QSE ESG reporting guidance: what listed companies should disclose

For almost a decade, ESG reporting by Qatar listed companies was voluntary. The Qatar Stock Exchange published guidance in 2016 and encouraged companies to use it. That era is over. The Qatar Financial Markets Authority Governance Code now requires listed companies to report under the ISSB Standards, starting with financial years beginning on or after 1 January 2026.

So the question has changed. It is no longer “what should we disclose under the QSE guidance?” It is “how do we turn what we already report into an ISSB-compliant disclosure, on time, with assurance?” This guide answers both.

The QSE guidance in brief

The QSE Guidance on ESG Reporting was published in 2016. It sets out 34 ESG indicators covering environmental, social and governance topics. In December 2018 the exchange launched an online platform where listed companies can upload sustainability reports and submit data on those indicators.

The indicators follow the familiar pattern of exchange ESG guidance. On the environmental side, energy use, emissions, water and waste. On the social side, workforce composition, health and safety, and training. On governance, board structure, ethics and disclosure practice.

The QSE has said publicly that new regulations would eventually mandate sustainability reporting for all listed companies. That is what the QFMA has now done, but through the ISSB Standards rather than the QSE indicator list.

What the QFMA now requires

The IFRS Foundation’s Qatar jurisdictional profile sets out the position:

• Instrument. The QFMA Governance Code for Listed Companies, issued following QFMA Board Decision No. 5 of 2025. It took effect on 17 August 2025.
• Requirement. Article 11 and Appendix 1.4 require listed companies to use the ISSB Standards, meaning IFRS S1 and IFRS S2.
• Guidance. QFMA published guidance titled How to start the journey in applying the ISSB Standards, in English and Arabic.
• Start. Financial years beginning on or after 1 January 2026.
• Timing. The QFMA guidance does not permit the IFRS S1 relief that lets first-year disclosures be published after the financial statements. Listed companies must publish with their accounts from year one.
• Assurance. QFMA guidance requires external assurance of the sustainability report under Chapter Five of the Governance Code. It refers to ISSA 5000, the international sustainability assurance standard.

The extended Scope 3 relief applies. Listed companies may omit Scope 3 emissions for the first two annual reporting periods.

Why the 34 indicators are not enough

The QSE indicators are mostly metrics. ISSB asks for much more than metrics.

QSE indicator approach	ISSB approach
A fixed list of indicators for everyone	Disclosure driven by what is material to enterprise value for your company
Focus on performance data	Governance, strategy, risk management, then metrics and targets
Separate sustainability report	Part of general purpose financial reporting, same entity and period
No requirement for scenario analysis	Climate resilience assessed using scenario analysis
Voluntary, no assurance requirement	Mandatory, with external assurance under QFMA guidance

A company that has reported all 34 indicators each year has a head start on data. It does not have a head start on governance narrative, risk integration or scenario analysis, which are where most first-year ISSB reports are weakest.

What listed companies should disclose for 2026

Here is the core structure of an ISSB-compliant disclosure, with notes on what a typical Qatar listed company needs.

Governance

Name the board body responsible for sustainability and climate risk. Describe how often it meets on the topic, what information it receives, and how its oversight shows up in decisions such as capital allocation or remuneration. State management’s role. If the audit committee owns it, say so, and describe the link to internal control.

Strategy

Describe the sustainability and climate risks and opportunities that could affect cash flows, access to finance or cost of capital. Be specific to your business. A real estate company should discuss cooling demand, building standards and physical heat risk. An industrial company should discuss energy costs, carbon pricing in export markets such as the EU CBAM, and customer demand for low-carbon products. A telecom should discuss energy use in networks and data centres.

Then describe the effect on your business model, your current financial position and your expected position. Finally, assess the resilience of your strategy under climate scenarios.

Risk management

Explain how you identify, assess and monitor sustainability risks, and how that process sits inside your enterprise risk framework. If climate is managed outside the risk register, fix that before you write the disclosure.

Metrics and targets

Disclose Scope 1 and Scope 2 greenhouse gas emissions, with the method, factors and boundaries. Scope 3 can wait two years under the relief, but start the screening now. Disclose any climate targets, how they are set and progress against them. Add the industry-based metrics that apply to your sector.

Our guide to Scope 1, 2 and 3 for Qatar companies explains the calculation and the grid factor choice.

Reuse your QSE data, carefully

Much of the QSE indicator data can feed the ISSB report. Energy and emissions data feeds Scope 1 and 2. Health and safety data may be material for industrial companies. Board data supports the governance pillar.

Three warnings.

1. Boundaries. ISSB disclosures cover the same reporting entity as the financial statements. If your past ESG data covered only the parent or a few sites, it must expand to the consolidated group.
2. Period. Use the financial year. If your sustainability data ran on a different period, align it.
3. Controls. Assurance providers will test how numbers were produced. A figure emailed from a site once a year will not survive ISSA 5000 testing without supporting evidence.

A realistic timeline for a December year-end company

When	What
Now	Gap analysis against IFRS S1 and S2. Appoint an owner. Brief the board.
Next 2 months	Materiality assessment. Expand data boundaries to the group.
Next 4 months	Scope 1 and 2 for the full group. Governance and risk narratives.
Next 6 months	Scenario analysis. Draft disclosure. Engage the assurance provider.
With 2026 accounts	Publish, with assurance, at the same time as the financial statements.

For many companies the calendar is already tight. If you are reading this in late 2026 without a gap analysis, focus on a compliant minimum for the first year: clear governance, a defensible materiality assessment, a clean Scope 1 and 2 inventory and an honest qualitative scenario analysis. Improve in year two.

Common mistakes

• Republishing the old ESG report with an ISSB index at the back. The structure and the materiality test are different.
• Forgetting the timing difference. QCB-regulated entities may have first-year timing relief. Listed companies do not.
• Late engagement with assurance. The assurance provider’s view of your controls should shape the data process, not arrive after it.
• Unsourced factors. State every emission factor and its source. Our calculator shows how.

Next step

Read the regulation summary and our practical guide to ISSB S1 and S2. If you need help building the first report, see our sustainability reporting service.

Sources

1. Qatar Stock Exchange, Sustainability and ESG
2. Qatar Stock Exchange, Guidance on ESG Reporting
3. IFRS Foundation, Qatar jurisdictional profile on use of ISSB Standards
4. IFRS S2 Climate-related Disclosures
5. 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.