Navigating Mandatory ESG Reporting in the UAE: Preparing for Compliance Post-Federal Decree-Law No. 11 of 2024

Key Takeaways

  • By May 30, 2025, Federal Decree-Law No. 11 requires all PJSCs and large private firms (≥500,000 tCOâ‚‚e), including those in free zones, to submit ESG reports.
  • Secure five years of audit-ready ESG data and use GRI, TCFD, and SASB frameworks to maintain compliance and access to government contracts.
  • Follow ASC Group’s 90-day plan—phase 1: gap analysis; phase 2: framework alignment; phase 3: assurance prep—to fast-track ESG readiness.
  • Kick off with a 30-day materiality and data audit to prioritize key disclosures and implement real-time KPI dashboards.
  • Engage ASC Group early for streamlined MOCCAE submissions and to unlock sustainable financing opportunities.

Introduction: Preparing for the Evolving ESG Reporting Landscape in the UAE 

The UAE's commitment to sustainability is rapidly shaping its corporate landscape. Public Joint-Stock Companies (PJSCs) listed on DFM and ADX face a mandatory sustainability disclosure deadline of March 31, 2025, for their 2024 annual reports. Beyond this, a new era of broader mandatory reporting is ushered in by Federal Decree-Law No. 11 of 2024 on Environmental, Social, and Governance (ESG) disclosures, effective May 30, 2025. This law will extend mandatory requirements to large private firms and other entities, including those in free zones. This evolving environment demands a strategic shift from voluntary CSR initiatives to comprehensive, auditable disclosures. Proactive engagement with expert sustainability compliance UAE advisors is crucial. These advisors help companies establish robust reporting frameworks aligned with international standards like GRI, TCFD, and SASB, ensuring they not only meet their specific regulatory obligations but also unlock new opportunities for investment, financing, and partnerships in an increasingly sustainability-focused global market. 

 

Problem: Evolving ESG Reporting Requirements and Their Impact on Capital Access 

The landscape of mandatory ESG reporting in the UAE is rapidly expanding. For Public Joint-Stock Companies (PJSCs) listed on DFM and ADX, the deadline for submitting their 2024 annual sustainability report is March 31, 2025. Failure to meet this deadline for PJSCs can lead to reputational damage, frozen capital inflows, and regulatory consequences. 

Looking ahead, Federal Decree-Law No. 11 of 2024, effective May 30, 2025, marks a significant shift, broadening the scope of mandatory ESG reporting. This law mandates disclosures for large private firms (specifically those with 500,000t COâ‚‚e/year emissions and above), in addition to public entities. Critically, the law applies to both public and private entities, including those in free zones. Companies covered by this new mandate must prepare to: 

  • Measure and disclose Scope 1 & 2 emissions (Scope 3 optional, depending on sector). 
  • Align with GRI, TCFD climate risk, and SASB industry metrics. 
  • Maintain five years of audit-ready data. 

While there is no March 31, 2025, ESG reporting deadline for 2024 data specifically for these newly mandated entities (large private firms and free zone entities), their compliance and reporting obligations will commence after the May 30, 2025, effective date, subject to further implementing regulations from the Ministry. Failure to prepare proactively and comply with future reporting cycles will: 

  • Exclude firms from ESG-linked financing and equity issuances. 
  • Trigger potential penalties and impede government contracts. 
  • Undermine investor confidence amid rising demand for transparent sustainability performance. 

2. Solution Overview: 90-Day ESG Compliance Blueprint 

ASC Group’s 90-day UAE ESG reporting deadline 2025 blueprint guides businesses through rapid compliance: 

 

Phase Key Activities Deliverables 
Days 1–30 ESG gap analysis; stakeholder mapping Materiality matrix; data-collection plan 
Days 31–60 Framework alignment (GRI, TCFD, SASB); target setting Draft disclosures; KPI dashboards 
Days 61–90 Third-party assurance prep; submission readiness Investor-grade report; MOCCAE portal files 

 

3. Phase 1 (Days 1–30): ESG Gap Analysis & Data Infrastructure 

  • Materiality Assessment: Engage stakeholders to prioritize ESG topics aligned with Vision 2030 and investor criteria. 
  • Data Audit: Map existing environmental and social data streams; identify Scope 1, 2, and relevant Scope 3 sources. 
  • System Setup: Implement digital data-management tools and assign internal ESG champions. 
  • Outcome: Comprehensive materiality matrix and data-collection framework ready for reporting. 

4. Phase 2 (Days 31–60): Framework Alignment & KPI Development 

  • Framework Mapping: Cross-map GRI disclosures, TCFD risk statements, and SASB metrics to organizational processes. 
  • Target Setting: Define science-based emission reduction goals and social impact KPIs (e.g., workforce diversity, supplier audits). 
  • Draft Report: Prepare preliminary sections on governance, strategy, and metrics; build real-time KPI dashboards. 
  • Outcome: First draft of sustainability report and live dashboard for executive monitoring. 

5. Phase 3 (Days 61–90): Assurance Prep & Readiness for Submission 

  • External Assurance: Coordinate with accredited auditors to verify emissions data and narrative disclosures. 
  • Investor-Ready Packaging: Finalize report layout, infographics, and compliance checklists for future regulatory/investor reviews. 
  • Regulatory Readiness: Prepare disclosures for submission to the Ministry of Climate Change & Environment (MOCCAE) portal once reporting cycles and deadlines relevant to each entity are officially announced. 

Outcome: Fully assured, investor-grade ESG report ready for future submission, positioning the company to unlock sustainable finance opportunities. 

 

6. Documentation Templates & Tools 

  • ASC provides ready-to-use templates: 
  • Materiality matrix workbook 
  • GRI/TCFD/SASB cross-reference tracker 
  • Emissions-data logging sheet 
  • Assurance readiness checklist 
  • Submission guide for MOCCAE digital platform 

 

Conclusion 

The enactment of Federal Decree-Law No. 11 of 2024 signals a new era for corporate responsibility in the UAE. While PJSCs navigate their March 2025 deadline, all other newly mandated entities must proactively prepare for sustainability compliance as the law becomes effective on May 30, 2025. This preparation is essential to safeguard access to critical capital and maintain investor confidence. By leveraging ASC Group’s 90-day blueprint—comprising rigorous gap analysis, alignment with GRI/TCFD/SASB frameworks, and assurance readiness—organizations can transform these evolving reporting obligations into strategic advantages. With ready-to-use templates, real-time KPI dashboards, and expert advisory support, companies can not only meet future regulatory requirements but also unlock sustainable finance opportunities. Proactive ESG disclosure positions UAE businesses to thrive in a market where transparency and resilience are paramount for long-term growth and investment success. 

 

Don't risk penalties or lost investment opportunities. Partner with ASC Group today for our 90-day ESG Compliance Blueprint and ensure your timely, investor-ready sustainability disclosure. 

 

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