Ask one simple question — “does this apply to us?” — and you can end up with four regulators, three acronyms nobody briefed you on, and a deadline you’re not entirely sure exists yet.
You haven’t missed anything obvious. The confusion is structural: SCA, ADX, DFM, and the federal climate law weren’t designed as one coherent system. They were introduced separately, by different bodies, at different times, to solve different problems. No one has mapped them against each other for you — until now.
Here’s the ledger — four entries, what each one actually costs you if you get it wrong, and where your company sits on it.
The four pillars, at a glance
| Regulator / Instrument | What it is | Who it applies to | Status |
|---|---|---|---|
| SCA (Securities and Commodities Authority) | Corporate Governance Code, Article 76 | All public joint stock companies listed in the UAE | Mandatory |
| ADX (Abu Dhabi Securities Exchange) | ESG Disclosure Guidance | Companies listed on ADX | Voluntary, but expected |
| DFM (Dubai Financial Market) | ESG Reporting Guide | Companies listed on DFM | Voluntary, but expected |
| Federal Decree-Law No. 11 of 2024 | Reduction of Climate Change Effects | Public and private entities in sectors named by MOCCAE — listed or not | Mandatory law, thresholds still rolling out |
Two of these trace back to the same source. Two are separate instruments entirely. And one has nothing to do with whether you’re listed on an exchange at all. That last distinction is where most companies — even careful, well-run ones — get caught out.
SCA: the legal foundation everyone else builds on
Start here, because everything else references it. Under Article 76 of the SCA’s Corporate Governance Code (Decision No. 3/R.M. of 2020), every public joint stock company listed on ADX or DFM must publish an annual sustainability report alongside its financial and governance reports. This isn’t exchange etiquette. It’s law, and it comes with a hard deadline: 90 days from financial year-end, or before your annual general assembly, whichever lands first.
Here’s the part that quietly derails people: a December year-end means a March 31 submission. Financial close is usually a well-oiled machine by then. Sustainability data collection, for most companies, isn’t — which means the clock is often already running by the time anyone in the building realizes it started. And it’s not a report you can quietly finish late and email over: it has to be filed through the official SCA portal, alongside your Public Governance Report, on the same timeline (preliminary results carry an even tighter 45-day window). There’s no separate, more forgiving track for sustainability.
ADX and DFM: the same mandate, two different guidebooks
Once SCA has told you that you must report, ADX and DFM each tell you how. Both exchanges publish their own guidance — the ADX ESG Disclosure Guidance and the DFM ESG Reporting Guide, both dating back to 2019 — built around the Sustainable Stock Exchanges Initiative’s core metrics, GRI, and TCFD-style climate risk disclosure. Both exchanges are now in the process of updating that guidance to bring it in line with the newer IFRS Sustainability Disclosure Standards (IFRS S1 and S2), which didn’t exist when the original guides were written. If your last report was built for the pre-2023 version of either guide, it’s worth checking whether the goalposts have quietly moved.
Technically, neither guide is compulsory on its own. In practice, “voluntary” barely holds anymore. Consider the audience reading these reports: institutional investors representing over $121 trillion in assets have signed on to frameworks demanding TCFD-aligned climate disclosure from the companies they hold. When your report lands on their desk formatted to the wrong exchange’s template, that’s not a paperwork issue — it’s a credibility issue, at exactly the moment you’re trying to build trust with capital.
Get the wrong guide in front of the wrong exchange, and you haven’t saved time. You’ve just guaranteed you’ll do the work twice, closer to the deadline, with less patience left for it.
Federal Decree-Law No. 11 of 2024: the one that isn’t about being listed
This is where the search for a “sustainability reporting framework” most often goes sideways — because this law has nothing to do with SCA, ADX, or DFM. Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects was issued in late 2024, with implementation rolling out through 2025, and it reaches public and private entities whose activities release greenhouse gases above thresholds the Ministry of Climate Change and Environment (MOCCAE) is defining sector by sector — listed or not.
That last part matters: the law itself is broad by design, but the specific “does this apply to me, and how much do I need to measure” answer is being filled in through Cabinet Decisions and Executive Regulations as MOCCAE rolls them out — so this isn’t a one-size-fits-all obligation for every business with any emissions footprint at all, but it is a fast-widening one. Where SCA and the exchanges govern disclosure for listed companies, this law governs emissions for a growing list of sectors, with non-compliance penalties reaching up to AED 2 million. That’s not an abstract regulatory risk. It’s a number a CFO has to explain to a board.
This is the single most common gap we find in a compliance assessment: a company correctly concludes “we’re not listed, so ESG reporting doesn’t apply to us” — and never checks whether their sector has since been named under the climate law, which was never about being listed in the first place.
The pressure that’s building even where the law hasn’t caught up yet
Even set the regulators aside for a moment. The market is already moving faster than the mandates:
- 59% of businesses now say they expect to remove poor ESG performers from their supply chains — which means a weak sustainability story can cost you a contract long before it costs you a fine.
- 40% of UAE firms still can’t track Scope 3 emissions — the hardest, most-overlooked category, and increasingly the first thing a serious investor or buyer asks for.
- Exporters in steel, cement, and aluminum now have to hand over verified emissions data just to clear EU customs under the Carbon Border Adjustment Mechanism (CBAM) — a European rule quietly reaching straight into UAE supply chains.
None of this shows up on the SCA’s calendar. All of it shows up on a scorecard someone else is already using to decide whether to do business with you.
So which one applies to you?
A rough map — not legal advice, just a starting point for a conversation:
- Listed on ADX or DFM? You’re in scope for SCA’s Article 76 mandate, and your report should follow your specific exchange’s guidance — not a generic template borrowed from the other one.
- Not listed, but your operations emit greenhouse gases — manufacturing, energy, logistics, construction, and similar sectors are squarely in view — you’re likely in scope for Decree No. 11, regardless of who owns the company.
- Regulated in ADGM? The Financial Services Regulatory Authority (FSRA) runs its own Sustainable Finance framework, with ESG disclosure obligations for regulated entities, listed funds, and asset managers — separate from SCA entirely.
- Based in DIFC? DIFC operates under its own legal system, with sustainable finance commitments driven through the Dubai Sustainable Finance Working Group rather than SCA’s rulebook.
- A bank, insurer, or other licensed financial institution? The Central Bank of the UAE has its own climate-risk governance principles for financial institutions, on top of — not instead of — anything above.
- None of the above technically applies, but your bank, your biggest customer, or your investors keep asking anyway? You’re in the fastest-growing category of all. The market is starting to behave like a mandate before the law has fully caught up — and by the time it does, the companies without an answer will be the ones scrambling.
Why this keeps getting tangled — and why it doesn’t have to
If you’ve felt behind on this, you’re genuinely not the exception. Between the exchanges, the federal climate law, free zone regulators, and the sector bodies layered on top, it’s a fair question with no single obvious answer — and “which one applies to us” is one of the most common, most reasonable things we hear, almost never asked too late to matter. It’s usually asked at exactly the right moment: before the data collection starts, before a deadline gets uncomfortably close, before a board meeting where someone asks a question nobody’s ready for.
That’s the work D1Percent does first — before a single spreadsheet gets touched. As a sustainability reporting framework consultant working across all four of these at once, we map your entity against SCA, ADX/DFM, and Decree No. 11 simultaneously, find where the obligations overlap so your team collects data once instead of four times, and flag exactly where they don’t overlap, so nothing quietly falls through the gap between “not listed” and “not exempt.”
Not sure which of these four actually apply to your business — or what it’s already costing you not to know? Book a Free Compliance Assessment with D1Percent. We’ll map your exact regulatory position before your next deadline gets closer than it looks.
This article is for general information and does not constitute legal advice. Regulatory requirements referenced are current as of publication; always confirm deadlines and scope with SCA, your listing exchange, or a qualified advisor.