QCB Sustainability Reporting Framework 2026 explained for Qatar banks and insurers

Every bank and insurer regulated by the Qatar Central Bank now reports sustainability information under the ISSB Standards. The first financial year in scope began on 1 January 2026. The first report lands with the 2026 accounts. If your institution has not yet built the data, the governance and the controls, the time to start was last quarter. The second best time is now.

This guide sets out what the framework requires, what relief you have, and how to plan the first year.

What the QCB issued

On 4 December 2025 the QCB issued its Sustainability Reporting Framework (SRF) According to ISSB Standards: For Banks and Insurance Companies 2025. The IFRS Foundation records it in its Qatar jurisdictional profile as one of three parallel regimes that bring the ISSB Standards into Qatar law and regulation.

The framework applies two standards:

• IFRS S1, General Requirements for Disclosure of Sustainability-related Financial Information.
• IFRS S2, Climate-related Disclosures.

The IFRS Foundation profile records no jurisdictional modifications to either standard. In plain terms, the QCB has not written its own version of ISSB. It has adopted the standards as issued and adjusted only some transition reliefs. Reporters must make an explicit and unreserved statement of compliance with the ISSB Standards.

Who is in scope

The framework covers all banks and insurance companies regulated by the QCB, listed and non-listed. That last point matters. A non-listed insurer that has never published a sustainability report is in the same position as a listed bank.

Two other regimes sit alongside it:

Regulator	Instrument	Who it covers
QCB	Sustainability Reporting Framework, 4 December 2025	Banks and insurers regulated by QCB
QFMA	Governance Code for Listed Companies, Board Decision No. 5 of 2025, effective 17 August 2025	Companies listed on the main market
QFCRA	General Rule RM/2025-1, issued 26 June 2025	QFC Category A firms (banks, insurers, discretionary investment managers) and designated Category B firms

A listed bank answers to both the QCB and the QFMA. The good news is that all three point to the same IFRS S1 and S2. One well-built report can satisfy both, provided you meet the stricter timing and assurance rule of each.

The core requirement

IFRS S1 asks for material information about sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital over the short, medium or long term. The users are investors, lenders and other creditors. Not NGOs, not the general public.

For a bank or insurer, the material risks rarely sit in your own buildings. They sit in the balance sheet. Climate transition risk in a corporate loan book. Physical risk in a mortgage portfolio or a property insurance book. Underwriting exposure to carbon-intensive sectors. The report must show how you govern these risks, how they shape strategy, how you identify and manage them, and which metrics and targets you use.

IFRS S2 structures climate disclosure under four pillars:

1. Governance. Which board body oversees climate risk, how often, with what skills, and how it feeds into decisions.
2. Strategy. The climate risks and opportunities you face, their effect on your business model and financial position, and the resilience of your strategy under climate scenarios.
3. Risk management. How climate risk is identified, assessed, prioritised and monitored, and how that process links to enterprise risk management.
4. Metrics and targets. Scope 1, 2 and 3 greenhouse gas emissions, climate-related targets and industry-based metrics.

For banks and insurers, Scope 3 includes financed emissions and, for insurers, emissions associated with underwriting. IFRS S2 asks for specific information on these for entities in commercial banking, insurance and asset management. This is the hardest data in the whole report.

Timing and the first-year relief

The IFRS Foundation profile says sustainability disclosures must be published at the same time as the financial statements. For the first annual reporting period, banks and insurers regulated by the QCB may use the relief in paragraph E4 of IFRS S1. That relief lets an entity publish its first-year sustainability disclosures after the financial statements, within limits set in the standard.

Be careful if you are also listed. The profile states that QFMA guidance does not permit this relief for listed entities. A listed bank therefore has to publish with its 2026 accounts. The QCB relief does not help it.

Extended transition reliefs

Qatar has extended two IFRS S2 reliefs from one year to two years for all entities reporting under the ISSB Standards:

• Scope 3 relief. You may omit Scope 3 emissions for the first two annual reporting periods instead of one.
• Measurement method relief. If you used a method other than the GHG Protocol Corporate Standard before, you may keep using it for two years.

The Scope 3 extension is the important one for banks. It buys time to build financed emissions properly. It does not remove the need. Use the two years to collect counterparty data, choose an attribution method, and test it. If you wait until year two to start, you will publish a weak number in year three.

IFRS S1 also includes a climate-first relief, letting entities report only on climate in the first year. Check how the QCB framework treats this before you rely on it.

What a QCB report needs from your teams

A working first report pulls from four places.

Risk. Your climate risk assessment, sector heat maps, scenario work and the link to credit risk appetite. If your stress testing does not include climate yet, IFRS S2 scenario analysis will force the question.

Finance. The same reporting entity and period as the financial statements. Connections between sustainability disclosures and financial line items, such as impairment assumptions or provisions affected by climate risk.

Operations. Scope 1 and 2 from branches, head office, data centres and vehicles. These are small numbers for a bank, but they are the easiest place to show a clean method.

Business lines. Exposure by sector, collateral location for physical risk, and green or sustainable finance volumes. Those volumes must align with the QCB Sustainable Finance Framework if you label them.

A practical first-year plan

Here is a sequence that works for most mid-sized institutions.

Month 1. Scope and gap. Read IFRS S1 and S2 against what you already publish. Most Qatar banks have an annual sustainability report built on the QSE indicators or GRI. Map each ISSB requirement to existing content, partial content or nothing. The gap list is your project plan.

Month 2. Materiality. Run an ISSB-style materiality assessment. It differs from a GRI impact assessment. The question is what affects enterprise value, not what affects the world. Expect climate to be material. Test whether other topics, such as governance of data privacy or financial inclusion, meet the bar.

Months 2 to 4. Governance and controls. Name the board committee. Write its terms of reference for climate. Set a management owner. Document data flows and controls as you would for any financial disclosure. External assurance will test these.

Months 3 to 6. Data. Close Scope 1 and 2. Start financed emissions on your largest sectors. Collect what counterparties already publish before you send questionnaires.

Months 5 to 8. Scenario analysis. Choose at least one orderly and one disorderly or hot-house scenario. Apply them qualitatively at first if needed. IFRS S2 allows an approach proportionate to your skills and resources, but it must be explained.

Months 8 to 12. Draft, review, align. Draft the disclosures. Align numbers and assumptions with the financial statements. Run an internal dry run of the assurance process.

Common mistakes to avoid

• Treating ISSB as a rebrand of the old sustainability report. The audience and the materiality test are different. Long narratives on community events do not answer IFRS S2.
• Building the report outside finance. The disclosures sit in general purpose financial reports and follow the same period and entity. Finance must own the close.
• Leaving financed emissions to year three. The extended relief is a runway, not a waiver.
• Using grid factors without stating the source. Disclose which factors you used and why. Our Scope 1-3 calculator lists its sources for this reason.

Where to start this week

Run the QCB readiness checklist. It scores your institution against the main framework areas in about ten minutes and shows the biggest gaps. Then read the regulation summary and the related guide on ISSB S1 and S2 for GCC companies.

The framework text itself is published by the QCB. Treat this guide as orientation and check every requirement against the issued document.

Sources

1. IFRS Foundation, Qatar jurisdictional profile on use of ISSB Standards
2. Qatar Central Bank, official website
3. IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
4. IFRS S2 Climate-related Disclosures
5. GHG Protocol Corporate Accounting and Reporting Standard

This article is general information, not legal or regulatory advice. Check the current text of each rule with the issuing authority.