A Saudi company asked about its ESG reporting obligations will find that, for listed shares, there is no legal requirement to report. That is accurate, and it is also an incomplete answer. Investors, lenders, index providers, and the Saudi Exchange itself have built a set of voluntary expectations that a growing number of companies now meet, and the frameworks behind them are specific. Understanding which document says what is the first step to reporting credibly.
The Saudi Exchange ESG Disclosure Guidelines
The Saudi Exchange, known as Tadawul, published its ESG Disclosure Guidelines on 28 October 2021. They encourage listed companies to disclose voluntarily, and they were developed in line with the model guidance of the UN Sustainable Stock Exchanges initiative, which the Saudi Exchange joined as a partner exchange in 2018.
The guidelines are a framework for thinking about ESG, not a reporting template. They do not set a numbered list of KPIs. Instead they group the issues a company should consider into ten themes, four environmental, four social, and two governance, each broken down into key issues. For the reporting itself, they point companies to established international frameworks, including the Global Reporting Initiative (GRI), the Sustainability Accounting Standards Board (SASB) standards, the Task Force on Climate-related Financial Disclosures (TCFD), CDP, and the UN Global Compact.
In practice this means the guidelines tell a company what to think about, and a recognised framework tells it how to report. A company that follows the guidelines without choosing a framework ends up with disclosures that are hard for investors to compare.
The 29 GCC metrics are a separate document
A figure that appears in discussions of Saudi ESG reporting is 29 metrics. Those do not come from the 2021 Tadawul guidelines. They come from the unified ESG disclosure metrics published by the GCC Exchanges Committee, which the Saudi Exchange chairs, on 9 January 2023. The set contains 29 metrics, 10 environmental, 10 social, and 9 governance, aligned with the World Federation of Exchanges and the UN Sustainable Stock Exchanges initiative.
The GCC metrics are also voluntary, and they do not replace each exchange’s own guidelines. Their value is comparability: a group listed or operating across several GCC markets can report one consistent set of core metrics, which is useful for a Bahrain or UAE group with a Saudi listing or subsidiary.
How many companies report
Voluntary does not mean rare. According to figures from the Capital Market Authority and the Saudi Exchange, 94 listed companies disclosed sustainability practices in 2024, up from 81 in 2023, and 65% of the top 100 Main Market issuers disclosed, up from 58%. Among the largest listed companies, not reporting is now the minority position.
What the Capital Market Authority requires
The Capital Market Authority (CMA) has not made ESG or sustainability disclosure mandatory for listed equity issuers. The Corporate Governance Regulations include a guiding provision on a company’s social responsibility policy, but guiding provisions are not binding in the way mandatory articles are.
The firmer requirements sit in sustainable finance. The CMA’s Guidelines for Issuing Green, Social, Sustainable, and Sustainability-Linked Debt Instruments took effect on 27 May 2025. They are guiding in nature, but an issuer of a Saudi riyal-denominated instrument offered in the Kingdom, whether publicly or by private placement, must disclose any non-compliance with the guidelines in its framework or offering documents. For a company planning a green sukuk or bond, ESG reporting stops being optional in practice, because investors in those instruments expect the use of proceeds and impact to be reported.
IFRS S1 and S2: not adopted in the Kingdom
The ISSB standards, IFRS S1 on general sustainability disclosures and IFRS S2 on climate, were issued in June 2023 and apply from periods beginning on or after 1 January 2024 in jurisdictions that adopt them. As of October 2026, no Saudi regulator has adopted them, and Saudi Arabia does not appear among the jurisdictions the IFRS Foundation lists as having adopted or committed to the standards. SOCPA has published the official Arabic translations of IFRS S1 and S2 under an agreement with the IFRS Foundation, but translation is not adoption, and no effective date or roadmap has been announced.
The regional picture is mixed. Qatar has applied the ISSB standards to its regulated banks and insurers from 1 January 2026, while Bahrain’s framework for listed companies is built on other international frameworks. Our guide to ESG reporting in Bahrain and the GCC sets out the differences.
For a Saudi company, the practical question is whether to align with IFRS S1 and S2 voluntarily. For a company raising capital from international investors who use ISSB-aligned data, early alignment can make sense. For others, a well-run GRI report is a sound foundation, and the data systems built for it carry over if the standards are adopted later.
GRI in a Saudi report
GRI is one of the frameworks the Tadawul guidelines point to, and the one built for impact reporting. The current GRI Universal Standards, GRI 1, 2, and 3, were issued in 2021 and apply to reports from 1 January 2023, replacing the 2016 versions. Companies in the oil and gas sector also have GRI 11, the sector standard for oil and gas, published in October 2021.
The difference between GRI and the ISSB standards is one of perspective. GRI reports a company’s impact on the economy, environment, and people. IFRS S1 and S2 report sustainability-related risks and opportunities that affect the company’s own prospects. A report built on GRI does not automatically meet IFRS S1 and S2, and the reverse is also true, which is why the choice of framework should follow from who the report is for. A materiality assessment is where that choice is made in practice.
Assurance
Independent assurance of an ESG report is not mandatory in Saudi Arabia. Where a company chooses to have its report assured, SOCPA’s auditing standards board has approved ISSA 5000, the new international standard for sustainability assurance, for voluntary assurance engagements by SOCPA members. Its global effective date is for periods beginning on or after 15 December 2026.
The national context
Saudi Arabia announced the Saudi Green Initiative in October 2021, with a target of net zero emissions by 2060. Neither creates a direct reporting duty for companies, but they frame the expectations of government-linked investors, lenders, and customers, and they are the background against which a Saudi company’s climate disclosures will be read.
A practical sequence
For a Saudi company starting out, or one whose existing report has grown without a clear structure, the work follows a sensible order:
- Decide who the report is for. Equity investors, lenders, a green bond programme, or a parent group each point to different frameworks.
- Run a materiality assessment to fix which of the Tadawul themes and GCC metrics actually matter to the business.
- Choose the framework and map it to the GCC 29 metrics, so the report is comparable across the region.
- Build the data and governance: who owns each metric, where the data comes from, and who signs it off.
- Decide on assurance, and whether to align with IFRS S1 and S2 ahead of any requirement.
A note on scope and sources
The position above reflects the Saudi Exchange ESG Disclosure Guidelines of October 2021, the GCC Exchanges Committee metrics of January 2023, published CMA guidance and disclosure statistics, the IFRS Foundation’s jurisdiction information, and the GRI standards as they currently stand. Saudi requirements in this area could change, and sector regulators such as the Saudi Central Bank have their own supervisory expectations, so the position for a particular company should be confirmed against current CMA, Saudi Exchange, and SOCPA publications.
SRR Consultants provides ESG and sustainability advisory in Saudi Arabia: materiality assessments, framework selection and mapping to the Tadawul guidelines and GCC metrics, sustainability report preparation, and readiness work for IFRS S1 and S2, as part of our advisory work in the Kingdom. SRR is a management and business advisory consultancy and is not a licensed audit firm, so it does not provide assurance on sustainability reports.