QCB’s Sustainability Reporting Framework: What Qatari Banks and Insurers Must Do Before 2027

QCB Sustainability Reporting Framework
Regulatory position last reviewed 5 November 2026
The short answer

The Qatar Central Bank (QCB) issued its Sustainability Reporting Framework on 4 December 2025. It is based on IFRS S1 and IFRS S2, the sustainability standards of the International Sustainability Standards Board (ISSB), and it covers the banks and insurance companies that QCB regulates. Reliefs defer parts of the work. They do not remove it.

4 Dec 2025Framework issued by QCB
1 Jan 2026Applies to financial years beginning on or after this date
FY2026First reporting year
2027First report falls due

The QCB sustainability reporting framework has moved ESG reporting in Qatar’s financial sector from voluntary practice to a supervised, standards-based regime. That changes who owns the data, who signs it off and what an auditor, a supervisor or a rating analyst can ask you to prove.

The timing is tighter than the headline suggests. For an institution with a December year-end, the first reporting year closes on 31 December 2026. The question for most banks and insurers is no longer whether to start. It is how to evidence FY2026 data that is already being generated, and how to be ready to report it in 2027.

This guide explains the QCB ESG reporting requirements: what the framework requires, who it covers, how IFRS S1 and S2 apply in Qatar, and what to do next for Qatar ESG compliance. It separates what the sources show is mandatory from what we recommend as good practice, and it flags the points to confirm against the official text.

What Is QCB’s Sustainability Reporting Framework?

QCB’s Sustainability Reporting Framework (SRF) is a regulatory framework that sets out how Qatar’s banks and insurers disclose sustainability-related financial information. It is built on IFRS S1 and S2. The IFRS Foundation’s jurisdiction profile for Qatar describes the country as adopting ISSB Standards with limited transition.

Why QCB introduced it. Public reporting describes the framework as part of the Third Financial Sector Strategy, and as aligned with the national ESG and Sustainability Strategy for the Financial Sector. The stated aims are better transparency, accountability and quality of sustainability disclosures, and stronger management of climate-related risk. Adopting ISSB Standards also puts Qatari institutions on the same disclosure basis as investors, lenders and rating agencies elsewhere.

What it covers. Public summaries describe four core disclosure areas: governance, strategy, risk management, and metrics and targets. These mirror the structure of IFRS S1 and S2.

It is phased. QCB adopted a phased approach with transitional reliefs, because institutions start from different levels of maturity. The reliefs are covered in the timeline section below.

Which Financial Institutions Must Comply?

The framework applies to banks and insurance companies regulated by QCB, whether or not they are listed. That includes commercial banks and other QCB-licensed banks, and QCB-licensed insurers. Do not read this as a rule for every financial institution in Qatar. Three regulators issue separate ISSB-based requirements, and the right one depends on your licence and listing status.

QCBQatar Central Bank
Who it covers
Banks and insurers licensed by QCB, listed or unlisted
Instrument
Sustainability Reporting Framework, issued 4 December 2025
Key point
Financial years beginning on or after 1 January 2026. First-year timing relief and transitional reliefs apply
QFCRAQFC Regulatory Authority
Who it covers
Firms authorised in the Qatar Financial Centre. Category A firms automatically, other firms if designated
Instrument
General Rule RM/2025-1, issued 26 June 2025
Key point
Separate rulebook. Financial years beginning on or after 1 January 2026. The QFCRA plans an assurance framework
QFMAQatar Financial Markets Authority
Who it covers
Companies listed on the Qatar Stock Exchange
Instrument
Governance Code, Board Decision No. 5 of 2025, effective 17 August 2025
Key point
Article 11 and Appendix 1.4 require ISSB Standards. External assurance under Chapter Five. QFMA guidance does not allow first-year timing relief
Dual obligations are possible

A bank listed on the Qatar Stock Exchange answers to the QFMA as a listed company and to QCB as a bank. An institution licensed in both the QFC and by QCB may face both rulebooks. Do not assume one report satisfies every regulator. Confirm with each regulator how the requirements interact, including which timing relief applies to a listed bank.

Understanding IFRS S1 and IFRS S2

The two standards behind IFRS S1 and S2 reporting in Qatar work as a pair. IFRS S1 sets the general rules for disclosing sustainability-related financial information. IFRS S2 applies those rules to climate.

IFRS S1General Requirements for Disclosure of Sustainability-related Financial Information

Asks for information on sustainability-related risks and opportunities that could reasonably be expected to affect cash flows, access to finance or cost of capital over the short, medium and long term. That is financial materiality: the effect on the institution’s own prospects, not every sustainability topic.

  • Governance: board and management oversight
  • Strategy: effect on business model and resilience
  • Risk management: how risks are identified and managed, and the link to enterprise risk management
  • Metrics and targets: how performance is measured
IFRS S2Climate-related Disclosures

Uses the same four headings for climate.

  • Physical risks: acute events such as flooding and heat, and chronic climate shifts
  • Transition risks: policy, technology, market and reputation effects
  • Opportunities from climate change
  • Scenario analysis: resilience under different climate outcomes
  • Emissions: Scope 1, 2 and 3, subject to reliefs
  • Financial effects on position, performance and cash flows

For banks and insurers, Scope 3 matters more than for most sectors, because the largest emissions sit in the loan book, investments and underwriting portfolios. IFRS S2 includes industry-specific guidance on financed emissions for these sectors. Confirm the exact requirements and how the reliefs apply against the standard and the QCB text.

The Four Core Pillars of QCB Sustainability Reporting

Each pillar has a regulatory expectation, an internal owner and a typical gap. The expectations reflect IFRS S1 and S2. The owners and gaps are our practical view, not a requirement.

Governance

What is expectedBoard and management oversight of sustainability-related risks and opportunities

What to assessWho is accountable, what skills the board has, how oversight is documented

TeamsBoard secretariat, CEO office, compliance, internal audit

Common gapOversight exists in practice but is not written into committee terms of reference or minutes

Strategy

What is expectedHow risks and opportunities affect strategy, business model and financial position, including climate resilience

What to assessMaterial risks and opportunities, effects by time horizon, scenario analysis

TeamsStrategy, finance, treasury, business lines

Common gapStrategy documents do not mention climate. Scenario analysis is absent or one-off

Risk management

What is expectedHow the institution identifies, assesses and manages these risks, linked to enterprise risk management

What to assessWhether climate risk sits in the risk register, credit and underwriting processes

TeamsChief Risk Officer, credit, underwriting, compliance

Common gapClimate is reported in a separate silo from enterprise risk

Metrics and targets

What is expectedCross-industry and industry metrics, emissions, targets and progress

What to assessEmissions inventory, financed emissions, target basis, data sources

TeamsSustainability, finance, IT, data, procurement

Common gapInconsistent methods, missing Scope 3 data, no evidence trail

Built on IFRS S1 and IFRS S2 (ISSB)

The 2026 to 2027 Sustainability Reporting Timeline

  1. 4 December 2025QCB issues the Sustainability Reporting Framework.
    IFRS Foundation profile and press reports
  2. 1 January 2026Applies to financial years beginning on or after this date.
    IFRS Foundation profile
  3. FY2026: first reporting yearGovernance in place, data collected, assessments done.
    Derived from the effective date
  4. 2027: first reportCovers FY2026 information.
    Adviser summaries citing the framework
  5. Year one reliefInstitutions may publish sustainability disclosures after the annual financial statements (first-year relief in IFRS S1 paragraph E4).
    IFRS Foundation profile and adviser summaries
  6. Year two onwardsPublication alongside the financial statements.
    Adviser summaries. Confirm in the framework
Reliefs, not exemptions

Qatar extends two IFRS S2 reliefs by one year: the option to keep using a measurement method other than the GHG Protocol, and the option to omit Scope 3 emissions. Adviser summaries describe this as two years of relief in total. They apply to timing and method, and they do not remove the duty to build the capability.

Assurance. QCB has stated that a framework for assurance of sustainability information will be developed and implemented based on international assurance standards. We found no date. Treat assurance as coming, and keep an audit trail now.

What we could not confirm

We found no stated submission date to QCB for the first report. Confirm the exact submission and publication deadlines with QCB, and do not assume a date from adviser calendars.

What Qatari Banks and Insurers Must Do Before Their First 2027 Reporting Cycle

The framework sets the obligation. These twelve steps are our recommended preparation, in a practical order. Where we say “must”, it comes from the standards or the framework. Everything else is good practice.

  1. Run an IFRS S1 and S2 gap assessmentIt shows what you already disclose and what is missing.Sustainability, finance, risk, compliance
  2. Identify material risks and opportunitiesFinancial materiality decides what you report.Strategy, risk, business lines
  3. Establish board and management oversightName accountable committees and record the oversight.Board secretariat, CEO office
  4. Integrate climate risk into enterprise risk managementSupervisors and auditors will look for one risk process, not two.Chief Risk Officer, credit, underwriting
  5. Run climate scenario analysisIFRS S2 expects resilience to be assessed. Decide scope and tools early.Risk, strategy, treasury
  6. Assign ESG data ownershipEvery metric needs a named owner and a backup.Finance, sustainability, IT
  7. Build Scope 1, 2 and relevant Scope 3 inventoriesStart with operations, then financed and insured emissions, using the reliefs deliberately.Sustainability, finance, facilities, portfolio teams
  8. Define metrics and targetsChoose metrics you can measure repeatedly.Strategy, sustainability, finance
  9. Build data collection and validationSet templates, thresholds and reconciliations.Finance, data, IT
  10. Establish internal review and reporting controlsTreat sustainability data like financial data: preparer, reviewer, sign-off.Finance, internal audit, compliance
  11. Prepare evidence and documentationKeep methods, sources, assumptions and approvals.Every data owner
  12. Assess assurance readinessAssurance requirements are developing, and listed banks already face assurance under the QFMA Code.Internal audit, external auditor, audit committee

Common Challenges Financial Institutions May Face

Fragmented ESG dataData sits in finance, HR, facilities and risk systems.FixCreate one dataset with named owners and a single data dictionary.
No standard methodsDifferent teams calculate the same metric differently.FixDocument one methodology per metric and apply it every year.
Hard-to-assess climate financial riskModels and loan-level data are limited.FixStart with sector and geography screens, then refine by portfolio.
Gaps in emissions dataSuppliers and borrowers do not report.FixUse documented estimates, label them clearly and plan data improvement.
Unclear ownershipSustainability is treated as one team’s job.FixAssign owners by metric and put sign-off in the controls.
Limited technical skillsISSB expertise is scarce.FixTrain core teams and bring in specialist support for the first cycle.
Weak audit trailEvidence lives in emails and spreadsheets.FixKeep sources, versions and approvals in one place.
Climate outside enterprise riskSustainability reports to a separate committee.FixAdd climate to the risk register and to credit and underwriting processes.
Inconsistent year-on-year disclosureMethods and boundaries change.FixFix the boundary and methods, and log every change.

How Technology Can Strengthen Sustainability Reporting

Spreadsheets can carry a first cycle, but they strain under a second. Technology helps most where the challenges above are about process, not judgement:

  • Centralised ESG data management
  • Automated data collection
  • Reporting workflows
  • Validation and accountability
  • KPI monitoring
  • Audit trails
  • Management dashboards
  • Reporting documentation

Platforms such as SEED ESG support structured sustainability data management, monitoring and reporting workflows. Software does not decide materiality, does not interpret the standards and does not guarantee compliance. It makes good governance easier to run and to evidence.

How D1 Percent Can Support Financial Institutions

D1 Percent is an ESG and sustainability advisory firm that works with companies in the UAE, India, Qatar and the wider GCC. For banks and insurers preparing for QCB reporting, we map our support to the challenges above:

Readiness and gap assessmentsShow where you stand against IFRS S1 and S2.
ESG strategy and governancePuts oversight, ownership and committee structures in place.
Climate risk and materialityDefines what you report and how it links to risk management.
ESG data managementBuilds the dataset, owners and controls behind each metric.
Emissions measurement and monitoringRepeatable Scope 1, 2 and 3 inventories. See our carbon accounting and GHG reporting support.
Sustainability reporting supportDrafts and reviews the report. See our ESG reporting services.

We also build the implementation roadmap and internal controls that turn the first cycle into a repeatable process. For the wider regional picture, read what an ESG policy needs across the GCC, and our guide to ESG reporting for banks and insurers in the UAE.

Frequently Asked Questions

What is QCB’s Sustainability Reporting Framework?

It is a framework issued by the Qatar Central Bank on 4 December 2025 that applies IFRS S1 and IFRS S2 to the banks and insurance companies QCB regulates. It requires disclosure on governance, strategy, risk management, and metrics and targets.

Which banks and insurance companies must comply with QCB’s ESG reporting framework?

Banks and insurers regulated by QCB, whether listed or unlisted. QFC-authorised firms follow the QFCRA’s rules, and Qatar Stock Exchange-listed companies also follow the QFMA Governance Code. Some institutions face more than one set of requirements.

When does QCB sustainability reporting become mandatory?

The framework applies to financial years beginning on or after 1 January 2026. The first report, covering FY2026, falls in 2027. Confirm the exact submission and publication dates with QCB.

What is the first reporting year under QCB’s framework?

FY2026. Institutions may use first-year relief to publish their sustainability disclosures after the annual financial statements. From year two, they are expected to publish alongside them.

What is the difference between IFRS S1 and IFRS S2?

IFRS S1 sets the general requirements for disclosing sustainability-related financial information. IFRS S2 sets climate-specific requirements, including physical and transition risks, scenario analysis and greenhouse gas emissions. Both use the same four headings.

What are the four pillars of sustainability reporting?

Governance, strategy, risk management, and metrics and targets. They come from the ISSB standards and form the core disclosure areas of the QCB framework.

Is ESG reporting mandatory for banks in Qatar?

For banks regulated by QCB, sustainability reporting under the framework applies from financial years beginning on or after 1 January 2026. Listed banks also follow the QFMA Governance Code, and QFC-authorised banks follow the QFCRA rules.

What should banks do before 2027?

Run a gap assessment, assign data ownership, build emissions inventories, integrate climate into risk management, set up controls and keep evidence. The twelve-step list above sets out the sequence.

What are the biggest challenges in implementing IFRS S1 and S2?

Fragmented data, inconsistent methods, financed-emissions data, unclear ownership, limited technical skills and weak audit trails. Most are process and governance problems that start early and are cheaper to fix before the first report.

Build the Reporting Infrastructure Before the First Cycle

The QCB sustainability framework for 2026 applies ISSB-based disclosure to Qatar’s banks and insurers for financial years beginning on or after 1 January 2026, and it sets the pace for sustainability reporting in Qatar’s financial sector. The first reporting year is FY2026, and the first report falls in 2027. Reliefs give time on method and publication, but the governance, the data and the controls need to exist now.

The institutions that handle the first cycle well will not be the ones with the longest report. They will be the ones that can show where each number came from.

Is your institution ready for its first QCB sustainability report?

D1 Percent can assess your reporting readiness against IFRS S1 and S2, map your data and governance gaps, and set a roadmap for the first cycle.

Contact D1 Percent

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