Sustainability Reporting Requirements in the UAE

Last updated: May 28, 2026. Sustainability reporting in the UAE is now a layered compliance question. Listed public joint stock companies have ESG and sustainability reporting expectations through the Securities and Commodities Authority (SCA), Abu Dhabi Securities Exchange (ADX), and Dubai Financial Market (DFM). ADGM has a separate ESG Disclosures Framework for certain ADGM entities. Financial-sector regulators have adopted common sustainability-related disclosure principles. In addition, Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects is moving the UAE from voluntary climate ambition toward legally enforceable greenhouse gas measurement and reporting.

Short answer: UAE companies should first identify which route applies to them. A listed company on ADX or DFM should prepare annual sustainability or ESG disclosure as part of its public-company reporting. An ADGM company may need to comply or explain under ADGM's ESG Disclosures Framework if it meets the turnover or AUM thresholds. Financial institutions should track the UAE Sustainable Finance Working Group disclosure principles and the rules of their own regulator. Public and private entities operating in the UAE, including free-zone entities, should also assess their exposure under the UAE Climate Change Law, which requires monitoring and reporting greenhouse gas emissions in accordance with approved methodologies.

Why UAE sustainability reporting has changed

The old way to describe UAE sustainability reporting was simple: listed companies report, most private companies disclose voluntarily. That is no longer enough. The UAE has combined capital-market ESG disclosure, financial-sector sustainable finance principles, free-zone ESG frameworks, and a federal climate law.

The result is not one single sustainability report requirement for every company. It is a set of overlapping routes:

SCA, ADX, and DFM expectations for public joint stock companies and listed issuers;
ADGM ESG disclosures for in-scope ADGM entities meeting threshold conditions;
SFWG sustainability-related disclosure principles for reporting entities in the UAE financial sector;
Federal climate-law obligations around greenhouse gas emissions monitoring, reporting, reduction, and climate-risk management; and
market-driven requests from customers, banks, investors, free-zone authorities, government tenders, and multinational buyers.

Who needs to report sustainability information in the UAE?

The answer depends on the company's legal status, exchange listing, regulator, sector, free-zone location, and emissions profile.

ADX and DFM listed companies

Public joint stock companies listed in the UAE are the clearest sustainability-reporting audience. SCA's public-company governance framework incorporates sustainability disclosure requirements, while ADX and DFM provide ESG reporting guidance to help issuers structure disclosures and respond to investor expectations.

In practice, listed issuers should be ready to disclose their sustainability strategy, environmental performance, social and workforce information, governance approach, economic contribution, material ESG issues, and greenhouse gas emissions where relevant. ADX's 2025 ESG Disclosure Guidance also points issuers toward recognised global frameworks such as IFRS Sustainability Disclosure Standards, GRI, the Sustainable Stock Exchanges initiative, and World Federation of Exchanges guidance.

ADGM entities

ADGM has its own ESG Disclosures Framework. The ADGM summary says the framework applies to ADGM entities unless they are out of scope, exempt, or do not meet threshold conditions. In-scope ADGM companies meeting the threshold conditions must either comply with the ESG disclosure requirements or explain non-compliance.

The key ADGM thresholds are:

more than US$68 million turnover in a financial year; or
for FSRA-licensed fund and asset management companies, assets under management above US$6 billion at any time during the financial year.

ADGM disclosures must be prepared using a globally recognised standard, such as CDP, GRI, ISSB, or TCFD. Submissions are made with the company's annual accounts, or in a separate document that accompanies those accounts, through the ADGM process.

Financial institutions and regulated financial entities

The UAE Sustainable Finance Working Group launched Principles for Sustainability-Related Disclosures for Reporting Entities in 2024. The SFWG includes the Ministry of Finance, Ministry of Economy, Ministry of Climate Change and Environment, the Office of the UAE Special Envoy for Climate Change, CBUAE, SCA, ADGM FSRA, DFSA, ADX, DFM, and Nasdaq Dubai.

The principles are important because they set common minimum expectations for sustainability-related disclosure frameworks across UAE financial-sector authorities. They highlight policies, procedures, and systems for sustainability reporting; transparency, materiality, relevance, and stakeholder engagement; disclosures that reflect governance, strategy, and risk management; and product-level transparency for sustainability-related products.

Public and private companies under the Climate Change Law

Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects entered into force on 30 May 2025. The Law Library of Congress describes the law as applying to public and private sector entities operating in the UAE, including free-zone entities, and requiring them to measure, report, and manage greenhouse gas emissions.

For companies, this is a major shift. Even if a company is not listed, not in ADGM, and not a financial institution, it may still need to prepare for greenhouse gas monitoring, emissions data retention, reporting under approved methodologies, climate-risk assessment, and reduction planning. The practical details depend on implementing rules, competent authorities, sector treatment, and any reporting platform or forms specified by the Ministry of Climate Change and Environment or local authorities.

Private companies and suppliers

Private UAE companies may not need a full public ESG report, but they can still be asked for sustainability data by customers, banks, investors, landlords, government procurement teams, or global supply-chain partners. Common requests include Scope 1 and Scope 2 emissions, energy use, climate-risk information, labour and health-and-safety policies, waste and water data, and supplier due-diligence information.

For these companies, the practical goal is often a concise sustainability data pack rather than a long report. The data pack should be credible enough to answer customer and lender questions, and structured enough to become a full report if obligations expand.

What should a UAE sustainability report include?

A UAE sustainability report should be proportionate to the company's obligation. A listed issuer or large regulated entity will need more detail than a private supplier, but the core building blocks are similar.

Reporting boundary: which legal entities, operations, sites, and subsidiaries are included.
Governance: board and management oversight of ESG, climate, and sustainability risks.
Strategy: how sustainability topics affect the company's business model, long-term strategy, investment plans, and stakeholder relationships.
Materiality: the environmental, social, and governance topics most relevant to the company and its stakeholders.
Environmental data: energy, Scope 1 and Scope 2 GHG emissions, relevant Scope 3 categories, water, waste, pollution, and resource use where material.
Climate information: climate-related risks and opportunities, transition actions, targets, adaptation measures, and reduction plans.
Social data: employees, health and safety, diversity, training, labour practices, community impact, and supplier expectations.
Governance data: board structure, independence, ethics, anti-corruption, risk management, data controls, and policy commitments.
Methodology and evidence: calculation methods, assumptions, emission factors, source files, data owners, and internal review steps.

Greenhouse gas reporting is becoming central

The UAE's sustainability-reporting conversation is increasingly emissions-led. Listed issuers face investor and exchange expectations. ADGM entities may need disclosure aligned to global standards. Financial institutions are being pushed toward more consistent sustainability-related disclosures. The Climate Change Law creates a federal legal basis for emissions monitoring and reporting.

Companies should therefore build greenhouse gas data systems early, even where the exact reporting form is still developing. A practical UAE GHG inventory should include:

Scope 1 emissions from owned or controlled fuel combustion, vehicles, generators, refrigerants, and industrial processes;
Scope 2 emissions from purchased electricity, cooling, steam, or heating where relevant;
relevant Scope 3 categories where customers, lenders, investors, or regulators request value-chain information;
site-level activity data and evidence files;
emission factors and calculation methodology;
clear treatment of estimates, missing data, and restatements; and
internal sign-off by finance, operations, facilities, and sustainability owners.

Common mistakes

The first mistake is assuming that sustainability reporting in the UAE is only for listed companies. Listed-company reporting is still important, but the ADGM framework, financial-sector disclosure principles, and federal climate law mean the obligation map is wider.

The second mistake is treating ESG reporting as a marketing exercise. Investors and regulators are moving toward decision-useful disclosures tied to governance, strategy, risk management, metrics, and targets. Claims need evidence.

The third mistake is starting with report design before building the data. The report is the output. The hard part is boundary-setting, data collection, emissions calculations, internal controls, and management review.

The fourth mistake is ignoring free-zone and customer requirements. A company may be outside one regime but inside another, or it may be commercially exposed because a customer, bank, investor, or tender requires sustainability data.

What companies should do now

Before drafting a sustainability report, UAE companies should complete a short applicability review:

Is the company listed on ADX, DFM, Nasdaq Dubai, or another market?
Is it a public joint stock company subject to SCA governance requirements?
Is it established in ADGM, DIFC, or another free zone with relevant ESG expectations?
Does it meet ADGM's turnover or AUM thresholds?
Is it regulated by CBUAE, SCA, ADGM FSRA, DFSA, or another financial regulator?
Does the Climate Change Law create GHG monitoring, reporting, reduction, or adaptation obligations for its operations?
Are customers, lenders, investors, or government tenders asking for sustainability or emissions data?
Does the company already have energy, fuel, refrigerant, waste, water, workforce, and governance data in usable form?

Once the route is clear, the company can choose the right level of work: a listed-company ESG report, an ADGM disclosure, a GHG emissions inventory, a climate-law readiness review, a customer-response data pack, or a broader sustainability report.

How Keslio can help

Keslio helps UAE and regional companies translate sustainability requirements into practical reporting work. We can support:

UAE sustainability reporting applicability reviews;
SCA, ADX, DFM, and ADGM ESG disclosure gap checks;
Climate Change Law GHG readiness reviews;
Scope 1, Scope 2, and relevant Scope 3 emissions calculations;
data request templates and evidence trackers;
materiality assessments and stakeholder input;
sustainability reporting and communications support;
supplier and customer-request response support; and
annual refreshes once the reporting process is in place.

Official sources and further reading

Conclusion

UAE sustainability reporting is no longer a single listed-company exercise. Listed issuers still need strong ESG reporting, but ADGM threshold rules, financial-sector disclosure principles, customer expectations, and the Climate Change Law all affect how companies should prepare.

The right first step is to confirm the applicable route, then build the data and evidence needed for that route. For many companies, the foundation is a clear reporting boundary, a reliable greenhouse gas inventory, and a concise sustainability data pack that can support a report, regulator submission, lender request, or customer questionnaire.