Your First Sustainability Report in the UAE: Questions and Answers

Insights · ESG reporting · UAE

For many UAE companies, this is the year sustainability reporting stops being optional. If yours has never published a sustainability report, the questions below cover where to start, what applies to you and what a realistic first year looks like.

New River Group12 questions8 min read
The short answer

01How can a company prepare for UAE climate and ESG reporting if it has never published a sustainability report?

Confirm which UAE rules apply to your entity, put a board-level owner in charge, run a materiality and data-gap assessment, build a Scope 1 and 2 greenhouse gas inventory, choose a recognised framework such as GRI or IFRS S2, and publish a concise first report with a clear plan to improve. A first report doesn't need to be perfect. It needs to be credible and well documented.

02Which UAE rules apply to my company?

It depends on your legal status and who you work with:

If your company is…What appliesKey requirement
Any entity that emits greenhouse gases (mainland or free zone)Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects, overseen by the Ministry of Climate Change and Environment (MOCCAE)Measure emissions, keep an inventory, report in MOCCAE-approved formats, keep records for at least 5 years
Listed on DFM or ADXSCA Corporate Governance Guide (Article 76), plus the DFM ESG Reporting Guide or ADX ESG Disclosure GuidancePublish an annual sustainability report; DFM's 2025 guide sets 32 benchmark ESG metrics
Registered in ADGMADGM ESG Disclosures FrameworkDisclose on a "comply or explain" basis using GRI, ISSB, TCFD or CDP
Supplying large companies, government or banksCustomer, tender and lender requirementsESG questionnaires, emissions data and policies

03Is sustainability reporting mandatory for private companies in the UAE?

For climate, yes. The UAE Climate Change Law applies to public and private entities whose activities emit greenhouse gases, on the mainland and in free zones. A full sustainability report is mandatory for companies listed on DFM and ADX. Private companies are also increasingly asked for ESG data by banks, investors and large customers.

04What are the deadlines and penalties under the UAE Climate Change Law?

The law came into force on 30 May 2025, with the first full reporting deadline set for 30 May 2026. In April 2026, MOCCAE representatives indicated that deadline was expected to be extended, but treat 2025 data as the baseline you will be asked for.

Fines under the law range from AED 50,000 to AED 2,000,000, and can double for repeat breaches.

05We've never reported before. What are the first steps?

  1. Confirm scope and deadlines. List every requirement that applies to you, its deadline and who it comes from. Separate what is mandatory from what customers or investors are asking for.
  2. Set up governance. Name a board member or executive sponsor and a day-to-day reporting lead, often from finance, legal or sustainability. Agree who approves data and who signs off the report.
  3. Run a materiality assessment. Identify the ESG topics that matter most to your business and your stakeholders. Many UAE companies now use double materiality, which looks at both your impact on people and the planet and the financial impact of ESG issues on you.
  4. Do a data-gap assessment. For each material topic, check what data exists, who holds it and how reliable it is. Expect gaps in the first year; the aim is to know where they are.

06How do we measure our emissions for the first time?

Start with Scope 1 and Scope 2, using the GHG Protocol:

  • Scope 1: direct emissions from fuel, generators, company vehicles and refrigerants.
  • Scope 2: emissions from purchased electricity and, in the UAE, district cooling.

Then screen the main Scope 3 categories, such as purchased goods and business travel, so you know where the largest value-chain emissions sit. Document every assumption and emission factor you use.

07Which reporting framework should a first-time UAE reporter use?

GRI is the most common starting point. Align your climate disclosures with IFRS S2 so you are ready as ISSB adoption grows. Listed companies should also map their report to DFM or ADX metrics.

08What should a first sustainability report include?

At minimum:

  • How ESG is governed and who is accountable
  • Your material topics and why they matter
  • A Scope 1 and 2 emissions baseline
  • Key policies, such as environment, health and safety, and ethics
  • Early targets and a roadmap for improving your data

Keep it concise and be open about limitations. Credibility matters more than length.

09How long does it take to prepare a first sustainability report?

Around three to six months, depending mostly on how easy your data is to collect:

  1. Month 1Scope, governance and materiality
  2. Months 2–3Data collection and GHG inventory
  3. Month 4Drafting and internal review
  4. Months 5–6Design, approval and publication

10Does our first report need to be assured?

Not always in year one, but plan for it. Emissions reported to MOCCAE are expected to be verified by an independent third party, and investors and lenders increasingly expect assurance. Keep evidence for every number so an auditor could trace it back to its source.

11What mistakes do first-time reporters make most often?

  • Starting with the report design instead of the data
  • Copying a large company's report and ending up with 100 pages you can't maintain
  • Leaving out Scope 2 because district cooling bills are hard to find
  • Making net-zero or carbon-neutral claims without a baseline or method
  • Treating the report as a one-off project instead of an annual process

12How can New River Group help first-time reporters?

New River Group is a Dubai-based ESG and sustainability focused Research and Development Organisation. We take UAE companies from no report to a published, assurance-ready first report: confirming which UAE rules apply, running materiality and data-gap assessments, building the GHG inventory, drafting the report against GRI, IFRS S1 and S2 and DFM or ADX guidance, and handing over a repeatable process your team can run next year. New River Institute can train your reporting team alongside the project.

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