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Regulation · · 2 min read

QFCRA vs QCB: Qatar’s two sustainability reporting rules compared

Qatar’s two sustainability reporting regimes converge on the ISSB standards but diverge in scope, enforcement architecture and the flexibility each allows during the transition.

WRITTEN BY

ESG Qatar Editorial

Hawkama International

The West Bay skyline in Doha, the towers of the city’s financial district seen from the road
Photograph: Zairon. Cropped for this page, licensedCC BY 4.0source (opens in a new tab)

Key takeaways

  • Both frameworks mandate the ISSB standards - IFRS S1 and IFRS S2 - so the substance of what must be disclosed largely converges.
  • The QFCRA’s GENE (Corporate Sustainability Reporting) Rules 2025 capture large Category “A” firms inside the QFC; the QCB’s Sustainability Reporting Framework captures banks and insurers licensed outside it.
  • Entities holding both licences fall under both frameworks simultaneously and must treat each regulator as a separate obligation.
  • Both frameworks defer Scope 3 emissions disclosure by two years, presented as a transitional stage rather than a permanent exemption.
  • The QFCRA extends its perimeter through the “designation” mechanism; the QCB relies on its direct supervisory relationship with licensed institutions.
  • The QFCRA permits continued use of a legacy emissions measurement methodology for the first two years, provided the divergence from the GHG Protocol is disclosed.

Who is in scope: QFC Category A firms, QCB licensees and the designation mechanism

  • Qatar Financial Centre Regulatory Authority (QFCRA)It has issued the GENE (Corporate Sustainability Reporting) Rules 2025. These apply to large Category “A” firms licensed within the Qatar Financial Centre (QFC), such as large banks and insurance companies, in addition to any other firm that the regulator notifies in writing to that effect on the basis of its size, its assets and its client base.
  • Qatar Central Bank (QCB)It has issued the Sustainability Reporting Framework (SRF). This applies to all banks and insurance companies licensed in Qatar outside the perimeter of the Qatar Financial Centre.

An important point: there are entities that may be subject to both frameworks at the same time, such as banks that hold a licence from the QCB and are also licensed in the QFC; these must treat each regulator as a separate obligation.

The standards adopted, and the Scope 3 grace period

Core standards: both frameworks impose compliance with the standards of the International Sustainability Standards Board (ISSB), specifically IFRS S1 (General Requirements for Sustainability Disclosure) and IFRS S2 (Climate-related Disclosures). This means that the substance of what is required is for the most part convergent.

Emissions scope (Scope 3): it is here that a substantive difference in the grace period emerges.

  • QFCRAIt grants a grace period of two years (the first two reports) for the disclosure of Scope 3 emissions - indirect emissions in the value chain - meaning that they are not required during that period.
  • QCBIt likewise grants an extended grace period of two years, specifically for the disclosure of Scope 3 emissions, treating this as a transitional stage and not a permanent exemption.

The mandating mechanism and flexibility

  • How the QFCRA mandatesIt relies on the “designation” mechanism, whereby the Authority may extend the scope of the mandate to cover other firms on the basis of specified criteria. It also allows flexibility for subsidiaries or branches of international groups to rely on sustainability reporting at group level, provided that this satisfies the QFC’s own disclosure requirements.
  • How the QCB mandatesThis arises through its direct supervisory relationship with licensed financial institutions, and is clearer in identifying the entities subject to the regime.

Flexibility in measurement (QFCRA): it permits continued use of the legacy methodology for measuring emissions (where this differs from the Greenhouse Gas (GHG) Protocol) during the first two years, with disclosure of that divergence.

In conclusion

The conclusion is that both frameworks adopt the same ISSB standards, which ensures consistency in the substance of the information required. The material difference lies in the regulatory structure and the mechanisms of application: the QFCRA framework is distinguished by greater flexibility in its mandating mechanism - through designation - and by the wider range of options it makes available for the transitional period, whereas the QCB framework is applied through a direct supervisory relationship across a broader population of financial institutions outside the free zone.

TOPICS

  • QFCRA vs QCB
  • GENE Rules 2025
  • Scope 3 grace period Qatar
  • ISSB adoption Qatar
  • QFC dual licensing compliance

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