Dubai's DFM ESG Reporting Guide: The Metrics DFM and Nasdaq Dubai Issuers Should Disclose | Spectreco

Dubai’s DFM ESG Reporting Guide: The Metrics DFM and Nasdaq Dubai Issuers Should Disclose

If your company is a public joint stock company listed on the Dubai Financial Market (DFM), a sustainability report is a rule, not a choice. Under Article 76 of the Corporate Governance Guide issued by the UAE’s Securities and Commodities Authority (SCA), the report is due within 90 days of financial year-end or before the annual general assembly, whichever comes first.

Spectreco, a US-headquartered sustainability technology and advisory company with an office in Dubai, frames the topic around three questions: are we in scope, when is it due, and which metrics does DFM expect? The DFM ESG Reporting Guide answers the third, but it is voluntary. This article separates law from benchmark, shows where Nasdaq Dubai issuers stand, and explains how the federal Climate Law GHG duty runs alongside.

Do DFM-Listed Companies Have to Report ESG?

Direct answer: Yes. Article 76 of the Corporate Governance Guide for public joint stock companies makes it mandatory. It applies to companies listed on DFM or the Abu Dhabi Securities Exchange (ADX). The report must follow Global Reporting Initiative (GRI) standards, plus any requirements the exchange sets.

Article 76 comes from SCA Decision No. 3/R.M. of 2020. The DFM guide itself cites Article 76 and restates the duty: listed companies must publish a sustainability report.

Sources: Al Tamimi and Company, Mandatory ESG Reporting for UAE Listed Companies, Dubai Financial Market, Guide to ESG Reporting 2025

One update matters for 2026 filings. The SCA became the Capital Market Authority (CMA) on 1 January 2026 under Federal Decree-Laws No. 32 and No. 33 of 2025. Cleary Gottlieb reports that existing SCA resolutions continue to apply to the extent they do not conflict with the new laws, until replaced or repealed. Article 76 therefore remains the working rule. Check the CMA website for replacement text before you file.

Source: Cleary Gottlieb, UAE Capital Markets Overhaul 2026

Who Is in Scope

• DFM-listed companies: public joint stock companies listed on DFM are bound by Article 76 directly. ADX-listed companies sit under the same article.
• Nasdaq Dubai issuers: Nasdaq Dubai is a DFM subsidiary, but the Dubai Financial Services Authority (DFSA) regulates it. Article 76 names only DFM and ADX. The DFSA material we reviewed covers green and sustainable debt listings: guidelines from 2018 and a 2024 fee waiver. We found no DFSA rule that mirrors Article 76 for equity issuers.
• DIFC and ADGM financial entities: a separate disclosure regime applies. Spectreco covers it in the DIFC and ADGM reporting guide.

Our reading: a company listed only on Nasdaq Dubai is not caught by the wording of Article 76. It should still use the DFM guide as its benchmark and confirm its own obligations with the DFSA.

Sources: DFSA, ESG listings on Nasdaq Dubai, Legal 500, UAE Capital Markets

When Is a Dubai Sustainability Report Due?

Direct answer: The deadline is 90 days from the financial year-end, or the date of the annual general assembly, whichever is earlier. A company with a 31 December year-end therefore has until about 31 March, unless its assembly falls sooner. Every financial year after 2020 runs on this clock.

For the 2020 financial year only, the SCA allowed six months.

Many boards plan to the 90-day date and forget that an early assembly moves the deadline forward. Build the reporting timetable backwards from the assembly date, not forwards from year-end.

Sources: Al Tamimi and Company, Mandatory ESG Reporting for UAE Listed Companies, Charles Russell Speechlys, ESG Reporting for Public and Listed Companies

What Is the DFM ESG Reporting Guide?

Direct answer: The DFM Guide to ESG Reporting is a voluntary guide for DFM-listed companies. The 2025 edition encourages disclosure against 32 ESG metrics and indicators, aligned with recommendations from the Sustainable Stock Exchanges (SSE) initiative and the World Federation of Exchanges (WFE).

Article 76 sets the duty. The guide sets the benchmark. It also recommends third-party assurance of ESG data and allows three formats: a section of the annual report, a standalone sustainability report, or an integrated report.

Source: Dubai Financial Market, Guide to ESG Reporting 2025

The Metric Benchmark

The guide groups its metrics under three headings:

• Environmental: GHG emissions (Scope 1, 2 and 3), emissions intensity, energy usage, energy intensity, energy mix, water and effluents, waste, environmental management, climate risks, opportunities and governance, and biodiversity.
• Social: CEO pay ratio, breakdown with staff, employee turnover and new hires, gender diversity and equality, human rights, health and safety, training and development, and community engagement.
• Governance: board diversity, board independence, collective bargaining, supply chain management, ethics and anti-corruption, data security, sustainability risks, opportunities and governance, and external assurance.

Because the guide is voluntary, leaving out one metric is not non-compliance. Missing the report, the deadline or GRI conformance is.

Source: Dubai Financial Market, Guide to ESG Reporting 2025

Which Frameworks Does DFM Recommend?

• GRI Standards: the mandatory baseline under Article 76.
• IFRS S1 and S2: issued by the International Sustainability Standards Board (ISSB). The guide says they build on the Sustainability Accounting Standards Board (SASB) standards and the Task Force on Climate-related Financial Disclosures (TCFD).
• TCFD: the climate governance, strategy, risk management and metrics structure that IFRS S2 builds on.
• Also referenced: SASB, CDP, the UN Global Compact and the EU’s Corporate Sustainability Reporting Directive (CSRD).

Our advice: build on GRI because the law names it, then layer IFRS S2 climate content on top. That keeps a DFM report ready for a shift toward ISSB-based rules without a rebuild.

Source: Dubai Financial Market, Guide to ESG Reporting 2025

How Does the Federal Climate Law GHG Obligation Sit Alongside?

Three instruments now apply to a DFM issuer, and they are not interchangeable:

• Article 76: mandatory. Covers the whole sustainability report, on GRI, within 90 days.
• DFM ESG Reporting Guide: voluntary. Sets the metric benchmark.
• Federal Decree-Law No. 11 of 2024 (Climate Law): mandatory. In force since 30 May 2025, it applies to public and private entities, free zones included, with no size threshold. Entities must measure emissions, report to the Ministry of Climate Change and Environment (MOCCAE) in approved forms and keep records for at least five years. Fines run from AED 50,000 to AED 2,000,000, doubling for a repeat violation within two years.

The 30 May 2026 compliance date needs care. Ropes and Gray reported in April 2026 that MOCCAE expected to extend it pending technical guidance. As of June 2026, Insight Advisory found no revised date confirmed. Confirm the current position with MOCCAE before relying on either date.

Here is the practical risk. The Scope 1 and 2 figure in your Article 76 report and the figure you submit to MOCCAE are now both on the record. They should reconcile. Two different totals is a problem you create, not a rule you break. This is Spectreco’s view, not a regulator’s position. Our UAE Climate Law guide covers the deadline in detail.

Sources: PwC Middle East, UAE Climate Change Law, Ropes and Gray, Preparing for New UAE GHG Emissions Reporting, Library of Congress, UAE Climate Law Takes Effect, Insight Advisory, UAE Climate Law 2026

Frequently Asked Questions

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Get DFM Reporting Ready Before the 90-Day Clock Starts

A DFM report built cleanly on GRI, the DFM metric set and IFRS S2 climate content meets today’s rule and prepares you for the next one. The Climate Law figure and the Article 76 figure should come from one dataset.

Spectreco supports Dubai-listed companies with a DFM reporting readiness review: scoping against Article 76, mapping the DFM metric set, and reconciling the GHG figure across both filings. Start with the Virtual Sustainability Office, our Compliance, Reporting and Disclosures advisory or the Spectreco sustainability platform.

Book a Spectreco DFM reporting readiness review before your next filing window.