Sustainability Reporting in Qatar: A First-Time Reporter’s Guide to the ISSB

Qatar has moved faster on sustainability disclosure than almost anyone expected. Within six months of 2025, three regulators, the Qatar Financial Markets Authority (QFMA), the Qatar Central Bank (QCB) and the Qatar Financial Centre Regulatory Authority (QFCRA), each adopted the ISSB Standards, IFRS S1 and IFRS S2, as mandatory requirements with no local modifications.⁵ The first reporting period is the financial year beginning on or after 1 January 2026: the report you publish in early 2027 covers the year you are living through right now.

This guide is for first-time reporters in finance, risk or investor relations: what is mandatory, what the standards require, and how to be ready in twelve months.

Why is sustainability reporting rising up the agenda in Qatar?

Disclosure rules rarely appear from nowhere. Qatar National Vision 2030, launched in 2008, made environmental development one of its four pillars, alongside diversification away from hydrocarbon dependence.¹ The National Environment and Climate Change Strategy (2021) translated that ambition into targets, including a 25% reduction in greenhouse gas emissions by 2030 against business-as-usual.^3,4

In November 2025 Qatar submitted its third Nationally Determined Contribution (NDC 3.0) under the Paris Agreement, a bottom-up, project-based approach targeting 42 million tonnes of CO₂e in emission reductions by 2040, with commitments to eliminate routine flaring, drive methane towards near-zero across all assets under OGMP 2.0 reporting, and decarbonise the LNG fleet.²

The commercial logic is just as important as the policy logic. Qatar is doubling down on LNG through the North Field expansion, marketing that gas to buyers in Europe and Asia whose regulators increasingly demand emissions data on imported energy. QatarEnergy has committed around US$170 million to flare and methane reduction and positions Qatari LNG on its carbon credentials.⁴ International investors in QSE-listed companies, meanwhile, expect the disclosures they receive from London or Singapore, and with more than 35 jurisdictions adopting or moving towards the ISSB Standards,¹⁴ a market that wants inward portfolio investment cannot stay silent.

The takeaway: this is the reporting arm of a twenty-year national strategy, not a passing compliance fashion, and full adoption of the international baseline was the fastest route to credibility.

What are Qatar’s ESG reporting requirements in 2026?

The landscape now has three mandatory tracks and a voluntary layer beneath them. Be precise about which instrument applies: the standards are identical, but supervisors, timelines and assurance expectations differ.

QSE-listed companies: the QFMA Governance Code

The QFMA issued a new Governance Code for Listed Companies by Board Decision No. 5 of 2025, published in the Official Gazette on 17 August 2025 and replacing the 2016 Main Market code.⁶ For the first time, listed companies must disclose their environmental and social impact in line with global standards, per the IFRS Foundation’s jurisdictional profile, that means IFRS S1 and S2 for financial years beginning on or after 1 January 2026, with external assurance under international auditing standards.⁵ Main Market companies must comply in full; Venture Market companies may follow a comply-or-explain approach.⁶ Notably, the QFMA does not permit the ISSB’s first-year timing relief: sustainability disclosures go out with, not after, the annual financial statements.⁵

Banks and insurers: the QCB Sustainability Reporting Framework

The Qatar Central Bank issued its Sustainability Reporting Framework in accordance with the ISSB Standards on 4 December 2025.^5,7 It requires banks and insurers, listed or not, to report annually under IFRS S1 and S2 from the financial year starting 1 January 2026. In year one, institutions may publish sustainability disclosures after the annual financial statements; from year two they must be concurrent. The QCB will also develop an assurance framework in line with international standards.⁷ A QSE-listed bank therefore answers to both the QFMA and the QCB, same standards, two supervisors.

QFC firms: the QFCRA’s corporate sustainability reporting rules

The QFC Regulatory Authority consulted on ISSB adoption in early 2025, drawing supportive responses from institutional investors such as Norges Bank Investment Management¹⁸, and issued its corporate sustainability reporting amendments to the QFC General Rules in June 2025.^5,8 The rules apply automatically to “Category A” firms, the largest prudentially regulated firms, including banks and insurers, and extend to any other authorised firm by written designation notice. First reports again cover financial years beginning on or after 1 January 2026; the regulator has signalled a transition-friendly posture, recognising standards the ISSB considers highly aligned with IFRS S1 and S2 while it develops an assurance framework based on ISSA 5000.^5,9

What remains voluntary in Qatar?

The Qatar Stock Exchange’s own ESG guidance, first issued in 2016 with recommended KPIs and a sustainability disclosure platform, remains voluntary, the exchange has long described it as preparation for the day reporting becomes mandated^10,11, a day that has now arrived for Main Market issuers. For private companies, unlisted state enterprises and QFC firms outside Category A without a designation notice, there is still no general legal mandate.

Voluntary does not mean consequence-free. QCB-regulated lenders will need counterparty emissions data for their own Scope 3 reporting, and large listed customers will push questionnaires down their supply chains. The roughly 51 companies listed on the QSE, with a combined market capitalisation of around US$200 billion, sit at the top of a disclosure chain that will pull in far more of the economy than the rules formally capture.¹²

When is your first ISSB report due? A worked example

The clock is set by your financial year. Take the common case: a December year-end company in scope. Its financial year beginning 1 January 2026 is the first reporting period, so its first IFRS S1/S2 report is published in 2027 alongside the 2026 financial statements. Scope 3 follows later: Qatar’s regulators adopted the ISSB’s transition reliefs and extended the Scope 3 relief, and the permission to use non-GHG Protocol measurement methods, by an additional year.⁵

The ISSB’s standard one-year Scope 3 relief plus Qatar’s one-year extension defers Scope 3 through FY2026 and FY2027, deferred, not waived.

Two timing nuances sit around that headline: QFMA-regulated listed companies get no first-year timing relief,⁵ while QCB-regulated banks and insurers may publish after the financial statements in year one only.⁷ Whichever track you are on, the reporting period has already begun.

Why are IFRS S1 and S2 the sensible baseline for Qatari companies?

For covered entities the question is settled: Qatar adopted the standards as issued, prohibits “dual reporting” against modified versions, and requires an explicit statement of compliance.⁵ But even outside the mandate, a family conglomerate weighing its options, a state enterprise with international bondholders, ISSB alignment is the rational baseline for three reasons.

First, investor access. The ISSB Standards were designed for capital markets: they ask for the sustainability information that affects enterprise value, in language investors and credit analysts already use. One ISSB-compliant report beats a thicker document nobody can compare.

Second, regional convergence. Jordan’s exchange is mandating IFRS S2 for its largest listed companies from 2026, UAE companies have begun referencing the ISSB Standards in their reports, and the direction across the Gulf is one-way.¹⁵ Build the reporting architecture on IFRS S1/S2 now and there is nothing to rebuild when subsidiaries in Dubai or Riyadh fall into scope of local rules.

Third, efficiency. IFRS S1 incorporates the TCFD architecture and the industry-based SASB metrics, so previous voluntary work, including reports under the QSE’s 2016 guidance, maps into it rather than being wasted. Starting from the international baseline once is cheaper than serially retrofitting.

What do IFRS S1 and S2 actually require? The four pillars explained

IFRS S1 sets the general requirements for disclosing sustainability-related risks and opportunities that could reasonably be expected to affect your cash flows, access to finance or cost of capital; IFRS S2 applies the same architecture to climate. Both are organised around four pillars inherited from the TCFD.

Governance asks who oversees sustainability risk: board committees, skills, management roles and incentives. Strategy asks what the risks and opportunities are, their effects on the business model and finances, any transition plan, and resilience under climate scenarios. Risk management asks how risks are identified, assessed, prioritised and integrated into enterprise risk. Metrics and targets asks for the numbers: Scope 1, 2 and, in time, material Scope 3 greenhouse gas (GHG) emissions, industry-based metrics, and targets with progress against them.

Three features surprise first-time reporters. The disclosures sit with your financial reporting, same entity, same period, connected to the accounts, which is why Qatar’s regulators expect the same rigour, controls and audit trail as financial reporting.⁹ The materiality lens is investor-focused: you disclose what could affect enterprise value, not everything with a social dimension. And the metrics pillar is quantitative, absolute gross emissions in tonnes of CO₂e. Vague narrative does not satisfy IFRS S2.

In practice: treat the four pillars as the table of contents for both your gap analysis and your final report.

How do you build a first GHG inventory in a hydrocarbon economy?

The metrics pillar is where most Qatari first-time reporters will spend most of their effort, and a Qatari inventory differs from a European services company’s in instructive ways.

Scope 1: combustion, flaring, venting and process emissions

Scope 1 covers direct emissions from sources you own or control. In Qatar’s industrial base this goes well beyond fuel in boilers and vehicles: it includes flaring and venting of associated gas, fugitive methane from valves, seals and compressors, and process emissions from petrochemicals, fertilisers, cement and aluminium. Methane deserves particular care, near-zero methane under OGMP 2.0 is written into Qatar’s NDC² and measurement-based approaches increasingly displace generic emission factors. If your operations flare, document the metering or estimation basis now; it will be among the first lines an assurance provider tests.

Scope 2: electricity and cooling

Scope 2 covers purchased electricity and, in the Gulf, purchased district cooling, an item that barely registers in European inventories but can be material in Doha. Qatar’s grid is overwhelmingly gas-fired, so location-based factors matter and should be sourced consistently year to year.

Scope 3: the value chain, including what you export

Scope 3 spans fifteen categories of value-chain emissions. For hydrocarbon producers and processors, Category 11, use of sold products, typically dwarfs everything else: the combustion of exported LNG, fuels and petrochemical feedstocks by customers. No serious reader of an energy company’s report will consider an inventory without it complete. For banks and insurers under the QCB framework, the equivalent is Category 15, financed emissions, precisely why the mandatory net will pull data from unlisted borrowers over time.

The extended relief is a planning window, not an exemption. A FY2026 first report can lawfully defer Scope 3, the sensible use of the window is to screen all fifteen categories, rank them with reasons, and build the supplier and customer data pipelines the full inventory will need by FY2028.⁵

Whatever your sector, the discipline is the same: match the organisational boundary to your financial consolidation, keep every activity-data source and emission factor in an evidence register, and make the calculation reproducible.

What does climate scenario analysis involve for a first-time reporter?

IFRS S2 requires you to assess and describe the resilience of your strategy using climate-related scenario analysis, proportionate to your circumstances. First-timers routinely overestimate what this demands: you are not being asked to build an in-house climate model, but to test your strategy against structured “what ifs” and report what you learned.

A proportionate first pass uses two contrasting scenarios: a low-carbon transition pathway (for a Qatari exporter, long-run LNG demand, carbon border mechanisms in customer markets, carbon pricing) and a higher-warming physical pathway (extreme heat affecting labour productivity and cooling loads, water stress, sea-level exposure of coastal infrastructure). Public reference scenarios, IEA and NGFS pathways, are acceptable starting points. Document the assumptions, horizons, business-model effects and management responses. The output is a judgement about resilience, evidenced and explained, not a forecast.

What does a 12-month readiness roadmap look like?

For a December year-end company in scope from FY2026, the maths is blunt: the reporting period has already begun, and the report lands with the 2026 annual report in early 2027. Twelve months is enough, if sequenced. Figure 2 shows a workable plan.

Months 1–3, govern and scope. Get an explicit board mandate and assign a board committee. Confirm which instrument captures you (see the table above), run a gap analysis against IFRS S1 and S2, and inventory what the QSE voluntary reporting years already give you.

Months 4–6, data and inventory. Fix the boundary to your financial consolidation. Build the Scope 1 and 2 inventory with documented factors and metering evidence; screen all fifteen Scope 3 categories and decide, with reasons, which are material. Start the evidence register on day one, retrofitting one in month eleven is miserable.

Months 7–9, analyse and draft. Run proportionate scenario analysis, complete the risk and opportunity assessment, and draft the four-pillar disclosure. Draft early: writing exposes data gaps while there is still time to close them.

Months 10–12, assure and publish. Internal audit or a dry-run assurance review against the evidence register; remediate; board sign-off; publish with the annual report. Listed companies should assume real assurance from year one, the QFMA requires it.⁵

Teams that treat this as a reporting-infrastructure project rather than a document project fare best, the design premise behind purpose-built platforms such as EcoLedger, spending the year on substance rather than spreadsheet archaeology.

How does Qatar compare with the UAE and Saudi Arabia?

Qatar’s full, three-regulator ISSB adoption makes it, perhaps unexpectedly, the Gulf front-runner on capital-markets sustainability disclosure.¹³ Its neighbours are on different tracks, and the dates tell the story.

The regimes differ in character, not just in timing. Qatar has built an investor-facing disclosure standard; the UAE a government-facing emissions-compliance law with broad scope; Saudi Arabia so far relies on voluntary, exchange-led guidance.

The consequence for regional groups: a Qatari parent reporting under IFRS S1/S2 already holds most of what its UAE subsidiaries need for climate-law GHG filings, the reverse is not true, because the UAE law demands emissions numbers but not strategy, scenario or governance disclosure. Building to the ISSB baseline covers the region’s most demanding requirement first.

Frequently asked questions

Is ESG reporting mandatory in Qatar?

Yes, for regulated entities. From financial years beginning on or after 1 January 2026, QSE Main Market companies (under the QFMA’s 2025 Governance Code), QCB-regulated banks and insurers, and QFC Category A firms must report under IFRS S1 and S2.⁵ For other private companies and unlisted state enterprises there is no general mandate yet, though the QSE’s voluntary guidance and investor expectations still apply.

Which companies must report under IFRS S1 and S2 in Qatar?

Three regulators have adopted the standards: the QFMA (Main Market listed companies, via Board Decision No. 5 of 2025), the QCB (listed and non-listed banks and insurers, via its December 2025 framework), and the QFCRA (Category A firms, plus any authorised firm brought in by designation notice).⁵

When is the first ISSB sustainability report due in Qatar?

The first mandatory reporting period is the financial year beginning on or after 1 January 2026 for all covered entities, so for a December year-end, the first report covers FY2026 and is published in 2027 alongside the annual financial statements.⁵

Does Qatar require Scope 3 emissions disclosure?

Ultimately, yes, IFRS S2 requires Scope 1, 2 and material Scope 3 emissions. Qatar’s regulators have extended the ISSB’s Scope 3 transition relief, and the permission to use non-GHG Protocol measurement methods, by an additional year.⁵ Scope 3 is deferred, not waived, use the window to screen categories and build data pipelines.

Is assurance required for sustainability reports in Qatar?

The QFMA requires external assurance under international auditing standards for listed companies. The QFCRA is developing an assurance framework based on ISSA 5000, and the QCB plans an assurance framework in line with international standards.⁵ Build controls and evidence on the assumption your numbers will be tested.

Can we report under GRI instead of IFRS S1 and S2 in Qatar?

Not as a substitute. Qatar’s adoption is fully aligned with the ISSB Standards, dual reporting against modified versions is prohibited, and an explicit compliance statement is required.⁵ GRI can complement an ISSB report for wider stakeholder audiences, but it does not discharge the regulatory obligation.

Do QFC firms have different requirements from QSE-listed companies?

The standards and first reporting period are the same, but the legal route differs: listed companies answer to the QFMA under the Governance Code, QFC firms to the QFCRA under its 2025 rules, which apply automatically to Category A firms and to others only by written designation.^8,9 Supervision and assurance expectations differ in detail, so confirm your track before you plan.

References

1. Government Communications Office, State of Qatar, Environment and Sustainability (Qatar National Vision 2030), accessed July 2026.
2. State of Qatar, Nationally Determined Contribution (NDC) 3.0, submitted to the UNFCCC, November 2025, accessed July 2026.
3. Climate Change Laws of the World, Qatar National Environment and Climate Change Strategy (2021), accessed July 2026.
4. International Trade Administration (US), Qatar Energy GHG Emissions Reductions and Sustainability Initiatives, accessed July 2026.
5. IFRS Foundation, Jurisdictional profile: Qatar (IFRS Sustainability Disclosure Standards), accessed July 2026.
6. Charles Russell Speechlys, The new Corporate Governance Code for listed companies (QFMA Board Decision No. 5 of 2025), accessed July 2026.
7. Qatar Central Bank, Sustainability Reporting Framework According to ISSB Standards, accessed July 2026.
8. QFC Regulatory Authority, Notification: GENE (Corporate Sustainability Reporting) and Minor and Technical Amendments Rules 2025, accessed July 2026.
9. Pinsent Masons, Qatar Financial Centre starts clock on new sustainability reporting rules, accessed July 2026.
10. Qatar Stock Exchange, Sustainability and ESG, accessed July 2026.
11. Qatar Stock Exchange, Guidance on ESG Reporting (2016), accessed July 2026.
12. UN Sustainable Stock Exchanges Initiative, Qatar Stock Exchange factsheet, accessed July 2026.
13. IFRS Foundation, Use of IFRS Sustainability Disclosure Standards by jurisdiction, accessed July 2026.
14. IFRS Foundation, IFRS Foundation publishes jurisdictional profiles evidencing progress towards adoption of ISSB Standards (June 2025), accessed July 2026.
15. KPMG, Two Years In: Adoption of the ISSB Standards (Middle East perspective, June 2025), accessed July 2026.
16. PwC Middle East, UAE Climate Change Law: Mandatory Emissions Reporting Obligations (Federal Decree-Law No. 11 of 2024), accessed July 2026.
17. Saudi Exchange (Tadawul), ESG Guidelines for listed companies, accessed July 2026.
18. Norges Bank Investment Management, Response to the QFCRA consultation on adoption of the ISSB Standards (2025), accessed July 2026.

This article reflects the regulatory position as verified in July 2026. It is general information, not legal advice; confirm requirements with your regulator or advisers before relying on them.