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.
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.
- 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
- 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
- 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
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.
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
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
The 2026 to 2027 Sustainability Reporting Timeline
- 4 December 2025QCB issues the Sustainability Reporting Framework.
IFRS Foundation profile and press reports - 1 January 2026Applies to financial years beginning on or after this date.
IFRS Foundation profile - FY2026: first reporting yearGovernance in place, data collected, assessments done.
Derived from the effective date - 2027: first reportCovers FY2026 information.
Adviser summaries citing the framework - 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 - Year two onwardsPublication alongside the financial statements.
Adviser summaries. Confirm in the framework
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.
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.
- Run an IFRS S1 and S2 gap assessmentIt shows what you already disclose and what is missing.Sustainability, finance, risk, compliance
- Identify material risks and opportunitiesFinancial materiality decides what you report.Strategy, risk, business lines
- Establish board and management oversightName accountable committees and record the oversight.Board secretariat, CEO office
- Integrate climate risk into enterprise risk managementSupervisors and auditors will look for one risk process, not two.Chief Risk Officer, credit, underwriting
- Run climate scenario analysisIFRS S2 expects resilience to be assessed. Decide scope and tools early.Risk, strategy, treasury
- Assign ESG data ownershipEvery metric needs a named owner and a backup.Finance, sustainability, IT
- 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
- Define metrics and targetsChoose metrics you can measure repeatedly.Strategy, sustainability, finance
- Build data collection and validationSet templates, thresholds and reconciliations.Finance, data, IT
- Establish internal review and reporting controlsTreat sustainability data like financial data: preparer, reviewer, sign-off.Finance, internal audit, compliance
- Prepare evidence and documentationKeep methods, sources, assumptions and approvals.Every data owner
- 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
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:
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:
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.
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