replace the existing ESG disclosure guidelines of individual GCC exchanges, so they sit alongside national requirements rather than superseding them. Their usefulness is as a common denominator: a company reporting against those 29 metrics has something comparable across every Gulf exchange, and a reasonable foundation for whatever each national regulator layers on top.

Qatar: Furthest Ahead, and the Only One Requiring Assurance

Qatar has moved fastest, and did so by starting with the financial sector rather than the whole listed market.

The Qatar Central Bank has mandated reporting under IFRS S1 and S2 for the banks and insurance firms it regulates, annually, starting from 1 January 2026. It set out the implementation roadmap in a dedicated Sustainability Reporting Framework covering the general requirements of both standards. On the QCB's own phasing, that means financial year 2026 is the first reporting year, with the resulting annual reports following in 2027. The Qatar Financial Centre Regulatory Authority applied a parallel requirement to larger regulated firms inside the QFC, through corporate sustainability reporting rules that took effect on the same date.

The framework carries sensible proportionality. In the first annual reporting period, sustainability disclosures may be published after the annual financial statements. From the second period, they must appear alongside them.

That makes Qatar, on most readings, the first GCC state to adopt the ISSB standards into binding regulation rather than guidance.

For the wider listed market the position is genuinely transitional, and worth stating carefully rather than confidently. The Qatar Financial Markets Authority has been moving sustainability reporting from voluntary guidance into its Governance Code for listed companies, and commentary through 2026 points to full mandatory ISSB aligned reporting for Qatar Stock Exchange issuers arriving across 2026 and 2027. At the same time, the exchange's own public guidance still describes its ESG reporting guidelines as voluntary while noting that mandatory reporting is the global direction. Anyone with a QSE listing should confirm their current obligation directly with QFMA rather than relying on secondary summaries, because the two descriptions have not fully caught up with each other.

Two features of the Qatari approach deserve attention because they are unusual in the region.

The first is assurance. QFMA guidance states that external assurance of the sustainability reporting framework shall be required, provided by the external auditor under Chapter Five of the Governance Code for listed companies. Separately, the QCB has said it will develop and implement an assurance framework for sustainability information. Assurance is the step most Gulf frameworks have deferred, and Qatar approaching it first is a meaningful signal about where regional expectations settle.

The second is proportionality. QFMA guidance sets out the transition reliefs available in the first year of applying the standards, with the IFRS S2 reliefs extended by an additional year from 2026, the first reporting year. That mirrors the approach taken in the UK and elsewhere and suggests Qatar is implementing the ISSB framework as designed rather than selectively.

The UAE: The Broadest Reach of the Three

The UAE has taken the opposite approach to Qatar. Rather than starting with listed companies or financial institutions, it started with everybody.

Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects came into force on 30 May 2025 and made the UAE the first MENA state with a binding federal climate law. Full compliance was due by 30 May 2026. It applies to public and private entities whose activities generate greenhouse gas emissions, across the Emirates and including free zones, creating obligations to measure, report and reduce emissions through the national Monitoring, Reporting and Verification system. Penalties run from AED 50,000 to AED 2 million per violation, doubling to a maximum of AED 4 million for repeat offences within two years.

Listed companies carry separate obligations on top. Public joint stock companies on the Abu Dhabi Securities Exchange and Dubai Financial Market must publish an annual sustainability report under Securities and Commodities Authority rules, filed within 90 days of financial year end or before the annual general meeting, whichever comes first.

The financial free zones add a third layer. ADGM operates its own ESG Disclosures Framework, applying from the third year following incorporation to companies with turnover above USD 68 million, and to FSRA licensed fund and asset management companies with assets under management above USD 6 billion. It runs on a comply or explain basis, with companies choosing not to comply required to submit a clear explanation to the Registrar, and several entity types including foundations, limited liability partnerships, branches of foreign companies and listed entities already making equivalent disclosures sit outside scope entirely. DIFC maintains its own arrangements, and the Central Bank has issued sustainability disclosure principles for financial institutions.

The practical consequence is that a UAE group can be running three or four overlapping frameworks simultaneously, and they do not satisfy one another. Entity level mapping across mainland, ADGM and DIFC is the first piece of work and the one most often done badly.

Saudi Arabia: The Largest Market, Still Voluntary

Saudi Arabia has the biggest listed market of the three and the lightest formal requirement.

The Capital Market Authority issued voluntary ESG disclosure guidance in 2019. The Saudi Exchange followed with a structured ESG Disclosure Guidelines framework in 2021, referencing GRI and SASB indicators, having joined the UN Sustainable Stock Exchanges Initiative in 2018. Both remain voluntary. There is no confirmed date for mandatory ISSB adoption, although the CMA has signalled its intention to converge, and the Ministry of Economy and Planning has been working toward unified national ESG guidelines.

One mandatory pocket does exist. In 2025 the CMA formalised a framework for green, social, sustainability and sustainability-linked debt instruments, which carries binding disclosure obligations for issuers of those instruments. So a Saudi company that issues a green sukuk faces mandatory ESG disclosure that its equity listed peer does not.

The more interesting signal is behavioural rather than regulatory. Reporting has become normal among the largest Saudi issuers even without a mandate, with roughly two thirds of the top 100 Tadawul companies by revenue now publishing ESG disclosures, while uptake across the full market remains considerably thinner. The Saudi Exchange group published its own first sustainability report in 2025. A mid cap company is now measured against the disclosure standard set by the largest issuers, whether or not any rule requires it.

The strategic context matters here. Vision 2030 and the Kingdom's 2060 net zero target both create policy momentum that points in one direction, and the gap between voluntary status and market expectation is where Saudi companies are currently operating.

Where the Three Stand

The Pressure that is not in any Rulebook

The most underrated driver of Gulf sustainability reporting is not a regulator. It is the region's sovereign wealth funds.

ADIA, Mubadala, ADQ, PIF and QIA together managed roughly USD 4.1 trillion as of 2023, and projections put the combined assets of the region's sovereign funds substantially higher by 2030. Four of the world's ten largest sovereign wealth funds are in the Gulf. These are not passive index investors. They take large direct stakes, co-invest alongside private equity sponsors, and hold positions for decades.

That matters for disclosure because their own commitments flow downward. PIF is one of the founding members of the One Planet Sovereign Wealth Funds network, whose 2018 framework set out how climate change should be integrated systematically into investment decision making, and which has since extended to asset managers and private equity firms. PIF's published ESG roadmap includes developing ESG policy and guidelines for portfolio companies and ensuring disclosures according to international standards. ADIA, Mubadala, QIA and PIF have all committed to the Santiago Principles on transparency and governance.

The practical translation for a Gulf company is straightforward. If a sovereign fund is on your register or in your capital structure, you are likely to face reporting expectations set by that investor's own framework rather than by your national regulator, and those expectations generally reference international standards rather than local guidance. A Saudi portfolio company can find itself reporting to a standard the CMA has not yet mandated, because PIF asked.

It is worth being even handed about the limits here. Independent assessments consistently note that Gulf sovereign funds operate with materially less transparency than their Nordic or Australasian counterparts, and that the closeness between these funds and their political leaderships complicates the credibility of voluntary commitments. The influence on portfolio company disclosure is real. The funds' own disclosure is a separate question.

The Signals Actually Worth Watching

Four things will tell you where this goes next.

Whether Saudi Arabia sets an ISSB date. The CMA has signalled convergence without committing to a timeline. Given the size of the Saudi market, a confirmed date would effectively set the regional pace, and it is the single highest impact announcement pending in the Gulf.

Whether Qatar extends the mandate beyond financial institutions on schedule. Qatar has proved the regional appetite for binding ISSB adoption. Completing the extension to the full QSE listed market across 2026 and 2027 would make it the first Gulf state with a comprehensive mandatory regime.

Whether assurance spreads. Qatar contemplating external auditor assurance is ahead of the region. If the UAE or Saudi Arabia follow, the cost and control implications for companies are considerably larger than the disclosure requirements themselves.

Whether the GCC baseline gets teeth. The 29 metric framework is currently a voluntary regional floor. Any move to make it binding, or to formally align it with IFRS S1 and S2, would simplify multi jurisdiction compliance significantly.

The underlying pattern across all three markets is that formal requirements lag actual expectations. Saudi reporting is voluntary but commonplace among large issuers. UAE requirements are broad but fragmented across authorities. Qatar is binding but still completing its rollout. In every case the companies facing real pressure are doing so because of investors, lenders and sovereign fund shareholders rather than because of a filing deadline. Building to IFRS S1 and S2 is the response that works under all three regimes and under the investor pressure that precedes them.

Gulf Readiness Checklist

1. Map obligations entity by entity, since UAE mainland, ADGM, DIFC, QSE, QFC and Tadawul listings each carry different requirements that do not satisfy one another.

2. Treat the GCC Exchanges 29 metric set as your baseline, since it is comparable across all six member states.

3. Build to IFRS S1 and S2 regardless of your current jurisdiction, because every Gulf regulator is converging on them.

4. For UAE entities, confirm your position under Federal Decree-Law No. 11 of 2024, which applies to free zone companies and had a compliance deadline of 30 May 2026.

5. For UAE listed companies, diarise the SCA filing window of 90 days after financial year end or before the annual general meeting, whichever falls first.

6. For ADGM entities, check the USD 68 million turnover and USD 6 billion assets under management thresholds and remember the comply or explain route requires a written explanation to the Registrar.

7. For Qatari financial institutions, confirm your QCB or QFCRA obligation, which began on 1 January 2026 using 2025 data.

8. For QSE listed companies, verify current status directly with QFMA rather than relying on secondary summaries, since guidance and Governance Code positions have not fully aligned.

9. For Saudi issuers of green, social, sustainability or sustainability-linked debt, note that disclosure is already mandatory for you even though equity issuers remain voluntary.

10. If a sovereign wealth fund holds a position in your company, ask what its own reporting framework expects, since that will usually exceed the national requirement.

Position as of July 2026. Gulf sustainability reporting frameworks are moving quickly and several are mid transition, particularly in Qatar. Confirm current obligations directly with the CMA, Saudi Exchange, SCA, ADGM, DIFC, QFMA, QCB and QFCRA as applicable, and take professional advice for your circumstances.

Sources

Capital Market Authority of Saudi Arabia, Saudi Exchange, Public Investment Fund, One Planet Sovereign Wealth Funds framework, Abu Dhabi Global Market, Central Bank of the UAE, Qatar Stock Exchange, GCC Exchanges Committee, World Federation of Exchanges, United Nations Sustainable Stock Exchanges Initiative, IFRS Foundation, Santiago Principles, Norton Rose Fulbright, Cleary Gottlieb, Bahrain Bourse, Corporate Disclosures, Ghazzawi Law Firm, Stiftung Wissenschaft und Politik, HLB, Spectreco, STA Terra

This article is intended for general professional information and does not constitute legal, financial, or investment advice.