ESG reporting in the UAE and Saudi Arabia: what is required in 2026
ESG reporting in the UAE is now partly a legal duty. Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects, in force since 30 May 2025, requires emitting entities to measure and report greenhouse gas emissions and keep records, and listed companies must publish annual sustainability reports. In Saudi Arabia, ESG reporting remains largely voluntary, guided by the Saudi Exchange's ESG Disclosure Guidelines, though investors, lenders and customers increasingly expect it.
ESG reporting in the UAE: the federal climate law
Federal Decree-Law No. 11 of 2024 is the first federal law in the UAE dedicated to climate change. It entered into force on 30 May 2025 and gave existing entities until 30 May 2026 to comply. It applies to public and private entities, including those in free zones, whose activities emit greenhouse gases. The law calls them "sources".
Core obligations
- Measure greenhouse gas emissions from activities in the UAE and prepare an emissions inventory.
- Report periodically to the Ministry of Climate Change and Environment (MOCCAE) or the competent local authority, in the approved form.
- Keep records of measured emissions for at least five years and make them available to regulators.
- Reduce emissions through approved measures, such as energy efficiency, clean energy, carbon capture or offsetting, in line with the UAE's net-zero goal.
Fines for violations range from AED 50,000 to AED 2,000,000, and can be doubled for repeat offences within two years.
What is still being defined
The law itself does not set thresholds, scopes or a calculation method. Those come from MOCCAE and emirate-level authorities. In October 2025 MOCCAE launched a national measurement, reporting and verification (MRV) system, including an Integrated Emissions Quantification Tool. Which entities are designated as sources, reporting boundaries and verification rules are being issued in stages. MOCCAE indicated in 2026 that the 30 May 2026 deadline was expected to be extended once technical guidance is issued, but we found no formal confirmation of a new date.
Assume you are in scope unless you can show otherwise, and confirm your designation, deadline and reporting form with MOCCAE or your emirate's environmental authority.
Abu Dhabi and the carbon credit register
Some emirates have moved faster than the federal framework. In 2026 the Environment Agency – Abu Dhabi issued Resolution No. 3 of 2026 on measuring, reporting and verifying greenhouse gas emissions. It requires facilities in targeted sectors above an emissions threshold to register, prepare monitoring plans and reports, and have their data verified by verifiers registered with the agency. Facilities below the threshold may report voluntarily.
Separately, Cabinet Resolution No. 67 of 2024 created the National Register for Carbon Credits. Entities with Scope 1 and 2 emissions of 0.5 million tCO2e or more a year must register, report annually and have their inventory independently verified. Other entities may join voluntarily.
UAE listed companies: CMA, ADX and DFM
Listed public joint stock companies in the UAE must publish an annual sustainability report under the federal corporate governance rules. The federal securities regulator was renamed the Capital Market Authority (formerly the Securities and Commodities Authority) from 1 January 2026. The exchanges add guidance on what to report:
| Body | Guidance | Status |
|---|---|---|
| Abu Dhabi Securities Exchange (ADX) | ESG Disclosure Guidance for Listed Companies, first issued in 2019 with 31 indicators, updated in 2025 with reference to IFRS S1 and S2 and GRI | Guidance supporting the mandatory sustainability report |
| Dubai Financial Market (DFM) | ESG Reporting Guide, updated in 2025 with 32 metrics | Voluntary guidance |
| Abu Dhabi Global Market (ADGM) | ESG Disclosures Framework for in-scope ADGM entities above revenue or AUM thresholds, using a recognised standard such as ISSB, GRI or TCFD | Comply or explain |
| UAE Sustainable Finance Working Group | Principles for sustainability-related disclosures for regulated entities | Principles-based |
Neither ADX nor DFM has made IFRS S1 and S2 mandatory. Companies with international investors increasingly use them anyway; see our explainer on IFRS S1 and S2.
ESG reporting in Saudi Arabia
Saudi Arabia has no general legal requirement for companies to publish sustainability reports or emissions inventories. The main reference for listed companies is the Saudi Exchange's ESG Disclosure Guidelines, published in 2021, which encourage issuers to report on emissions, energy, water, workforce and governance. Disclosure under them is voluntary.
Pressure comes from elsewhere:
- National targets — Saudi Arabia has committed to net zero by 2060 under the Saudi Green Initiative.
- Sustainable debt — issuers of green, social, sustainability and sustainability-linked debt instruments face disclosure requirements under the Capital Market Authority's framework.
- Investors and lenders — international investors and banks request emissions and climate-risk data.
- Customers — exporters to the EU face CBAM data requests, and multinational customers ask suppliers for Scope 1 and 2 data.
Regulators have signalled interest in international standards, but no mandatory ISSB adoption date had been announced as of October 2026. Check the Capital Market Authority and Saudi Exchange for updates.
GCC ESG: the regional picture
In January 2023 the GCC Exchanges Committee published 29 unified ESG metrics for listed companies across Saudi Arabia, the UAE, Qatar, Kuwait, Bahrain and Oman. The metrics are voluntary and sit alongside each exchange's own guidance. They give companies a common baseline across the region.
| UAE | Saudi Arabia | |
|---|---|---|
| Emissions reporting law | Yes — Federal Decree-Law No. 11 of 2024 | No general requirement |
| Listed company sustainability report | Required annually | Voluntary, under exchange guidelines |
| Main exchange guidance | ADX, DFM | Saudi Exchange ESG Disclosure Guidelines (2021) |
| Net-zero target | 2050 | 2060 |
What companies in the Gulf should do now
- Confirm your status — under the UAE climate law, Abu Dhabi rules and the carbon credit register, by entity and by site.
- Build a GHG Protocol inventory — Scope 1 and 2 at minimum, by facility, with fuel, electricity and process data and evidence for each entry. Follow our step-by-step carbon footprint guide.
- Keep five years of records in a form a regulator or verifier can follow.
- Prepare for verification — Abu Dhabi and the carbon register already require it.
- Choose a reporting framework — GRI for impacts, IFRS S2 for investors, and ESRS if you have EU-listed parents or customers.
- Plan reductions — the UAE law expects reduction measures, not just reporting.
How EKOTRACE helps
EKOTRACE builds facility-level GHG Protocol and ISO 14064-1 inventories with versioned emission factors, data collection calendars, maker-checker approvals and evidence attached to each entry, giving verifiers a complete audit trail. Data can be hosted in the customer's region or on their own servers. The same data feeds sustainability reports mapped to GRI, ISSB/IFRS S1-S2 and ESRS, plus CBAM calculations for exporters. See GHG accounting, ESG reporting and compliance risk.
Frequently asked questions
Is emissions reporting mandatory in the UAE?
Yes, for entities whose activities emit greenhouse gases, under Federal Decree-Law No. 11 of 2024. Detailed thresholds, forms and deadlines are set by MOCCAE and emirate authorities, so confirm whether your entity has been designated and when it must report.
What are the penalties under the UAE climate law?
Fines range from AED 50,000 to AED 2,000,000 per violation, and can be doubled for a repeat violation within two years. Violations include failures to measure, report or keep records.
Is ESG reporting mandatory in Saudi Arabia?
Not generally. The Saudi Exchange's ESG Disclosure Guidelines are voluntary, though issuers of sustainable debt face disclosure requirements. Many listed companies report voluntarily because investors and customers ask for it.
Which framework should a GCC company use?
Start with a GHG Protocol emissions inventory, which every framework needs. Then use the exchange guidance where you are listed, and add GRI, IFRS S2 or ESRS depending on your investors and customers.