ESG Reporting in the UAE: How to Communicate Disclosures Clearly

An analyst reading a UAE ESG report can usually tell within a page or two whether the numbers were measured or merely described. That gap is what ESG reporting exists to close. ESG reporting is the structured disclosure of how a company manages its environmental, social and governance factors. For UAE listed companies that means presenting emissions, energy, water, workforce, board oversight and ethics against a recognized framework, so investors and stakeholders can read performance year on year. It is a metric-based exercise, not a narrative one, and the quality of the report comes down to how clearly those metrics are presented.

This guide covers what the Dubai Financial Market and Abu Dhabi Securities Exchange ask companies to disclose, how the major global frameworks connect to that, and how to present ESG content so readers can actually follow it. It is written for company secretaries, investor relations teams, and communications leads preparing a UAE ESG or sustainability report for the first time, or raising the quality of the next cycle.

A note on scope. Walk Production is a report design and copywriting studio, not an audit, assurance, ESG advisory or legal firm. Everything here is about what to present and how to present it clearly. Confirm your reporting obligations against the current official sources cited below, because the rules in this area are updated regularly.

What is ESG reporting, and what does it cover for UAE companies?

ESG reporting is the structured, metric-based disclosure of how a company manages its environmental, social and governance performance. It is distinct from a marketing narrative: where a brochure says a company “cares about sustainability”, an ESG report states the Scope 1 and 2 emissions figure against a defined baseline year and methodology.

The three pillars frame the content. The DFM’s Guide to ESG Reporting covers them as follows: the environmental pillar includes energy consumption, water withdrawal, waste generation and greenhouse gas emissions; the social pillar covers the workforce, community engagement and human rights; the governance pillar addresses board composition, transparency, anti-corruption policies and ethics. A UAE listed company’s ESG disclosure addresses all three, each metric presented against a baseline and a clear methodology.

The difference between a disclosure and a slogan matters in practice. “We are committed to reducing emissions” is not a disclosure. “Scope 1 and 2 emissions are 14 percent below our 2020 baseline under the GHG Protocol Corporate Standard” is. The first tells the reader nothing a regulator, analyst or rater can verify. The second invites scrutiny, which is the point.

ESG content can sit inside the annual report as an integrated section, or as a standalone sustainability report published alongside it. Either way, the two documents need to tell one consistent story. For an overview of how those two document types relate to each other, the annual reports and sustainability reports guide for UAE companies covers that ground in full.

Is ESG reporting mandatory for DFM and ADX listed companies?

Yes. Onshore public joint stock companies listed on the Dubai Financial Market and Abu Dhabi Securities Exchange are required to publish annual ESG or sustainability disclosures. The Capital Market Authority (CMA, formerly the Securities and Commodities Authority or SCA) Corporate Governance Code incorporates sustainability disclosure requirements, and both exchanges publish guides that operationalize those requirements in practice.

The DFM’s own guide describes ESG data reporting mandated by the then-SCA reaching DFM and ADX listed companies in recent reporting cycles, with the requirement generally understood to have taken effect from around the 2022 to 2023 financial years. Because the exact onset and scope have been refined over successive updates, treat any single start date as indicative rather than settled, and always confirm the current requirements directly with the Dubai Financial Market, the ADX and the CMA, as the rules in this area change.

On timing, reports are generally expected to be filed within 90 days of the financial year-end or before the annual general meeting, whichever is earlier. That deadline shapes the production calendar, a point the section on compiling ESG data alongside the financial close returns to. Confirm the live filing expectation with DFM, ADX and the CMA before locking any schedule.

The mandatory floor is the Corporate Governance Code’s disclosure requirement inside the annual report. The DFM and ADX guides are voluntary guidance documents that show companies how to structure and present that mandatory disclosure, and most issuers adopt the exchange guide metrics as the practical architecture for their ESG section. As of 2025, that exchange-led picture sits underneath a federal legal backdrop as well, which raises the stakes on getting the emissions disclosure right.

The word “voluntary” can mislead a team approaching its first cycle, so it is worth pinning down. The disclosure obligation is not voluntary; what is voluntary is the choice to follow the DFM or ADX guide as the way of meeting it. A company could in principle disclose its ESG performance in some other recognized structure. In practice almost none do, because the exchange guides are written to satisfy the Code, are familiar to local analysts and raters, and give the report a metric set that is comparable with peers on the same exchange. For the team building the document, the working assumption is straightforward: the disclosure is required, and the exchange guide is the path of least resistance and most credibility for delivering it. Confirm the current scope of the mandatory requirement with DFM, ADX and the CMA, since it has been refined over successive updates.

How does the UAE Climate Law change the reporting backdrop?

The UAE ESG conversation used to be mostly about exchange guidance and comparability. A federal law has widened it. Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects was issued on 28 August 2024 and came into force on 30 May 2025, and it is generally described as the first binding climate-accountability law in the MENA region. It applies to public and private entities operating in the UAE, including those in free zones, and requires them to measure, report and manage their greenhouse gas emissions in support of the UAE Net Zero 2050 initiative.

For a reporting team, the practical effect is a shift in the stakes, not a new style of section. Emissions figures that once lived in a voluntary ESG disclosure now sit against a federal obligation to measure and report them. That makes the basis behind a number, the boundary, the baseline year and the method, the thing a reader, a rater and now a regulator can hold the company to. An emissions figure stated cleanly, on a named basis and reported the same way each year, reads as governed. The same figure floating without a basis reads as assembled, and that gap is more exposed than it was a cycle ago.

The end of the transition period sharpens that point. The law gave entities a year from the in-force date to align with its provisions, and that period ended on 30 May 2026. Full compliance is now required. The law also provides for administrative penalties where an entity falls short, with repeat breaches treated more severely than a first one. The precise penalty levels and the way they escalate sit in the law and its implementing decisions rather than in a presentation guide, and they have been reported in different forms as guidance is issued, so treat the penalty regime as an item to confirm on the official UAE legislation portal linked above and with your advisers. The point for the report itself is simpler: an emissions number now sits against a live obligation, which is a strong reason to state it on a basis a reader can follow and to repeat that basis each cycle.

This guide stays on presentation, so the takeaway here is narrow. The law is the reason rigor in the emissions disclosure matters more, and the reason an ESG section now needs to connect every climate metric to the governance that sits behind it. The implementing detail is still being phased in, so confirm the applicable obligations, scope, timing and penalties with your advisers and the official sources, rather than reading anything here as a guide to compliance.

What does the DFM ESG Reporting Guide ask companies to disclose?

The DFM Guide to ESG Reporting sets out a benchmark of 32 ESG metrics and indicators across the environmental, social and governance pillars. That fixed set exists precisely for comparability: an investor reading a DFM-listed company’s ESG section can compare performance year on year, and peer to peer, because the metric set is consistent.

The 2025 update introduced two significant enhancements. First, the double materiality concept, which asks companies to consider both the impact the business has on the environment and society, and the financial effects those factors have on the business. Second, the update aligns the guide’s metrics with the International Sustainability Standards Board’s standards and references GRI and Sustainable Development Goals. Confirm the current version on the DFM website, as the guide is updated periodically.

For a report designer or communications team, a fixed benchmark has a clear practical implication: the report should lead with a performance summary or dashboard before the detailed data. A table showing headline metrics across all three pillars at the front of the ESG section gives the reader the takeaway before the full disclosure begins. A fixed metric set also means year-on-year comparatives are built into the structure from the start. When we approach a sustainability report for a listed client in Malaysia or Singapore, the benchmark set is already decided by their advisers; what we shape is whether a reader can find the headline figure on the first page or has to dig for it on the fortieth.

How does ADX ESG disclosure guidance differ in emphasis?

The Abu Dhabi Securities Exchange publishes its own ESG Disclosure Guidance for Listed Companies, first issued in 2019 and updated to June 2025. Like the DFM guide, it is a voluntary guidance document that complements and explicitly references the Corporate Governance Code’s sustainability disclosure requirements.

The ADX guidance sets out a structured set of ESG disclosure metrics across the environmental, social and governance categories, each mapped to recognized references including the GRI Standards and a regional GCC ESG metric set, and tied to the UN Sustainable Development Goals. It aligns disclosure with IFRS S1 and S2 as well. Where the DFM guide hands a company a fixed benchmark of 32 metrics to populate, the ADX guidance puts the materiality assessment first: companies identify the ESG topics most relevant to their own operations and stakeholder groups, then disclose against the indicators that those topics call for. An appendix in the June 2025 edition walks through the materiality assessment methodology in detail. Confirm the current indicator set and count on the ADX guidance itself, as it is revised periodically.

That difference in starting point is the substance of the contrast. DFM begins with the metric list and asks the company to report it consistently; ADX begins with the company’s material topics and asks it to choose the indicators that fit. The two converge in practice because both reference the same global frameworks, so a company that reconciles them is usually populating one overlapping pool of indicators rather than two separate ones.

For a team producing the ESG section, the difference has a practical presentation implication. A company following DFM’s fixed metric set structures its ESG section around those 32 metrics, with a performance table leading the way. A company applying ADX’s materiality-led approach needs to show its materiality matrix before the metrics, so the reader understands why those particular topics are disclosed in depth and others are treated more briefly. The structural order changes: one report opens with the data, the other opens with the reasoning behind the data.

Many UAE listed companies reconcile both guides alongside the global frameworks. A materiality assessment that reflects ADX emphasis, reported against DFM’s 32-metric benchmark and tagged to GRI and the SDGs, covers both exchange expectations and the international references in one coherent structure. The next section sets out how to keep that single structure consistent rather than reporting each figure several times over.

How do global frameworks like GRI and IFRS S1 and S2 fit in?

UAE exchange guidance points toward the global frameworks that investors and raters already use. Both the DFM and ADX guidance reference the GRI Standards and the IFRS S1 and S2 standards, creating a natural alignment between exchange expectations and recognized international frameworks.

The GRI Standards are the most widely adopted basis for sustainability reporting worldwide. They are structured across three tiers: Universal Standards (applicable to every reporting organization), Sector Standards (for specific industries), and Topic Standards (for individual ESG topics such as emissions, water or labor practices). GRI takes an impact materiality lens, asking how the organization affects the economy, the environment and people.

The IFRS S1 and S2 standards from the International Sustainability Standards Board approach disclosure from a financial materiality perspective. IFRS S1 covers general sustainability-related risks and opportunities; IFRS S2 covers climate specifically, on an investor-focused basis. Both ADX and DFM guidance reference these standards in their current editions.

Two presentation points follow from this. First, naming the framework you report against, and staying consistent with it from year to year, signals that the disclosure is built on a recognized basis rather than assembled ad hoc. With a federal greenhouse-gas reporting obligation now in force, that naming discipline carries more weight: reporting on the same basis each year is what lets an investor, and now a regulator, read the emissions numbers as governed rather than reassembled every cycle. Second, climate and governance content has to connect: the ESG section should show the metrics alongside how the board oversees the risks behind them. A climate target presented without any governance context reads as a number without an owner.

How do you present one emissions figure across DFM, ADX and the global frameworks?

Map each figure once, then tag it to whichever references ask for it. The DFM benchmark, the ADX indicators, the GRI Standards and IFRS S1 and S2 overlap heavily on the same underlying numbers, so a company that answers each reference separately ends up reporting the same data point several times, on slightly different bases, in different parts of the report. The cleaner approach is one governed dataset that every framework draws from.

The overlap is the opening. DFM sets a fixed list of 32 metrics; the ADX guidance frames its indicators against GRI, the GCC metric set and the SDGs; both point to GRI and IFRS S1 and S2 as the international reference. A single emissions figure can answer the DFM metric, the matching ADX indicator, the relevant GRI disclosure and the IFRS S2 climate requirement at the same time. So can a workforce ratio, a board-independence measure, or a water-withdrawal number. The frameworks ask in different words; the figure underneath is one figure.

This is data architecture before it is design. A report team maintains a master list of every figure it discloses, each with its own definition, unit, boundary, baseline year and method, and against each one a note of which references it answers. The figure is captured once; the frameworks become tags on it rather than four separate sources of truth. A short reference column in the data index, naming the framework each disclosure aligns to, lets an analyst trace a figure on the page back to the standard it answers, and it tells the reader the disclosure rests on a recognized basis without a word of marketing copy.

Two gains follow. A figure stays identical everywhere it appears, because the narrative spread, the performance dashboard and the back-of-report index all draw from the same source entry rather than being keyed in by hand three times. And the production effort scales with the number of distinct data points, not the number of frameworks, so adding another reference next cycle means adding a tag, not rebuilding the section. The exact DFM metric set, the ADX indicator set and what applies to your filing change over time and are not all interchangeable, so confirm the current versions with DFM, ADX, the CMA and your advisers before you fix the mapping. The architecture stays durable even as the specifics are revised.

How should ESG disclosures be presented so investors can actually follow them?

Lead with the headline, then the detail. The most common structural failure in UAE ESG sections is burying the performance picture inside dense tables that a non-specialist reader has to decode before understanding what the company’s position actually is.

A performance dashboard or summary table at the opening of the ESG section gives the reader the takeaway before the full data. It does not replace the detailed tables; it frames them. A shareholder who reads only the summary leaves with a coherent picture. An analyst who reads the full section finds the data exactly where they expect it.

A handful of design principles hold across ESG reporting:

• Design the charts, do not just generate them. A multi-year emissions trend or an energy intensity chart is read in seconds. The axis scale, the baseline year and the choice of single-metric versus comparative view decide whether the section gets read or skipped.
• Keep one visual language. ESG and financial content produced in different graphic systems tells the reader the report was assembled from separate workstreams. Typography, color palette and chart styling should hold consistently across both halves.
• Make tables scannable. Column headers should be clear, figures aligned, units stated once at the top, and multi-year comparatives included with brief commentary on inflection points. A table without a baseline year is a table without context.
• Connect data to governance. Present the metric alongside the board oversight structure behind it. An emissions figure with no reference to which committee monitors it reads as data without accountability.

The governance link is worth showing rather than asserting. Take a climate target, set out as a percentage reduction by a target year. Presented on its own, it is an ambition with no owner: the reader cannot tell who set it, who checks it, or whether anyone is accountable if it slips. Now tie the same target to the board committee that reviews it, state how often that committee meets on it, and name the metric that tracks progress against it. The number has not changed, but it now reads as a commitment the company is governing rather than a line it hopes to grow into. That is the difference a single sentence of governance context makes, and an analyst registers it immediately.

The difference between a governed metric and a loose one shows up the moment a reader tries to use the number. The pair below uses an illustrative energy-intensity figure to make the point.

The figures here are illustrative. The point is that a number stated once, with its baseline year, boundary and unit fixed, can be compared and trusted; the same number floating in two forms across the report cannot, and it gives an analyst a reason to question the rest of the section.

What should companies know about bilingual Arabic and English ESG reporting?

Many UAE ESG reports are produced in English alone, but Arabic and English bilingual reporting is common, particularly for companies with significant domestic or government stakeholders. Three things shape the ESG section specifically. Arabic reads right-to-left, so the leading column of a metric table and the entry point of a spread sit on the opposite side and have to be planned for the Arabic reader, not mirrored from the English version. Arabic also runs to a different length than the same English content, and the difference is not uniform across headings, body and captions, so a grid built around English line lengths overflows when the Arabic is poured in. An ESG section designed in English and retrofitted to Arabic at proof stage almost always shows it, with overset text and two versions that drift apart.

The highest-risk bilingual element in an ESG report is the data table. Every figure, unit and precision must match exactly across both language versions, because a different total in the Arabic and English emissions tables is the kind of inconsistency an assurance reviewer, regulator or analyst catches at once. Feeding both tables from one governed source figure, the same architecture described above, is what makes them agree by construction rather than by luck. Our team produces bilingual reports in Bahasa Malaysia and English, and that layout and figure-matching discipline carries directly to Arabic and English production. The fuller bilingual treatment, covering typography across two scripts, numeral conventions, terminology management and equal-treatment proofing, sits in the guide linked earlier.

Compiling ESG data alongside the financial close

Most ESG sections that read as bolted-on were produced that way. The fix is a calendar habit, not a design move: compile the ESG dataset on the same timeline as the financial close, so the ESG and financial narratives are drafted together and reconciled once rather than patched against each other at the final proof.

The 90-day filing window does the planning for you if you work backward from it. Annual reports are generally expected to be filed within 90 days of the financial year-end or before the annual general meeting, whichever is earlier, so that date is the outer edge of the schedule. Every translation pass and proofing round has to fit inside it. Confirm the live filing expectation with DFM, ADX and the CMA before locking the calendar, as these dates can change.

Working back from that edge, a UAE ESG cycle tends to move through six stages. Naming them gives the calendar enough resolution to protect the bilingual rounds, which are the ones that get squeezed when a schedule slips.

The habit that protects a bilingual report is building the translation and equal-treatment proofing rounds into the schedule from day one rather than the deadline. Every late edit to the English has to flow through to the Arabic and be proofed again. A calendar that allows for only one translation pass rarely survives the normal volume of board edits.

One more point belongs in the calendar. Some companies obtain external limited assurance over selected ESG metrics, alongside the statutory audit of the financial statements, and that adds a round of its own. Whether assurance is obtained, and over which metrics, is a decision for the company and its advisers. From a production standpoint the relevant rule is narrow: any assured metric must read identically wherever it appears, including across the Arabic and English versions, so the assurance scope and the published figures stay aligned. A figure that carries assurance in one language and a different value in the other is exactly the kind of gap assurance is meant to close, not open.

What are the common mistakes that weaken a UAE ESG report?

The most consequential failures in UAE ESG reporting are usually presentation problems rather than data ones: content that is accurate but not readable, or a structure that obscures the story the company is trying to tell. The recurring ones:

• An ESG section in a different voice from the rest of the report. If the financial review reads as confident and analytical and the ESG section reads as a press release, the reader registers the inconsistency. Both sections should carry the same tone, graphic system and degree of precision.
• Disclosure without governance context. Metrics presented with no explanation of how the board or a board committee oversees the risks behind them look like data without accountability. Governance should connect to every metric in the environmental and social pillars rather than sitting in its own walled-off section.
• Vague materiality. A materiality matrix where every topic sits in the same upper-right quadrant tells the reader that the company has not made genuine prioritization decisions. A useful matrix shows clear separation between topics and explains why the high-priority ones are high.
• A qualitative-only climate narrative where the data exists. An ESG section that describes climate ambition without quantitative emissions figures, baseline years or measurable targets invites the inference that the measurement work was never done. Where the data exists, it should be disclosed.
• Marketing claims that exceed the report. The credibility gap an analyst or ESG rater flags most often is the distance between the corporate website’s sustainability claims and the qualified language in the actual ESG disclosure. The two should say the same thing.
• Bilingual versions that drift apart. Layout, figures and tone should hold consistently across Arabic and English versions. A performance figure that differs between the two languages, or a chart that appears in one version and not the other, is a presentation failure and a potential compliance risk.
• Multi-year metrics without commentary. A three-year energy consumption trend with no explanation of what drove the inflection point in year two leaves the reader to guess. Brief commentary on the cause of significant movements is what turns a data table into a disclosure.

How Walk Production can help

Walk Production designs and writes sustainability and ESG report content for listed companies and organizations, with a track record across Malaysia and Singapore and now serving the UAE market. Our in-house team handles report copywriting, disclosure layout, data visualization and bilingual production under one account team, working alongside the reporting team and advisers who own the content and compliance decisions.

Our sustainability report design service covers the full production scope: concept development, ESG section structure, performance dashboard design, data table typesetting, bilingual layout, and print-ready file preparation. We do not provide ESG advisory, audit or assurance services; those sit with your appointed advisers and auditors.

The most productive early step for any UAE ESG report is aligning the ESG narrative with the financial story and planning the bilingual structure before design begins, so the report is built as one document from day one rather than assembled from separate workstreams at the end. To see how that reads in finished reports, browse our reporting work, including our sustainability report for QSR Brands, an F&B group, from the reports we have produced across Malaysia and Singapore, or talk to the team about your next reporting cycle.