SCA Mandatory Sustainability Reports for ADX-Listed Companies: Article 76 and the 90-Day Clock

The Sustainability Report Is a Filing Obligation for ADX Issuers, Not a Nicety

Most Abu Dhabi boards treat the sustainability report as an investor-relations nicety. It is a filing obligation with a hard deadline. Under Article 76 of the Securities and Commodities Authority (SCA) Corporate Governance Guide, every public joint stock company listed on the Abu Dhabi Securities Exchange (ADX) must publish an annual sustainability report, and the clock starts the day the financial year closes.

Spectreco, a US-headquartered sustainability technology and advisory firm that works with issuers across the GCC, sees the same gap repeatedly. Companies know the UAE has climate rules. They do not always know which rule applies to them, who they file with, or when. This article covers the SCA Article 76 duty for ADX issuers: who is in scope, the 90-day deadline, what must be disclosed, the recommended frameworks, and how it differs from the separate greenhouse gas duty under the UAE Climate Law.

Sources: Charles Russell Speechlys  |  Greenplaces: SCA Decision 3/RM/2020

In this article

• Whether UAE-listed companies have to publish a sustainability report

• What SCA Article 76 is and where it comes from

• When the report is due under the 90-day clock

• What ADX issuers must disclose and which frameworks apply

• How Article 76 differs from the UAE Climate Law GHG duty

• How to prepare for the Article 76 report

• FAQ

Do UAE-Listed Companies Have to Publish a Sustainability Report?

Yes. Under Article 76 of the SCA Corporate Governance Guide, all public joint stock companies listed on the Abu Dhabi Securities Exchange or the Dubai Financial Market must publish an annual sustainability report. It is a mandatory listing obligation, not a voluntary disclosure.

The requirement applies uniformly across both exchanges, including dual-listed foreign issuers. For an ADX issuer, the sustainability report sits alongside the annual financial statements as a standing regulatory filing.

Sources: Greenplaces: SCA Decision 3/RM/2020  |  DMCC

What Is SCA Article 76?

Article 76 is the sustainability-reporting article of the SCA Corporate Governance Guide, issued under the Chairman of the SCA Board of Directors’ Decision No. 3/R.M of 2020. The Securities and Commodities Authority is the federal regulator for the UAE’s onshore capital markets, which include ADX and DFM.

The decision made the annual sustainability report a governance requirement for listed PJSCs across the federal market. It is the single federal rule that both Abu Dhabi and Dubai issuers answer to, even though each exchange publishes its own implementation guidance beneath it.

A Federal Rule, With Exchange-Level Guidance

ADX issuers follow the SCA duty, supported by the exchange’s own ESG disclosure guidance. Dubai-listed issuers answer to the same Article 76 and follow the DFM ESG Reporting Guide as their metric benchmark, covered in our companion piece on Dubai’s DFM ESG Reporting Guide.

The practical point for an Abu Dhabi board is that the obligation is set at federal level. Delisting the report as “nice to have” is not an option an ADX issuer has.

Source: Charles Russell Speechlys

When Is the Report Due? The 90-Day Clock

An ADX issuer must submit its sustainability report within 90 days of the financial year-end, or before the annual general assembly meeting, whichever is earlier. For a company with a 31 December year-end, that points to a filing window closing around the end of March.

The “whichever is earlier” wording matters. A company that calls its annual general assembly early does not get the full 90 days. The assembly date can pull the deadline forward, so the report has to be ready when the governance calendar demands it, not when the quarter happens to end.

When the rule first took effect, entities already listed in 2020 were given six months to file their first report for the 2020 financial year. That transitional window is long closed. Every ADX issuer now works to the standing 90-day-or-AGM clock each year.

Sources: Prima Consulting  |  DMCC

What ADX Issuers Must Disclose

The sustainability report is expected to combine a narrative on ESG strategy and governance with quantitative performance metrics and a materiality assessment. It is not a marketing brochure. Regulators and investors read it for data they can compare year over year.

The Core Disclosure Areas

• Environmental: energy consumption, greenhouse gas emissions, water use, and waste management.

• Social: workforce diversity, employee engagement, labour standards, and human rights.

• Governance: board composition and independence, executive remuneration, audit structure, and anti-corruption controls.

• Materiality: an assessment of which ESG issues are most relevant to the business and its stakeholders.

Which Frameworks the SCA Recommends

The baseline is the Global Reporting Initiative (GRI), the international standard for sustainability reporting that most listed UAE issuers use as their reference. ADX guidance points issuers toward internationally recognised standards, with GRI as the anchor and the Task Force on Climate-related Financial Disclosures (TCFD) and the ISSB’s IFRS Sustainability Disclosure Standards increasingly referenced as the direction of travel for climate content.

ADX’s own ESG disclosure guidance set out 31 ESG metrics drawn from GRI and the work of the Sustainable Stock Exchanges initiative and the World Federation of Exchanges. Dubai’s DFM guide sits in the same family with its own benchmark metric set. The exchanges differ on the detail, but the federal duty and the GRI anchor are shared.

Sources: IR Magazine  |  Greenplaces: SCA Decision 3/RM/2020

SCA Article 76 vs the UAE Climate Law: Two Different Duties

This is where issuers get caught out. The SCA sustainability report and the UAE Climate Law greenhouse gas duty are two separate obligations, owed to two different regulators. Being listed does not cover you for the climate law, and reporting emissions to the climate ministry does not satisfy the SCA.

Article 76 is a disclosure duty triggered by being listed. You file an ESG report with the SCA framework, built on GRI, within the 90-day-or-AGM window. The UAE Climate Law, Federal Decree-Law No. 11 of 2024 on the Reduction of Climate Change Effects, is an operational duty triggered by emitting. It came into force on 30 May 2025, with the full reporting obligation applying from 30 May 2026.

The climate law requires measuring emissions, keeping an inventory for at least five years, and filing periodic reports with MOCCAE. We cover that duty in detail in what the 30 May 2026 UAE Climate Law deadline means.

An ADX-listed industrial or energy company can owe both. The emissions numbers it measures for MOCCAE become evidence inside the sustainability report it files under Article 76. Treating them as one data exercise, two filings, is the efficient read.

Sources: PwC Middle East  |  DMCC

How to Prepare for the Article 76 Report

1. Confirm your clock. Fix the filing deadline against both your financial year-end plus 90 days and your annual general assembly date, then work to the earlier of the two.
2. Pick your framework and lock the metric set. Anchor on GRI, map the ADX ESG metrics, and decide how far to align with TCFD and IFRS S2 climate content this cycle.
3. Build the emissions baseline once. Measure Scope 1 and Scope 2 to a standard that serves both the sustainability report and the Climate Law inventory, rather than running two parallel exercises. A cloud-native ESG platform keeps one dataset feeding both filings.
4. Run a materiality assessment. Document which ESG issues matter to the business and stakeholders, so the report leads with substance, not boilerplate.
5. Close the capacity gap. Where internal teams are thin, a Virtual Sustainability Office can run the reporting cycle end to end against the SCA calendar.

Frequently Asked Questions (FAQs)

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The Bottom Line

For an ADX issuer, the sustainability report is a fixed annual filing with a moving deadline. Anchor it on GRI, read the ADX guidance, and build it on emissions data that also answers the UAE Climate Law. The companies that treat these as one data programme with two filings spend less and defend their numbers better.

Spectreco helps ADX-listed companies get their Article 76 sustainability report ready against the SCA calendar. Book an SCA reporting readiness assessment with our Compliance, Reporting and Disclosures team before your next filing window opens.

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