Qatar IFRS S1 and S2: What Banks Must Report in 2026
Qatar IFRS S1 and S2: What Banks and Financial Institutions Must Report in 2026
Your FY2026 data is being collected right now. By the time you finalise your annual financial statements in 2027, your sustainability report needs to be ready alongside them. If you have not yet confirmed which regulator governs your institution or whether two do, you are already behind.
Qatar is the first country in the GCC to formally mandate the International Sustainability Standards Board (ISSB) standards through two separate regulatory channels simultaneously. The Qatar Central Bank (QCB) governs all banks and insurance firms licensed in Qatar. The Qatar Financial Centre Regulatory Authority (QFCRA) governs QFC-authorised firms. A bank with both a QCB licence and QFC authorisation is subject to both.
This article sets out exactly what each regulator requires under IFRS S1 (General Requirements for Sustainability-related Disclosures) and IFRS S2 (Climate-related Disclosures), who falls within scope, and what your compliance calendar looks like for the FY2026 reporting cycle.
Source: IFRS S1 General Requirements (ISSB, June 2023) | IFRS S2 Climate-related Disclosures (ISSB, June 2023)
Qatar's Dual Regulator Structure: QCB and QFCRA
The Qatar Central Bank Sustainability Reporting Framework
On 4 December 2025, the Qatar Central Bank (QCB) issued its Sustainability Reporting Framework (SRF) for financial institutions, built on IFRS S1 and IFRS S2 as published by the ISSB in June 2023. The SRF is mandatory for all banks and insurance companies licensed by the QCB.
Source: QCB Sustainability Reporting Framework | Gulf Times — QCB Sustainability Reporting Framework
Implementation commenced on 1 January 2026. The first sustainability report, covering FY2026 data, is due for submission in 2027. The QCB confirmed a phased approach with transitional relief measures. This is not a one-year pilot. It is a permanent annually recurring regulatory obligation.
Source: QCB Sustainability Reporting Framework | HLB AG — QCB ESG Rules in Qatar
The QFCRA GENE Corporate Sustainability Reporting Rules 2025
On 26 June 2025, the Qatar Financial Centre Regulatory Authority (QFCRA) issued its GENE (Corporate Sustainability Reporting) and Minor and Technical Amendments Rules 2025, alongside guidance titled "How to start the journey in applying the ISSB Standards".
Source: QFCRA GENE Rules 2025 | QFCRA Corporate Sustainability Reporting Guidance
The GENE Rules apply to Category A firms, large QFC-authorised banks and insurers, and to any other QFC-authorised firm designated by written notice. Financial years starting on or after 1 January 2026 are in scope, with first reports due in 2027, aligned with the QCB calendar.
Source: QFCRA GENE Rules 2025 | Lexis Middle East — QFCRA Category A & CSR Rules
Who Does Each Regulator Govern?
- QCB-regulated: All banks and insurance companies licensed in Qatar outside the Qatar Financial Centre.
- QFCRA-regulated: QFC-authorised firms incorporated within the Qatar Financial Centre banks, insurers, investment managers, and asset managers.
- Dual-regulated: A bank holding both a QCB licence and QFC authorisation may face obligations under both frameworks simultaneously.
Source: QCB Sustainability Reporting Framework | QFCRA GENE Rules 2025
According to Pinsent Masons' analysis of the QFCRA Rules, QFC branches and subsidiaries of international groups should examine whether group-level sustainability reports satisfy local QFC-specific disclosure requirements before assuming automatic compliance.
Source: Pinsent Masons — Qatar QFC sustainability reporting rules
What Does IFRS S2 Require Qatar Banks to Disclose?
Short answer: IFRS S2 requires disclosures across four pillars, governance, strategy, risk management, and metrics and targets, including Scope 1, 2, and 3 GHG emissions. Both the QCB and QFCRA mandate all four. First reports cover FY2026 data and are due in 2027. Transitional relief applies to certain GHG disclosures in the first two years.
Source: IFRS S2 Climate-related Disclosures (ISSB, June 2023) | QCB Sustainability Reporting Framework | QFCRA GENE Rules 2025
Governance
Boards must demonstrate active oversight of climate-related risks and opportunities. Institutions must identify which committee holds climate accountability, how frequently climate risks are reviewed, and how sustainability considerations reach senior decision-makers. The QCB requires evidence of these structures in every submitted sustainability report.
Source: IFRS S2 Climate-related Disclosures (ISSB, June 2023) | QCB Sustainability Reporting Framework
Strategy
Institutions must disclose how climate risks and opportunities affect their business model, financial planning, and strategic direction. This includes a climate transition plan: a documented pathway toward a low-carbon economy aligned with Qatar's national climate targets. Scenario analysis is required, covering both physical risk (flood, heat, water scarcity) and transition risk (carbon pricing, policy change, stranded assets) scenarios.
Source: IFRS S2 Climate-related Disclosures (ISSB, June 2023) | QCB Sustainability Reporting Framework
Risk Management
Climate risk must be integrated into the institution's enterprise risk management framework not handled as a separate ESG workstream. Institutions must document the processes used to identify, assess, and prioritise climate-related risks. The QCB specifically flags greenwashing prevention as part of this obligation.
Source: IFRS S2 Climate-related Disclosures (ISSB, June 2023) | QCB Sustainability Reporting Framework
Metrics and Targets
Under IFRS S2, institutions must disclose Scope 1 (direct), Scope 2 (purchased energy), and Scope 3 (value chain) GHG emissions. For banks, Scope 3 Category 15, financed emissions, is the most material disclosure. Financed emissions are the GHG emissions associated with a bank's loans, bonds, and equity investments. According to the Partnership for Carbon Accounting Financials (PCAF), financed emissions account for over 95% of most banks' total carbon footprint.
Source: IFRS S2 Climate-related Disclosures (ISSB, June 2023) | PCAF Global GHG Standard for Financial Institutions
The QCB's SRF grants an extended two-year transitional relief specifically for GHG emissions disclosures. This is a phased relief, not an exemption. Measurement should begin now.
Source: QCB Sustainability Reporting Framework
Category A Firms Under QFCRA: Scope, Designation, and Group Reporting
What Is a Category A Firm?
Category A firms are larger QFC-authorised firms incorporated within the Qatar Financial Centre, primarily large banks and insurers. All Category A firms must prepare and publish annual sustainability reports aligned with IFRS S1 and S2 for financial years starting from 1 January 2026.
Source: QFCRA GENE Rules 2025 | Lexis Middle East — QFCRA Category A & CSR Rules
The Designation Mechanism
The QFCRA Rules include a designation mechanism that extends reporting obligations beyond Category A. The Regulatory Authority may designate any QFC-authorised firm by written notice, based on:
- The size of the firm
- The amount and nature of assets and assets under management
- The firm's client base and market significance
- Whether the firm is already preparing voluntary sustainability reports
Source: QFCRA GENE Rules 2025
No firm should assume it is safe from designation simply because it is not automatically Category A.
Group Reporting and QFC Branches
Under QFCRA Rule 9A.1.4, QFC branches and subsidiaries forming part of a wider corporate group may rely on a group-level sustainability report, provided it satisfies the substantive disclosure requirements of IFRS S1 and IFRS S2 in full. QFC-specific materiality and disclosure completeness must be confirmed. A report prepared for a parent entity in another jurisdiction does not automatically satisfy Qatar local requirements.
Source: QFCRA GENE Rules 2025 | Pinsent Masons — Qatar QFC sustainability reporting rules
Are QCB and QFCRA Requirements Identical?
Both frameworks mandate IFRS S1 and IFRS S2 in full across the four pillars of governance, strategy, risk management, and metrics and targets. Both apply from 1 January 2026 with first reports due in 2027. The underlying standards are substantively the same.
Source: QCB Sustainability Reporting Framework | QFCRA GENE Rules 2025 | SustainGulf — Corporate Sustainability Reporting in the Gulf
The differences lie in regulatory architecture. The QCB applies its SRF through its supervisory relationship with QCB-licensed institutions. The QFCRA operates under the QFC's distinct legal framework with its own rulebook, designation mechanism, and firm classification system. A bank subject to both must treat each regulator as a separate compliance relationship, not assume one report satisfies both without verification.
Source: Pinsent Masons — Qatar QFC sustainability reporting rules | Lexis Middle East — QFCRA Category A & CSR Rules
Qatar IFRS S2 Compliance Calendar: FY2026
Multi-GCC Operators: Qatar IFRS S2 and the UAE Climate Law
Banks operating across the GCC face parallel regulatory obligations that do not automatically satisfy each other. Qatar mandates IFRS S1 and S2 through the QCB and QFCRA. The UAE Climate Law (Federal Decree-Law No. 11 of 2024) mandates GHG reporting under the Ministry of Climate Change and Environment's own MRV methodology, a separate system from ISSB, with different data inputs and submission infrastructure.
A Qatar bank that is IFRS S2 compliant is not automatically UAE Climate Law compliant. For multi-GCC operators, conflating these obligations creates compliance gaps in both markets.
For a full breakdown of what the UAE Climate Law requires, see Spectreco's guide: UAE ESG Compliance: What the 30 May 2026 Deadline Means for GCC Businesses.
The GCC sustainable finance market adds a capital markets dimension. According to S&P Global, the GCC is on track for USD 20-25 billion in sustainable bond issuance in 2026. For Qatari banks with green sukuk programmes or sustainable bond aspirations, credible IFRS S2 disclosures are increasingly a prerequisite for institutional investor confidence.
Source: S&P Global — GCC sustainable bond issuance 2026
How to Prepare Your Bank for Qatar IFRS S1 and S2 Reporting
The following six steps apply whether your institution is QCB-regulated, QFCRA Category A, or both. Each step maps to a specific IFRS S1 or S2 disclosure requirement.
- Confirm your regulatory scope. Establish whether your institution is QCB-licensed, QFC Category A, or both. Confirm Category A status and check whether a designation notice has been issued. Do not assume only one regulator applies.
- Document board governance. IFRS S2 requires demonstrable board-level oversight of climate risk. Record which committee holds this mandate, meeting frequency, and how climate topics reach the board. This is evidence-based: the report must demonstrate governance, not just describe it.
- Activate Scope 1 and Scope 2 data collection. The QCB's extended transitional relief covers GHG disclosures, but measurement must begin now. Waiting until 2027 to start data collection means your first report will be based on estimates, not auditable data.
- Assess financed emissions exposure. For banks, Scope 3 Category 15 (financed emissions) is the most material GHG obligation. The PCAF Standard is the recognised methodology for measuring financed emissions across loans, bonds, and equity portfolios.
- Complete climate scenario analysis. IFRS S2 requires analysis of how different climate scenarios affect your financial position. Both physical risk (flood, heat, water scarcity) and transition risk (carbon pricing, policy change, stranded assets) scenarios must be covered.
- Structure for assurance. The QCB has indicated it will develop an assurance framework for sustainability information. Build your reporting with assurance-readiness from the first cycle: source documentation, audit trails, and data validation processes in place before your first submission.
Source: IFRS S2 Climate-related Disclosures (ISSB, June 2023) | QCB Sustainability Reporting Framework | PCAF Global GHG Standard for Financial Institutions
Confirm Your Qatar ESG Compliance Position Before Q3 2026
The institutions that will struggle with Qatar IFRS S2 are the ones that start building data infrastructure in 2027, when the first report is due. The ones that are ready treated FY2026 as a live reporting year from 1 January.
Spectreco is an ESG technology and advisory firm with offices in Atlanta, London, Lisbon, and Lahore. We work with banks, insurers, and QFC-authorised financial institutions across the GCC on IFRS S1 and S2 implementation from regulatory scope mapping and governance design through financed emissions measurement, scenario analysis, and report production.
Map your Qatar IFRS S2 gaps now. Book a Qatar ESG compliance assessment with Spectreco. We will confirm your regulatory scope under both QCB and QFCRA, identify what you currently have versus what you need, and give you a prioritised implementation plan.
See how the Spectreco Platform automates IFRS S1 and S2 data collection, scenario analysis, and report production purpose-built for financial institutions.
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