ESG & Sustainability Advisory · Bahrain & GCC

ESG advisory built on what the regulators actually require.

SRR helps businesses in Bahrain and the GCC scope, structure, and report ESG: from the Central Bank of Bahrain’s ESG module and its 31 KPIs to sustainability reporting aligned with IFRS S1 and S2, GRI, and TCFD, led by ACA and ACCA qualified practitioners.

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The short answer

What does ESG and sustainability advisory in Bahrain involve?

ESG advisory in Bahrain covers four things: working out which requirements apply, starting with the Central Bank of Bahrain’s ESG module for listed companies and CBB licensees; running a materiality assessment to fix what is worth reporting; preparing a sustainability report aligned to a recognised framework; and structuring the governance to own it. The CBB module sets 31 KPIs and a six-month filing deadline after year end, and is referenced to GRI and TCFD rather than IFRS S1 and S2.

Complying with the CBB module does not make a business IFRS S1 and S2 (ISSB) ready, and the direction of travel across the GCC is towards ISSB alignment. SRR is a management and business advisory consultancy; ESG and sustainability advisory is a separate service from Economic Substance Regulations (ESR) advisory, which is a tax and corporate compliance regime under Ministerial Order No. 106 of 2018.

Source: CBB ESG reporting guidelines. Checked 25 August 2026.

CBB ESG module: 31 KPIs; 10 environmental, 11 social, and 10 governance indicators. The module first applied for the reporting period ending December 2024.
Filing deadline: Six months; An ESG report is submitted to the CBB within six months after financial year end, either standalone or inside the annual report.
Frameworks: IFRS S1/S2, GRI, TCFD; The CBB module is referenced to GRI and TCFD, not IFRS S1 and S2, so complying with it does not make a business ISSB ready.

What We Handle

ESG, from first scoping to a report that holds up.

One senior team takes ESG from working out what applies through to a measured, framework aligned report and the governance to keep it running year after year.

ESG scoping: which requirements apply, whether CBB, investor-driven, or voluntary
Materiality and double-materiality assessment
Baseline data collection and a gap analysis against the chosen framework
Sustainability report preparation aligned to GRI, TCFD, or IFRS S1 and S2
CBB ESG module KPI mapping and submission support
Greenhouse gas inventory scoping across Scope 1, 2, and 3 boundaries
ESG governance: roles, policies, and board and committee oversight
Readiness for external assurance where it is later required

Who It Is For

Where businesses usually come to us on ESG.

The CBB module now applies to you

You are a listed company or a CBB licensee within scope, a first report is due, and the 31 KPIs and the six-month deadline are not yet mapped to data you actually hold.

An investor or lender is asking for ESG data

A shareholder, bank, or fund wants sustainability metrics as a condition of capital, and there is no baseline, no boundary, and no framework behind the numbers yet.

You want to start before it is mandatory

A family group or private business deciding to build ESG credibility ahead of any mandate, where the initiative is internally driven rather than forced by a regulator.

You have a report but it does not hold up

An existing ESG statement that is narrative rather than measured, or not aligned to any recognised framework, and will not survive scrutiny from a regulator, investor, or assurer.

How It Works

A clear path from materiality to a defensible report.

Scope and materiality

We establish which requirements apply to your entity, and run a materiality assessment to fix what is actually worth reporting to your business and its stakeholders.
Baseline and gap

We collect the underlying data, map it to the chosen framework, set the reporting boundaries, and identify exactly where the gaps are before drafting anything.
Report and structure

We prepare the sustainability report and put the governance in place, roles, policies, and oversight, so the numbers have owners and the report can be defended.
Keep it current

We build the reporting into an annual rhythm, ready for tighter standards as the GCC moves towards IFRS S1 and S2, so each year builds on the last rather than starting over.

What Goes Wrong

The ESG mistakes that undo the whole exercise.

Most ESG reports that fail do not fail on ambition. They fail on the same few gaps, and every one of them is avoidable.

Assuming the CBB module makes you ISSB ready

Bahrain’s framework is referenced to GRI, TCFD, SASB and related standards, not IFRS S1 and S2. Qatar and the UAE are moving to ISSB alignment, so meeting the CBB module today is not the same as being IFRS S1 and S2 ready.

A narrative with no measurement

An ESG report that reads well but carries no KPIs, no baseline year, and no reporting boundary is not a report a regulator or an investor will accept.

Skipping the materiality assessment

Reporting on everything and nothing, rather than on what is actually material to the business and its stakeholders, produces a document that is long and unconvincing.

Treating ESG as a document, not a structure

Without named owners, policies, and board oversight, the report is a one-off exercise that cannot be repeated the following year or defended when questioned.

Common Questions

ESG and sustainability advisory, answered.

What is the CBB ESG module and who does it apply to?

The Central Bank of Bahrain issued its ESG module in November 2023, applying to listed companies and CBB licensees within scope. It sets 31 reporting KPIs, 10 environmental, 11 social, and 10 governance, and first applied for the reporting period ending December 2024. The report is submitted to the CBB within six months after the financial year end.

Does complying with the CBB ESG module mean we meet IFRS S1 and S2?

No. Bahrain’s framework is referenced to GRI, TCFD, SASB and related standards, not to IFRS S1 and S2. Meeting the CBB module does not make a business ISSB ready. This matters because Qatar applies ISSB standards to regulated banks and insurers from 2026, and the UAE requires IFRS S1 and S2 alignment for listed companies from FY2026, so the regional direction of travel is towards ISSB.

What is a materiality assessment, and why does it come first?

A materiality assessment identifies which environmental, social, and governance topics are actually significant to your business and its stakeholders, and, under double materiality, which of your impacts on the outside world are significant too. It comes first because it decides what the report covers. Without it, an ESG report tends to say a lot about topics that do not matter and little about the ones that do.

Do we need external assurance over our ESG report?

The CBB guidelines do not currently impose an external assurance requirement over the ESG report, which is a difference from the direction of travel elsewhere. We prepare the report and the underlying data so that, if assurance is later required by a regulator, an investor, or your own board, the evidence is already in place to support it.

Is ESG advisory the same as Economic Substance (ESR) advisory?

No. Economic Substance Regulations advisory is a tax and corporate compliance regime under Ministerial Order No. 106 of 2018. ESG and sustainability advisory is a separate service concerned with sustainability reporting and governance. The names are easy to confuse, but the work, the rules, and the deadlines are different.

Can you help a private or family business that is not regulated?

Yes. Private and family groups can build sustainability credibility ahead of any mandate, for example when an investor, lender, or partner asks for ESG data, or when the board decides it wants to be ready. We scope the same way, starting from what is material and what a recognised framework requires, rather than from a regulatory deadline.

Who delivers the ESG work, and what is SRR’s role?

SRR Consultants is a management and business advisory consultancy. ESG and sustainability advisory, readiness, materiality, reporting, and governance, is led by SRR’s own ACA and ACCA qualified practitioners. SRR is not a licensed audit firm, so where external assurance over the ESG report is required, that assurance sits with a separately registered firm.

Part of our advisory and assurance practice for regulated and institutional clients. For the detail on what the regulator requires, see our guide to ESG reporting in Bahrain and why it is not IFRS S1 and S2. ESG is a separate service from Economic Substance (ESR) advisory.

Scope your ESG reporting properly.

A short call with a senior practitioner is the quickest way to work out what applies to you, what is material, and what a compliant, defensible report actually needs.