DFM and ADX ESG Reporting Requirements for Listed Companies

Companies seeking a controlled ESG reporting process for listed companies should connect the reporting timetable, market metrics and framework requirements through one coordinated annual reporting programme.

Key Takeaways

• Sustainability reporting forms part of the annual reporting responsibilities of UAE-listed public joint-stock companies. 
• DFM’s 2025 guide encourages disclosure against 32 ESG metrics and indicators. 
• ADX states that listed companies follow mandatory sustainability reporting and provides guidance through 31 essential ESG indicators. 
• ESG information should be supported by evidence, calculation methodologies and internal review controls. 
• Material disclosures should remain consistent with the financial statements, governance report and approved corporate strategy. 
• Listed companies should start collecting ESG data several months before the financial year closes. 

Are ESG Reports Mandatory for DFM- and ADX-Listed Companies?

The Capital Market Authority’s circular for the 2025 reporting year requires the integrated report to include the board report, auditor’s report, annual financial statements, governance report and sustainability report. The company must comply with the sustainability-reporting requirements issued by the UAE financial market on which it is listed. 

The integrated report must be disclosed on the company’s website and the relevant financial market’s website within the first three months of the financial year and at least ten days before the annual general meeting, whichever occurs earlier. The CMA circular allows the component reports to be published together in one integrated document without preventing their separate disclosure. 

Mandatory Reporting vs Voluntary Guidance

The distinction between the reporting obligation and the exchange guides is important.

DFM describes its 2025 ESG Reporting Guide as voluntary guidance, but the guide also refers to mandated ESG data reporting for DFM- and ADX-listed companies. It encourages issuers to evaluate and report their performance against 32 ESG metrics aligned with international exchange initiatives and reporting frameworks. 

ADX’s 2025 ESG Disclosure Guidance is also described as voluntary. However, it expressly states that it complements the UAE regulatory framework containing sustainability disclosure requirements for listed companies. ADX’s current sustainability overview separately states that its listed companies follow mandatory sustainability reporting and that it provides guidance through 31 essential ESG indicators. 

Listed companies should therefore treat the guides as implementation tools while assessing compliance against the CMA framework and any current instructions, templates or circulars issued by the relevant exchange.

DFM vs ADX ESG Reporting at a Glance

ADX also publishes a separate unified GCC metrics page referring to 29 standards issued by the GCC Exchanges Committee. This is distinct from the 31 indicators highlighted on ADX’s current sustainability overview. Companies should use the latest reporting instructions and metric template issued for their reporting period rather than relying on one historic indicator count. 

1. Prepare a Regulatory and Reporting Requirements Register

The company should begin by documenting every requirement that may affect its ESG report. The register should cover:

• CMA integrated-reporting requirements. 
• Current DFM or ADX instructions. 
• Corporate-governance disclosures. 
• Sector-regulator requirements. 
• IFRS S1 and IFRS S2 where adopted or voluntarily applied. 
• GRI requirements where GRI alignment is claimed. 
• Group-level or overseas listing requirements. 
• Investor, lender and ESG-rating requests. 

Each item should be classified as mandatory, exchange-guided, framework-based or voluntary. The register should also assign an owner, evidence source and completion deadline.

This prevents two common problems: treating every suggested indicator as legally mandatory and overlooking a required disclosure because it does not appear in the selected international framework.

2. Establish ESG Governance Before Drafting

A listed company should clearly define who is responsible for sustainability matters and public ESG information. The governance framework should identify:

• Board or committee oversight. 
• Executive management responsibility. 
• ESG-report ownership. 
• Responsibilities of finance, risk, HR, operations and compliance. 
• Data-review and escalation procedures. 
• Authority to approve targets and public claims. 
• Internal audit involvement. 
• Final board-review arrangements. 

ADX’s guidance asks companies to explain the governance body or individuals responsible for sustainability-related risks and opportunities, how oversight is exercised and whether ESG performance is connected with remuneration. 

Companies without a clear governance structure should consider developing an ESG strategy and governance framework before starting the annual report. This creates defined priorities, responsibilities, targets and management processes against which performance can be reported.

3. Define the Reporting Boundary

The reporting boundary determines which entities, facilities and activities appear in the report. It should address:

• Parent company and subsidiaries. 
• Overseas operations. 
• Joint ventures and associates. 
• Recently acquired or disposed of entities. 
• Leased and managed assets. 
• Franchises. 
• Construction projects. 
• Outsourced operations. 
• Material upstream and downstream activities. 

The ESG reporting boundary should be compared with the consolidated financial statements. Differences may be technically appropriate, particularly for greenhouse gas accounting, but they should be explained.

For example, a listed property group may consolidate several subsidiaries financially while applying an operational-control approach to determine which buildings enter its emissions inventory. Changes in acquisitions, disposals or control should also be considered when preparing comparative data.

4. Complete a Materiality Assessment

Materiality determines which ESG issues require the greatest attention in the report.

Both the DFM and ADX guides place materiality within the reporting process. DFM describes a five-stage roadmap covering planning, stakeholder engagement and materiality, data collection, report development and optional assurance. ADX similarly recommends selecting a reporting framework, defining boundaries, engaging stakeholders, assessing material topics and collecting factual quantitative information. 

Material topics will vary by industry:

The final material topics should be approved by senior management or the appropriate governance body and linked with strategy, risk management and measurable KPIs.

5. Prepare Environmental and Climate Disclosures

The environmental dataset may include:

• Scope 1 greenhouse gas emissions. 
• Scope 2 greenhouse gas emissions. 
• Material Scope 3 emissions. 
• Electricity and fuel consumption. 
• Renewable electricity procurement. 
• Energy intensity. 
• Water consumption. 
• Waste generation and diversion. 
• Refrigerant leakage. 
• Environmental incidents. 
• Climate-related risks and opportunities. 
• Emissions-reduction targets and progress. 

ADX’s current guidance includes climate strategy, climate-related risks and opportunities, energy intensity, targets and governance over climate matters. It also asks companies to explain how sustainability-related risks affect their business models, value chains and prospects. 

Emissions measurement should support more than annual disclosure. A structured Climate Risk & Decarbonization Strategy can help management connect the carbon baseline with physical and transition risks, scenario analysis, operational investment and measurable reduction actions.

Renewable Electricity Claims

Where a listed company reports renewable electricity use, the disclosure should be supported by consumption records, certificate details, beneficiary information and formal redemption evidence.

IFRSLAB’s I-REC Services can support the procurement and retirement of energy attribute certificates for relevant market-based Scope 2 claims. The report should distinguish certificate-backed electricity claims from actual reductions in electricity consumption.

6. Prepare Social and Workforce Information

Social information should be collected through controlled coordination between HR, health and safety, procurement, legal and operations. Relevant metrics may include:

• Total workforce and employment type. 
• Gender representation. 
• Board and management diversity. 
• Emiratisation. 
• Employee turnover. 
• Training hours. 
• Occupational injuries. 
• Lost-time incidents. 
• Employee wellbeing. 
• Human rights and worker welfare. 
• Supplier screening. 
• Community investment. 
• Customer complaints. 

Definitions should remain consistent across subsidiaries and reporting years. A company should explain whether temporary workers, contractors and outsourced personnel are included.

It should also distinguish activities from outcomes. Reporting the number of training sessions does not show the percentage of employees trained, learning outcomes or whether the programme addressed a material risk.

7. Align Governance and Ethics Disclosures

Governance information should remain consistent with the company’s formal governance report and market disclosures. The ESG report may address:

• Board independence. 
• Committee responsibilities. 
• Board diversity. 
• Ethics and anti-bribery controls. 
• Whistleblowing arrangements. 
• Confirmed corruption cases. 
• Regulatory breaches. 
• Cybersecurity oversight. 
• Data privacy incidents. 
• ESG-linked remuneration. 
• Sustainability policies and targets. 

ADX’s guidance includes indicators covering board oversight, sustainability strategy, disclosure practices and external assurance. 

Companies should verify that reported governance information agrees with board-secretariat records, approved policies, committee terms and other public disclosures.

8. Build Evidence and Internal Controls

A listed-company ESG report should operate within a controlled reporting environment.

DFM recommends integrating ESG data collection into existing internal processes and subjecting it to internal-audit oversight. It also calls for disclosure of relevant assumptions, limitations and uncertainties. 

Several indicators originate in financial systems. Energy expenses, payroll, supplier payments, capital expenditure and provisions should be reconciled with reported physical information. A controlled Accounting and Bookkeeping process can strengthen traceability between ESG disclosures and the underlying financial records.

Should ESG Information Be Externally Assured?

External assurance is not presented in the DFM and ADX guides as universally compulsory for every ESG disclosure. However, both exchanges recognise verification as an important credibility mechanism.

DFM encourages listed companies to seek external assurance and describes assurance as the optional fifth stage of its reporting roadmap. ADX asks companies to state whether their sustainability information has been verified and to identify the KPIs covered. 

Priority areas may include:

• Scope 1, Scope 2 and Scope 3 emissions. 
• Energy and water consumption. 
• Safety performance. 
• Sustainable-finance KPIs. 
• Renewable electricity claims. 
• ESG-linked remuneration measures. 

Companies preparing for verification should establish an ESG Linked Financial Assurance process covering KPI definitions, evidence files, calculation controls and consistency with financial reporting.

Recommended Reporting Timeline

The timetable should be integrated with the financial-close, annual-report and AGM process rather than operated as a separate communications project.

Listed-Company ESG Readiness Checklist

Regulatory and Framework Readiness

• Confirm current CMA, DFM or ADX instructions. 
• Identify sector-regulator requirements. 
• Obtain the latest exchange metrics and templates. 
• Confirm the disclosure and AGM timetable. 
• Select and document the reporting framework. 

Governance and Materiality

• Assign board or committee oversight. 
• Appoint an executive report owner. 
• Define departmental responsibilities. 
• Complete or update the materiality assessment. 
• Obtain approval for material topics and targets. 

Data and Methodology

• Define the reporting boundary. 
• Calculate Scope 1 and Scope 2 emissions. 
• Screen material Scope 3 categories. 
• Collect social and governance indicators. 
• Document calculation methods and definitions. 
• Prepare comparative data. 
• Investigate material year-on-year changes. 

Controls and Publication

• Assign an owner and reviewer to every KPI. 
• Retain supporting records. 
• Reconcile ESG data with financial and operational records. 
• Complete internal audit and management review. 
• Assess external-assurance readiness. 
• Confirm consistency with financial statements and governance disclosures. 
• Obtain final board approval. 
• Publish through the required company and market channels. 

IFRSLAB Expert Commentary

“For a listed company, ESG reporting belongs within the controlled annual reporting environment. The process must connect market indicators, materiality, governance, financial information and operational evidence. The most serious reporting weaknesses are normally unsupported metrics, inconsistent boundaries and public commitments that cannot be traced to approved strategies or reliable data.” — Layla Hassan, Senior ESG Reporting Consultant at IFRSLAB

How IFRSLAB Supports DFM and ADX ESG Reporting

IFRSLAB supports listed companies in establishing an ESG reporting process that responds to UAE capital-market requirements while remaining aligned with appropriate international standards. The engagement begins with an applicability and readiness assessment covering the listing market, sector obligations, reporting framework, current disclosures and annual reporting timetable.

The reporting programme is then structured around governance, materiality and controlled data collection. IFRSLAB works with finance, risk, internal audit, HR, operations, procurement, compliance and the board secretariat to define KPI methodologies, assign data ownership and establish supporting evidence. Environmental work may include greenhouse gas measurement, climate-risk disclosures, energy information and decarbonization targets, while social and governance disclosures are reconciled with company policies and formal records.

The final drafting process includes technical review, framework mapping and consistency checks against the financial statements, governance report and approved corporate commitments. Where independent assurance is planned, the evidence base and reporting controls are developed early enough to support an efficient and technically defensible review.

Discuss DFM or ADX ESG reporting readiness with IFRSLAB.

Author Details

Layla Hassan

Senior ESG Reporting Consultant, IFRSLAB

Layla advises listed and regulated organisations on ESG reporting, materiality, sustainability governance, disclosure controls and alignment with UAE capital-market requirements. Her work focuses on integrating sustainability information into technically controlled annual reporting processes.

References

• UAE Capital Market Authority — Circular on Annual General Meetings of Public Joint-Stock Companies for 2025. 
• Dubai Financial Market — Guide to ESG Reporting 2025. 
• Abu Dhabi Securities Exchange — ESG Disclosure Guidance for Listed Companies, June 2025. 
• Abu Dhabi Securities Exchange — Sustainability Overview and ESG Metrics.