GCC ESG Disclosure Roundup: UAE vs. Saudi vs. Wider Region

Ask "is ESG reporting mandatory in the GCC?" and the honest answer is: it depends entirely on which country, which regulator, and which type of company you mean. The region moved from largely voluntary frameworks to a genuinely layered, partly mandatory landscape between 2024 and 2026 — but not at the same pace or in the same way everywhere. Here's how the major jurisdictions actually compare.

UAE — mandatory, and the most layered

The UAE has moved furthest and fastest, but "mandatory" here means several overlapping regimes rather than one rule:

• Federal Decree-Law No. 11 of 2024 (the Climate Law) — entered into force May 30, 2025, applies federally, and creates a binding legal obligation to measure, report, and reduce GHG emissions. Full compliance was expected by May 30, 2026. Fines for violations range from AED 50,000 to AED 2,000,000, doubling for repeat offenses within two years.
• SCA Corporate Governance Guide (Article 76) — requires all listed public joint stock companies on ADX or DFM to publish an annual sustainability report, submitted within 90 days of financial year-end or before the AGM, whichever is earlier. This is already in force, with IFRS S1/S2 alignment expected from FY2026.
• ADGM — a comply-or-explain ESG Disclosures Framework for companies above certain size thresholds (turnover above roughly $68 million, or assets under management above roughly $6 billion), effective since June 2023.
• DIFC — guidance-based rather than mandated, though DIFC-regulated firms are expected to integrate ESG into governance.
• Central Bank of the UAE — has issued sustainable finance disclosure principles for financial institutions, with a September 2026 compliance deadline.

The practical challenge for UAE-based groups: if you operate across mainland, ADGM, and DIFC, you may be running three overlapping — but not identical — frameworks at once.

Saudi Arabia — voluntary in name, increasingly mandatory in practice

Saudi Arabia hasn't yet mandated general ESG reporting for listed companies, but the gap between "voluntary" and "expected" has narrowed sharply:

• The Capital Market Authority (CMA) issued its first ESG guidance in 2019; the Saudi Exchange (Tadawul) built a structured ESG Disclosure Framework on top of it in 2021 (aligned with GRI and SASB). Both remain formally voluntary.
• What is mandatory: since 2025, the CMA requires ongoing ESG disclosures for issuers of green, social, sustainable, and sustainability-linked debt instruments.
• Market pressure is doing a lot of the regulatory work here: the number of Tadawul-listed companies voluntarily publishing sustainability reports rose from 81 in 2023 to 94 in 2024, and roughly 65% of the top 100 companies by revenue now report on ESG.
• No confirmed date exists yet for a full mandatory regime, but every signal from the CMA and Tadawul points toward eventual ISSB (IFRS S1/S2) alignment.

Qatar — moving from guidance to mandate in real time

• The Qatar Stock Exchange (QSE) has run voluntary ESG guidance since 2016/2017, with a Sustainability Platform for listed companies to disclose metrics.
• The Qatar Financial Markets Authority (QFMA) has updated its Governance Code to require sustainability- and climate-related disclosure for QSE-listed companies, aligning with ISSB/IFRS S1-S2, with the first reporting cycle based on 2025 data and submissions beginning in 2026.
• The Qatar Central Bank (QCB) has separately mandated ESG reporting for banks and regulated financial institutions, with the first cycle also based on 2025 data.
• Qatar is one of the jurisdictions the IFRS Foundation itself lists as having adopted ISSB-referencing mandatory rules effective at the start of 2026 (alongside Chile and Mexico).

Oman — mandatory and already fully rolled out for listed companies

Oman moved earliest and cleanest: under Administrative Decision 77/2025, sustainability reporting became mandatory from January 2025 for all companies listed on the Muscat Stock Exchange (MSX) Main and Parallel markets, disclosing against 30 GRI-aligned metrics within the first quarter of the financial year. Oman reportedly achieved 100% compliance in its first mandatory reporting cycle. The Central Bank of Oman separately mandates climate reporting for banks.

Kuwait — mandatory for Premier Market companies

Under CMA Circular 04/2025, Kuwait's Premier Market companies must publish ESG reports covering 30 KPIs starting from FY2025, with reports due by June 30, 2026. Boursa Kuwait's ESG Disclosure Guide is ISSB-aligned.

Bahrain — earliest mover, financial-sector focused

The Central Bank of Bahrain enforced ESG reporting for listed corporations and financial institutions starting in 2024, covering Scope 1, 2, and 3 emissions aligned with GRI, with non-compliance fines up to BHD 15,000.

The common thread across the region

Every GCC state has moved in the same direction — voluntary guidance first, then mandatory rules for listed and financial-sector entities, all converging toward ISSB (IFRS S1/S2) as the shared technical baseline. The GCC Exchanges Committee published a harmonized set of 29 ESG disclosure metrics back in January 2023 (10 environmental, 10 social, 9 governance), which several national frameworks build on. If your company operates across more than one GCC market, that shared metric set — rather than any single national rule — is probably the most useful starting point for a regional reporting approach.