Labeeb Reference · verified against the instruments, August 2026 · informational, not legal or assurance advice
GCC Sustainability Reporting: What Is Actually Mandatory
Six markets, six different answers — and most of what circulates online is wrong about at least one of them. We read the instruments: the decisions, the listing rules, the circulars. This page states each market’s real status, names the instrument behind it, and is explicit where a rule could not be verified from a primary source. It also lists the claims we found to be false, including two we had to correct on our own pages.
As of August 2026: sustainability reporting is mandatory for Kuwait’s Premier Market, Bahrain’s Mainboard and Qatar’s main market; the UAE reaches it through the integrated report rather than a standalone sustainability mandate; Saudi Arabia has no sustainability-reporting mandate at all — but the strictest language rule in the region; and Oman’s duty rests on its exchange’s own guideline, with IFRS S1 and S2 phased in only from 2029. If you report in more than one market, you are complying with several different instruments that share almost nothing but a metric set.
Market by market — the verified position
Kuwait — mandatory, and the deadline has teeth
CMA Circular No. (04) of 2025, issued 12 February 2025 under the Listing Rules, makes sustainability reporting mandatory for Premier Market companies from financial year 2025, to be disclosed on the Boursa website by the end of the second quarter — end of June 2026 — explicitly flexed for non-December year-ends. Boursa Kuwait’s 2026 guide (released 15 March 2026) recommends 30 metrics, but the guide is guidance; the circular is the mandate. Premier Market listed 39 participants when we checked. Official-primary (CMA Kuwait).
Bahrain — mandatory, two layers
Bahrain Bourse Listing Rules v5.0 (Board Resolution 3/5/2024, dated 30 September 2024) Rule 5.22: an issuer shall submit its ESG report no later than 6 months after financial year-end, separately or inside the annual report — binding on Mainboard issuers. Underneath sits the CBB Rulebook ESG module, first issued November 2023, requiring an annual ESG report built on 31 prescribed KPIs from FY2024, across listed companies, banks, insurers, Category 1 and 2 investment firms and financing companies. Official-primary (BHB Listing Rules; CBB Rulebook).
Qatar — mandatory on the main market
The QFMA Governance Code for Listed Companies, Board Decision No. (5) of 2025, issued 4 August 2025 and effective 18 August 2025, requires main-market companies to comply while secondary-market companies work on comply-or-explain. Article 11 obliges disclosure of the annual sustainability report, and Appendix 1 requires ESG performance disclosed in the annual report per ISSB and OECD standards, naming carbon emissions, energy, water, waste and Qatarization. Companies had to reconcile their position within one year of gazette publication — 17 August 2026 — a period the QFMA Chairman may extend. Separately, QCB requires banks and insurers to report under ISSB standards for periods beginning 1 January 2026, with year-one relief allowing IFRS S2 only and no Scope 3 in the first two years. Official-primary (QFMA; QCB). The first financial year covered is not stated in the Code — we will not guess it.
UAE — through the integrated report
There is no standalone sustainability-report mandate. Listed public joint stock companies file an integrated report under the governance guide of the UAE Capital Market Authority — renamed from the Securities and Commodities Authority effective 1 January 2026 — which names the sustainability report as one branch folded in, and delegates the substance to the markets’ own instructions. The widely-quoted 90-day deadline is ADX’s (Operational Rules Article 9(6)), not the governance guide’s; the regulator’s own AGM circular runs from the start of the financial year — within three months of it and at least ten days before the general assembly, whichever comes first. Both exchange ESG guides describe themselves as voluntary: ADX’s current June 2025 edition carries 35 metrics, DFM’s 2025 guide is voluntary too. Foreign companies listed in the market are excluded from the governance guide. Official-primary (UAE CMA; ADX; DFM).
Saudi Arabia — no mandate, strictest language rule
The Saudi Exchange ESG Disclosure Guidelines are framed throughout as encouragement — they contain no obligation language and no comply-or-explain mechanism, and they set out no metrics. We searched the current Rules on the Offer of Securities and Continuing Obligations and the Listing Rules for sustainability, ESG, green, environmental and climate: zero occurrences in each. There is no published mandate, draft rule or dated ISSB roadmap. The one hard edge is debt: under CMA-approved guidelines in force from 27 May 2025, issuers of riyal-denominated green, social, sustainability and sustainability-linked instruments must disclose any non-compliance with the guidance and, for public offerings, publish the framework and external reviewer report on Tadawul. Official-primary (Saudi Exchange; CMA).
Oman — exchange-led, with a 2029 horizon
The Muscat Stock Exchange’s own ESG Disclosure Guideline requires listed SAOG companies to report on 30 metrics — 29 unified with the GCC set plus one MSX-specific CSR metric — and states that while disclosure was voluntary in 2024, reporting became mandatory from 2025. Separately, FSA Decision E/7/2026 (17 March 2026) adopts IFRS S1 and S2 with a phase-in from 1 January 2029, and Scope 3 from 2030 — and it is addressed to accountants and auditors rather than to issuers directly. MSX guideline: official-primary. FSA decision: corroborated via the national legislation database. The separate FSA ESG decision commonly cited for this requirement could not be obtained from any primary source — the regulator’s own portal and the national legislation index return nothing — so we do not restate its number, filing deadline or scope from secondary alerts.
Across all six markets, the common denominator is the GCC ESG Disclosure Metrics published by the GCC Exchanges Committee on 9 January 2023 — 29 metrics (10 environmental, 10 social, 9 governance), explicitly voluntary and not a replacement for each exchange’s own guidance. Statuses and deadlines change; confirm against the instrument before you file. This page records what the rules say — it is not legal, assurance or compliance advice, and we are not auditors.
Commonly misstated — including by us
“The SCA requires an annual sustainability report within 90 days, in line with GRI.” Three errors in one sentence. The regulator is the UAE Capital Market Authority since 1 January 2026. The article usually cited governs the integrated report, and sustainability appears as a branch of it rather than in the enumerated required contents. The 90-day clock is ADX’s rule, and the regulator’s own circular measures from the start of the financial year, not the end. And GRI is named nowhere in either instrument — it appears only in the exchanges’ voluntary guides, alongside other frameworks. We had published a version of this claim ourselves; it is corrected as of 19 August 2026.
“The UAE mandates ISSB / IFRS S1–S2 for listed companies.” No such instrument exists. The regulator’s own 2024 principles paper describes ISSB among frameworks operating on a voluntary basis and leaves each authority to choose between voluntary, comply-or-explain and mandatory routes, and to set its own timeline.
“Saudi listed companies must report sustainability bilingually, Nomu included.” The bilingual rule is real and strict — but it is a disclosure rule, not a sustainability mandate, and it is Main Market only. Listing Rules Article 30 requires Main Market notifications and disclosures in Arabic and English; on the Parallel Market, Arabic is required and English is optional. Where an English version exists it must be identical to the Arabic, and the Arabic text prevails in any conflict — a rule that reaches Nomu as well.
“Bahrain’s CBB has required IFRS S1/S2 since March 2025.” There is no such instrument. The CBB ESG module was first issued November 2023 and prescribes 31 KPIs from FY2024; IFRS S1 and S2 appear once, in a descriptive list of widely-used frameworks.
“Muscat’s exchange reported 100% ESG compliance.” That figure belongs to the Amman Stock Exchange in Jordan — a confusion between بورصة عمان (Amman) and سلطنة عُمان (Oman), which share a spelling. The Muscat exchange has published no such statistic.
Metric counts drift, and exchanges contradict themselves. ADX serves both its current 35-metric guide and a superseded 31-metric edition; one DFM guide states a metric count its own table does not match; and the 29-metric figure widely attributed to Saudi Arabia’s guidelines actually belongs to the GCC unified set — the Saudi guidelines contain no metrics at all. If a number matters to your filing, take it from the edition your exchange currently links.
The language question, answered properly
Saudi Arabia — Arabic governs
Main Market disclosures must exist in Arabic and English; where both exist they must be identical; and in any conflict the Arabic version prevails. That makes the Arabic text the operative one — not a courtesy translation produced after sign-off.
UAE — bilingual by circular
The regulator’s AGM circular requires the governance report and the integrated report — and disclosures published on the market’s and the company’s websites — in both Arabic and English. Since the integrated report includes the sustainability report as a component, the bilingual duty reaches it.
DIFC and ADGM — the opposite default
The financial free zones run on English; the DFSA’s markets rules contain no Arabic requirement at all. Any blanket claim that “UAE listed entities must report bilingually” is wrong for these. Know which rulebook your entity sits under before budgeting translation.
What this means for the document
One report, several rulebooks
A group listed in more than one Gulf market is writing to several instruments at once. The narrative has to satisfy the strictest of them without becoming unreadable — a writing problem before it is a compliance one. Annual & sustainability report writing
Arabic that is the record, not the echo
Where the Arabic text prevails, it deserves to be written — not machine-translated after the English is signed off. Native bilingual drafting in both directions. See how we work
Your data, our narrative — and the line between
We write and structure the report from figures your teams and auditors own. We do not calculate emissions, assure disclosures, or advise on compliance — and we say so on every page that touches a regulator. Business writing & design
The rulebook sets the duty. The report still has to be written.
Bilingual annual and sustainability reports for Gulf listed entities — from a studio that reads the instruments and publishes what it found.