QFMA's new Governance Code: what Qatar listed companies must report under ISSB

Qatar listed companies now have a mandatory sustainability reporting rule. It is not a stock exchange suggestion. It sits in the Governance Code issued by the Qatar Financial Markets Authority (QFMA), and it points straight at the ISSB Standards.

This article explains what the Code requires, who it covers, how assurance works, which reliefs apply and what a listed company should do now. We stick to what the published sources say. Where a detail is not settled in the sources we found, we say so.

The rule in one paragraph

QFMA Board Decision No. 5 of 2025 issued a new Governance Code for Listed Companies. It was published in the Official Gazette and took effect immediately from 17 August 2025. Article 11 and Appendix 1.4 of the Code require listed companies to use the ISSB Standards: IFRS S1 for general sustainability-related disclosures and IFRS S2 for climate. QFMA also published guidance for Main Market companies on how to start applying the standards. That guidance requires external assurance of the sustainability report.

Where this came from

For years, ESG reporting by Qatar listed companies was voluntary. The Qatar Stock Exchange published ESG guidance in 2016, with 34 indicators. Many companies reported against it. Few reported in a form an investor could compare across markets.

The new Code changes the basis. ISSB reporting is investor-focused. It asks what sustainability risks and opportunities could affect a company’s cash flows, its access to finance or its cost of capital, over the short, medium and long term. That is a different question from “what ESG data do we have?”

Qatar now has three financial regulators applying the ISSB Standards in parallel. The Qatar Central Bank applies them to banks and insurers. The Qatar Financial Centre Regulatory Authority applies them to its Category A firms. The QFMA applies them to listed companies. All three point to the same standards. A listed bank can fall under two of these at once.

Who must report

The IFRS Foundation jurisdictional profile for Qatar, updated in June 2026, sets out the scope clearly:

• Main Market companies: required. All companies listed on the Main Market must report under the ISSB Standards.
• Venture Market companies: permitted. QFMA permits Venture Market companies to apply the ISSB Standards. It does not require them to.
• Listed banks and insurers: both rules. They fall under the QFMA Code and the QCB Sustainability Reporting Framework.
• Listed QFC firms: both rules. Listed QFCRA firms are subject to the QFMA requirements too. The profile notes that only one QFCRA firm is currently listed.

The profile also records that the sustainability disclosures must cover the same reporting entity as the financial statements. If your accounts are consolidated, your sustainability report is consolidated too.

When it starts

This is where public commentary has been inconsistent. Some summaries give a compliance window running into August 2026. Others talk about the 2026 or 2027 reporting year.

The IFRS Foundation profile states that listed entities regulated by QFMA are subject to the requirements starting from the financial year beginning on or after 1 January 2026. That is the clearest statement we found in a primary-adjacent source. For a company with a December year end, the first ISSB report would cover 2026 and publish with the 2026 financial statements.

Our advice is simple. Treat 2026 as the first reporting year unless the QFMA tells you otherwise in writing. If your company has a non-calendar year end or a special listing position, check the QFMA text for your own case. Do not plan on a later date that you cannot point to in the Code or the guidance.

No delay after the accounts

IFRS S1 includes a first-year relief. It lets a company publish its sustainability disclosures after its financial statements in the first year. QCB-regulated banks and insurers, and QFCRA firms, can use it.

Listed companies cannot. According to the IFRS Foundation profile, Table 1.2 of the QFMA guidance does not permit this relief. Listed companies must publish their sustainability disclosures at the same time as their financial statements, from the first year.

This is the most important practical point in the whole rule. It means the sustainability report runs on the same calendar as the annual accounts. The data must be closed, reviewed and assured in the same window as the financial audit. Companies used to publishing an ESG report months after the AGM need to change their process now.

External assurance

QFMA’s guidance requires companies to obtain external assurance for the sustainability report, in accordance with Chapter Five of the Governance Code. Market summaries describe this as assurance by the external auditor.

The guidance points to the international framework for sustainability assurance:

• ISSA 5000, the IAASB standard for sustainability assurance engagements.
• The IESBA ethics and independence standards for sustainability assurance.
• The IESBA Code of Ethics for Professional Accountants.

The sources we reviewed do not state whether the assurance is limited or reasonable in the first years. Check the QFMA text and agree the level and scope with your auditor.

What assurance means in practice:

• Every number needs a trail. Activity data, emission factors, calculations and estimates must be documented and reproducible.
• Controls matter. The auditor will look at who collects the data, who reviews it and how errors are caught.
• Judgements must be written down. Materiality decisions, scenario assumptions and boundary choices need a rationale on file.
• Timing is tight. Assurance work runs alongside the financial audit. Late data means a late report or a qualified one.

Transition reliefs

The profile records that Qatar has extended two IFRS S2 reliefs from one year to two:

• Scope 3 emissions. Companies may choose not to disclose Scope 3 greenhouse gas emissions for the first two years.
• Measurement method. Companies that used a method other than the GHG Protocol Corporate Standard in earlier reports may keep using it for two years.

The profile records no other jurisdictional modifications to IFRS S1 or S2. Companies must make an explicit and unreserved statement of compliance with the ISSB Standards. Dual reporting claims are not allowed.

A relief is not a reason to wait. Scope 3 is usually the largest share of a company’s footprint and the hardest to measure. Supplier data, spend data and product use data take time to collect. A company that starts its Scope 3 screening in year three will publish weak numbers in year three.

Other standards and digital reporting

QFMA guidance paragraph 24 says companies are free to also use GRI or ESRS, as long as the ISSB information stays clear and distinctly identifiable. Many Qatar companies already report under GRI. That can continue, but the ISSB disclosures cannot be buried inside a GRI index.

Digital tagging is not required. QFMA guidance encourages XBRL for sustainability reporting.

What the report must contain

IFRS S1 and S2 are built on four pillars:

1. Governance. How the board and management oversee sustainability and climate risks and opportunities.
2. Strategy. The material risks and opportunities, their effect on the business model and financial position, and climate resilience tested through scenario analysis.
3. Risk management. How the company identifies, assesses and monitors these risks, and how that links to overall risk management.
4. Metrics and targets. Scope 1, 2 and (after relief) Scope 3 emissions, industry-based metrics, and progress against any targets.

The old QSE indicators cover part of the fourth pillar. They say little about the first three. That is where most of the gap lies.

A practical plan for a listed company

If you have not started, this sequence works:

Step	Work
1. Gap assessment	Compare your current ESG report and QSE indicators with every IFRS S1 and S2 requirement. Rank the gaps by effort and risk.
2. Governance	Assign board and committee oversight. Name a management owner. Train the board on its duties.
3. Materiality	Identify risks and opportunities that could affect cash flows, finance access or cost of capital. Document the reasoning.
4. Emissions	Close Scope 1 and 2 with sourced factors. Screen Scope 3 categories now.
5. Scenario analysis	At least a qualitative climate scenario analysis in year one, with a path to quantitative.
6. Assurance readiness	Build the evidence pack. Run a dry run with your external auditor before year end.
7. Drafting	Write disclosures that sit with the financial statements and agree with them.

For many companies the time is short. If you are reading this late in 2026 with no gap assessment, aim for a compliant, defensible first report: clear governance, a documented materiality process, clean Scope 1 and 2 numbers and an honest qualitative scenario analysis. Improve in year two.

Common mistakes to avoid

• Treating it as an ESG report refresh. The ISSB test is financial materiality to investors. The structure is different.
• Assuming the QCB timing relief applies. It does not apply to listed companies under the QFMA guidance.
• Bringing in assurance at the end. The auditor’s view of your controls should shape your data process from the start.
• Ignoring Scope 3 because of the relief. The relief ends. The data takes longer than two years to build well.
• Using unsourced emission factors. Every factor needs a named source and year.

What we still recommend checking

Two points deserve a direct read of the QFMA text before you commit a plan. First, the exact first reporting period for your company, especially with a non-calendar year end. Second, the level of assurance expected in the first years. Both affect cost and timing.

Next step

Read our key facts on the QFMA rule. Try the Scope 1-3 emissions calculator to size your inventory. If you need help building the first report and getting it ready for assurance, see our ISSB reporting for Qatar listed companies service.

This article is a summary for orientation only. It is not legal advice. Always check the current text with the QFMA.

Sources

1. IFRS Foundation, Qatar jurisdictional profile on use of ISSB Standards (updated June 2026)
2. Qatar Financial Markets Authority, official website
3. Gulf Times, QFMA issues Code of Governance for Listed Companies
4. IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
5. IFRS S2 Climate-related Disclosures
6. IAASB, ISSA 5000 General Requirements for Sustainability Assurance Engagements

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