Qatar's QCB Sustainability Reporting Framework: Banks' First IFRS S1 and S2 Reports Under the 2026 Mandate
Qatar's QCB Sustainability Reporting Framework: Banks' First IFRS S1 and S2 Reports Under the 2026 Mandate
Your FY2026 data is being recorded right now, whether or not your reporting framework is ready for it. The Qatar Central Bank (QCB) Sustainability Reporting Framework makes IFRS S1 and IFRS S2 mandatory for banks and financial institutions from 1 January 2026. The first report covers the 2026 financial year and falls due in 2027. If your data collection has not started, your first report will rest on estimates rather than auditable numbers.
The QCB built the framework on the standards issued by the International Sustainability Standards Board (ISSB): IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures). Spectreco, an ESG technology and advisory firm with offices in Atlanta, London, Lisbon, and Lahore, works with banks and insurers across the GCC on exactly this kind of first-year implementation.
This guide sets out what the QCB Sustainability Reporting Framework requires for the 2026 mandate: who is in scope, the four disclosure areas, the Scope 1, 2 and 3 emissions requirement, how the transition reliefs apply, and a first-year preparation path.
Sources: Consultancy-ME: Qatar mandates IFRS S1 and S2 for banks | The Peninsula: QCB issues Sustainability Reporting Framework
What Is the QCB Sustainability Reporting Framework?
The QCB Sustainability Reporting Framework (SRF) is Qatar Central Bank's mandatory sustainability disclosure regime for financial institutions, built on IFRS S1 and IFRS S2. QCB issued it on 4 December 2025 and implementation commenced on 1 January 2026. It is a permanent, annually recurring obligation, not a one-off pilot.
The framework sits within QCB's Third Financial Sector Strategy and its ESG and Sustainability Strategy for the Financial Sector. It applies the ISSB standards through a phased approach with transition reliefs, which recognises that financial institutions are at different stages of readiness on sustainability reporting.
Sources: Gulf Times: QCB Sustainability Reporting Framework | The Peninsula: QCB issues Sustainability Reporting Framework
Who Must Report Under the QCB SRF?
The framework applies to banks and financial institutions regulated by the Qatar Central Bank, including insurers. QCB is not acting alone. To keep Qatar's financial system consistent, two other bodies have aligned their requirements to IFRS S1 and S2: the Qatar Financial Centre Regulatory Authority (QFCRA) and the Qatar Stock Exchange (QSE).
The QFCRA route matters for firms inside the Qatar Financial Centre. Its GENE (Corporate Sustainability Reporting) Rules 2025 apply to Category A firms, the larger QFC-authorised banks and insurers, for financial years starting on or after 1 January 2026. The QFCRA can also bring other firms into scope through a written designation notice.
A single institution can therefore sit under more than one regime. A bank with both a QCB licence and QFC authorisation should treat each regulator as a separate compliance relationship rather than assume one report satisfies both.
At a glance, here is how the two regulators line up:
| Feature | QCB Sustainability Reporting Framework | QFCRA GENE Rules 2025 |
|---|---|---|
| Who it covers | Banks and financial institutions licensed by the QCB, including insurers | Category A firms: larger QFC-authorised banks and insurers, plus any firm brought in by a designation notice |
| Standards basis | IFRS S1 and IFRS S2 (ISSB) | IFRS S1 and IFRS S2 (ISSB) |
| Effective from | 1 January 2026 | Financial years starting on or after 1 January 2026 |
| First report | FY2026 data, due 2027 | FY2026 data, due 2027 |
| First-year approach | Phased adoption with transition reliefs | Transition reliefs; a group-level report may be relied on if it fully meets IFRS S1 and S2 |
For a full breakdown of the dual-regulator structure, see Spectreco's guide: Qatar IFRS S1 and S2: What Banks Must Report in 2026.
Sources: Consultancy-ME: Qatar mandates IFRS S1 and S2 for banks | QFCRA: GENE Corporate Sustainability Reporting Rules 2025
The Four Disclosure Areas the SRF Requires
The QCB SRF follows the IFRS S1 and S2 structure, so every report covers the same four areas. Each one asks a different question about how climate and sustainability sit inside the institution.
Governance
Boards must show real oversight of climate-related and sustainability-related risks and opportunities. The report needs to identify which committee owns climate accountability, how often those risks are reviewed, and how they reach senior decision-makers. Describing a policy is not enough. The disclosure has to evidence the governance that is actually in place.
Strategy
Institutions disclose how sustainability and climate-related risks and opportunities affect the business model, financial planning, and strategic direction. This is where a climate transition plan and scenario analysis belong, covering both physical risk such as heat and water scarcity and transition risk such as carbon pricing and policy change.
Risk Management
The report must explain how the institution identifies, assesses, monitors, and integrates these risks. The test the QCB is applying is integration: climate risk sits inside the enterprise risk management framework, not in a separate ESG workstream that never touches credit or capital decisions.
Metrics and Targets
Institutions disclose their performance against sustainability and climate-related targets, along with greenhouse gas (GHG) emissions. This is the area that most often exposes weak data, because targets without measured emissions behind them do not survive review.
Sources: The Peninsula: QCB issues Sustainability Reporting Framework | Gulf Times: QCB Sustainability Reporting Framework
What Scope Emissions Must Qatari Banks Disclose?
The QCB SRF requires mandatory reporting of absolute Scope 1, Scope 2 and Scope 3 greenhouse gas emissions. Scope 1 is direct emissions from owned or controlled sources. Scope 2 is indirect emissions from purchased energy. Scope 3 is all other value-chain emissions. IFRS S2 requires these to be measured using the GHG Protocol.
For a bank, Scope 3 is where the real number sits. Scope 3 Category 15, financed emissions, covers the GHG emissions tied to a bank's loans, bonds, and equity investments. According to the Partnership for Carbon Accounting Financials (PCAF), the standard-setter for measuring financed emissions, these account for over 95% of most banks' total carbon footprint.
That single fact reshapes the work. A Qatari bank's largest emissions line is not its offices or its fleet. It is the carbon financed through its lending and investment book, which takes portfolio data, counterparty data, and a recognised methodology to measure.
Sources: Consultancy-ME: Qatar mandates IFRS S1 and S2 for banks | IFRS Foundation: IFRS S2 GHG educational material | EY: What you need to know about IFRS S2
How the Transition Reliefs Apply in the First Reporting Year
The QCB adopted a phased approach with transition reliefs, so the first report is not held to the full standard on day one. The reliefs are the ones built into IFRS S1 and S2 for a first annual reporting period. They ease the timing and the scope of what has to appear in year one, and they fall away afterwards.
The reliefs that matter most for a first QCB SRF report:
| Relief | What it covers | When it applies |
|---|---|---|
| Climate first | Report only IFRS S2 climate disclosures and defer the broader IFRS S1 sustainability disclosures | First reporting year only |
| Report timing | Publish sustainability disclosures at the same time as, or after, the annual financial statements | First reporting year only |
| Scope 3 relief | No requirement to disclose Scope 3 GHG emissions, giving banks room to build financed-emissions data | First reporting year only |
| No comparatives | No prior-period comparative figures required | First reporting year only |
Read these as breathing room, not an exemption. Scope 3 measurement still has to start now so that year-two disclosure is auditable rather than a rushed estimate.
Sources: EY: What you need to know about IFRS S2 | The Peninsula: QCB issues Sustainability Reporting Framework
How to Prepare for Your First QCB SRF Report
The following steps apply whether your institution reports to the QCB, the QFCRA, or both. Each one maps to a disclosure the SRF will expect.
- Confirm your regulatory scope. Establish whether you are QCB-regulated, a QFCRA Category A firm, or both, and check whether a QFCRA designation notice applies. Do not assume a single regulator.
- Document board governance. Record which committee owns climate risk, how often it meets on the topic, and how climate reaches the board. The report must evidence governance, not describe it.
- Activate Scope 1 and Scope 2 data collection. Start measuring now. Waiting until the report is due means your first numbers are estimates rather than auditable data.
- Scope your financed emissions. Map your loan, bond, and investment portfolio to the PCAF methodology so Scope 3 Category 15 is ready when the first-year relief ends.
- Run climate scenario analysis. Cover both physical risk and transition risk, and connect the results to your strategy and financial planning as IFRS S2 requires.
- Build for assurance from day one. Keep source documentation, audit trails, and data validation in place so your disclosures hold up when assurance requirements tighten.
The Spectreco Platform automates IFRS S1 and S2 data collection, financed-emissions measurement, scenario analysis, and report production for financial institutions.
Sources: IFRS Foundation: IFRS S2 GHG educational material | QFCRA: GENE Corporate Sustainability Reporting Rules 2025
Frequently Asked Questions
Get Your QCB SRF Reporting Right From Year One
The institutions that will struggle with the QCB Sustainability Reporting Framework are the ones that start building data infrastructure in 2027, when the first report is due. The ones that will be ready treated 2026 as a live reporting year from 1 January.
Spectreco maps regulatory scope across the QCB, QFCRA, and QSE, designs the governance and risk structures the SRF expects, and measures financed emissions to the PCAF standard.
Map your Qatar QCB SRF readiness now. Book a Qatar QCB SRF readiness assessment with Spectreco to confirm your scope under each regulator, see what you have against what the framework requires, and get a prioritised first-year plan. Banks operating across the GCC should also review Spectreco's guide to the UAE ESG compliance deadline, because a Qatar IFRS S2 report does not satisfy the UAE Climate Law.
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