At a time when ESG factors are reconfiguring global capital flows, sustainability reporting in UAE businesses has been transformed from a voluntary nice to have into a regulatory and market necessity. With the UAE’s Net Zero by 2050 target, mandatory Securities and Commodities Authority (SCA) requirements in light of the International Sustainability Standards Board (ISSB) aligned rules for 2025–2026 around the corner, the question now is not whether or not UAE companies should be issuing an annual Sustainability Report, every year from 2025 and onward but who within organizations will drive sustainability focused reports.
The Growing Mandate
As of 2024, listed companies on the Dubai Financial Market (DFM) and Abu Dhabi Securities Exchange (ADX) are required to undertake phased mandatory ESG reporting. Most large and publicly listed companies will need to produce ISSB-aligned Companies Sustainability Reports by 2026. Free-zone businesses at Abu Dhabi Global Market (ADGM) and Dubai International Financial Centre (DIFC) are also progressing toward the mandatory disclosure of climate-related information, complying with TCFD- and ISSB-enabled reporting regimes.
This regulatory momentum, paired with growing demand from global investors for reliable sustainable investing reports, makes the quality, completeness and timeliness of sustainability disclosure instrumental to its bottom-line impact on cost of capital, valuation multiples and access to green financing.
Who Should Own Sustainability Report Drafting?
There is not one size that fits all the answers, but experience in other firms across the UAE can offer some models along with their strengths and pitfalls.
1. The Board of Directors
It has a critical role in establishing the sustainability agenda. The Board may not write the report, but it should:
- Approve sustainability goals and KPIs
- Oversee ESG risks and opportunities
- Ensure the report is consistent with long term strategy
- Examine and approve of the independent Companies Sustainability Reports
This top-down control guarantees credibility and accountability, the most important features investors and regulators search for, in sustainability reporting among UAE companies.
2. Sustainability and ESG Department
For companies in the UAE with established sustainability systems, it is the sustainability or ESG department that takes the lead role in preparing so. Their core duties include:
- Collecting and validating sustainability data
- Mapping reports to frameworks such as GRI, IFRS S1/S2, CSRD or local ESG standards
- Writing the story for the sustainable investing report.
- Liaising with internal parties and external counterparts.
- Safeguarding the reliability of financial metrics with respect to environmental and social impact data.
- It is the hub or coordinating part for drafting the sustainability report.
3. Finance Department
Given the convergence of financial and non-financial disclosures worldwide, the department for Finance is now deeply involved in:
- Material accuracy on emissions, energy consumption and cost reporting
- ESG assurance and audit trails administration
- Connecting sustainability with financials
- Supporting integrated reporting
For companies working on their annual sustainability report 2025, the finance chapter is very important for credibility and adherence.
4. Human Resources
The HR team can provide valuable input on:
- Diversity and inclusion metrics
- Employee well-being programs
- Hours of training, talent development, and retention.
- Health and safety performance
These measures are core in companies’ sustainability reports, which tend to converge with international ESG benchmarks.
5. Operations & Facility Management
Typically, raw data is processed by facilities and operations teams for:
- Waste management
- Energy consumption
- Carbon emissions
- Water efficiency
Supply chain sustainability practices
Without proper operational data, sustainability reporting of the UAE companies is not informative and can be misled.
6. Marketing & Communications
The final UAE Firms’ Sustainability Report is approved by the Communications team and for publication that are:
- Clear, readable, and visually engaging
- Aligned with brand identity
- Intuitive to investors, regulators and customers
- Published across digital and print platforms
They also contribute to the organization signaling its ESG performance in a transparent and responsible manner.
7. External ESG Consultants
A lot of UAE businesses depend on ESG professionals such as sustainability consultants and auditors to:
- Direct compliance of UAE specific sustainability needs
- Benchmark performance against industry standards
- Support sustainability report drafting
- External assurance for investor-friendly confidence
This is helpful particularly for SMEs, first-time reporters as well as companies developing their initial annual sustainability report 2025.
Sustainability Report Guidance by CBM Consultants
CBM Consultants support UAE companies in preparing reliable sustainability reports and structuring credible financial and non-financial information aligned with international frameworks like GRI and IFRS S1/S2, as well as UAE guidelines. We verify carbon emissions and energy costs in connection with financial performance, ensuring compliance, and aiding regulatory standards.
Our role includes uncovering tax implications of sustainability initiatives, thereby driving strategic decisions and enhancing investor confidence. Overall, our firm provides a framework for accurate and authentic sustainability reporting for UAE companies.
Emerging Role: The Sustainability Controller
Another role that’s been emerging in the UAE is what is called a “Sustainability Controller” or “Head of ESG Reporting”, usually under the CFO. This is the bridge between technical sustainability know-how and financial reporting discipline, it’s just what regulators and investors require today.
Board-Level Accountability
Regardless of which party is operationally responsible for drafting the report, it falls to the Board of Directors to maintain final control over its preparation. SCA rules formally mandate board approval of ESG disclosures, and standards surveyed by ISSB place governance over sustainability in the reporting hierarchy. A Board Sustainability Committee is becoming common among UAE blue-chip companies.
Conclusion
Although the process is mostly driven by the Sustainability or ESG Department, in UAE firms, the task of preparing Sustainability Reports is collaborative. High-quality and investor-ready reports come from organizations that are incorporating inputs from:
- Board of Directors
- Finance
- HR
- Operations
- Communications
- External ESG experts
With the demand for transparency increasing, firms in the UAE that commit to strong sustainability reporting today will be well placed tomorrow receiving investment, ensuring compliance and building a reputation over the long term.
