Navigating ESG Regulations in the Middle East: Compliance, Strategy & Disclosure

As ESG (Environmental, Social, and Governance) practices become central to business strategy, the Middle East is witnessing a surge in regulatory frameworks to align with global sustainability standards. This blog summarizes key insights from our webinar on ESG regulations across the region and offers a practical roadmap for ESG reporting.

The Evolution of ESG in the Middle East

Over the last two decades, ESG has evolved from CSR (Corporate Social Responsibility) to a strategic imperative. Global and regional milestones shaping ESG include:

  • COP18 (Doha, 2012): Advanced sustainable finance and technology transfer
  • COP28 (Dubai, 2023): Reinforced global fossil fuel transition and accountability gaps
  • GCC Unified ESG Metrics (2023): Announced by Gulf Exchange for listed companies
  • UAE Free Zones ESG Mandate (2023) and Islamic Finance ESG Rule (Saudi Arabia, 2022)

Country-Level ESG Regulations Overview

United Arab Emirates (UAE)

  1. Capital Market Requirements:
    • DFM and ADX require ESG disclosures under Securities & Commodities Authority (SCA)
    • Integrated Reporting + Sustainability Report mandated by Article 76 of Joint Stock Companies Guide
    • ESG disclosure guides (DFM 2023, ADX 2019) provide 30 KPIs
  2. Climate Law (2024):
    • Federal Decree Law 11 mandates climate action for all public and private entities starting May 30, 2025
    • Requires GHG inventory (Scopes 1, 2, 3), reduction strategy, and data archiving
    • Penalties: AED 50,000 to AED 2 million
  3. Net Zero Target: 2050 (rated "Average" by Climate Action Tracker)

Oman

  • Muscat Stock Exchange (MSX): Mandatory ESG disclosure (30 KPIs) from March 31, 2025
  • Net Zero Target: 2050
  • Clear 2030, 2040, and 2050 emission targets for top 5 emitting sectors (Industry, Oil & Gas, Transport, Buildings, Power)
  • Vision 2040: Integrates GDP and climate goals

Saudi Arabia

  • Saudi Exchange: ESG disclosure is voluntary (aligned with GRI, TCFD)
  • Vision 2030: Aligns ESG with development and diversification
  • Net Zero Target: 2060 (Rated "Poor" by Climate Action Tracker)
  • Reduce GHGs by 278 MtCO₂e by 2030; plant 600M trees

Qatar

  • Qatar Stock Exchange: ESG disclosures are voluntary but encouraged
  • Climate Goals: 25% emission reduction by 2030; 4 GW renewables; 30% land/marine protected

Kuwait

  • Boursa Kuwait: Mandatory ESG reporting (30 KPIs) from FY2025
  • No net zero target yet
  • National Development Plan 2035: Focuses on renewable energy

Bahrain

  • Bahrain Bourse: ESG disclosures are voluntary (29 KPIs)
  • Vision 2030: Sustainability as a core principle

Other Countries

  • Net-zero targets in Cyprus, Israel, Jordan, Palestine, Turkey
  • SSE Initiative signatories with voluntary ESG reporting

Roadmap for ESG Reporting in the Middle East

Whether you're a listed company or private enterprise, here’s how to get started:

  1. Understand Regional Requirements: Identify exchange rules and national laws (e.g., UAE Climate Law, MSX Guide). Determine if disclosure is mandatory.
  2. Conduct Materiality Assessment: Use GRI 3 or stakeholder engagement to identify ESG topics.
  3. Develop a GHG Inventory: Include Scopes 1, 2, 3 to baseline emissions.
  4. Set Climate Goals: Align with national targets (e.g., UAE’s 2050 goal, Oman’s sector cuts).
  5. Build a Mitigation Plan: Consider energy efficiency, renewables, offsets.
  6. Compile ESG Report: Follow frameworks (GRI, TCFD, SASB, CDP); include KPIs per country guidance.
  7. Conduct Assurance: Opt for limited/reasonable assurance for emissions/KPIs.
  8. Publish Report: Use website and/or exchange portals (e.g., MSX ESG Platform).

Case Study: UAE Public Bank (Hypothetical)

  • Regulation: Must follow ADX ESG Guide + SCA report
  • Materiality: Use GRI 3 to prioritize emissions, governance, data privacy
  • GHG Inventory: Scope 1 (branches), Scope 2 (power), Scope 3 (commute, vendors)
  • Mitigation: Green branches, solar procurement, carbon offsets
  • Reporting: Limited assurance, publish on corporate site

How Sustainium Can Help

  • Automated carbon accounting (Scopes 1, 2, 3)
  • Disclosure-ready reports for UAE, KSA, Oman, Kuwait
  • Regional emission factor libraries (Arabic/English)
  • Multi-site, multi-subsidiary dashboards
  • Expert help for ESG strategy, materiality, and assurance

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