How Saudi-listed companies, boards, and finance teams can meet CMA and Tadawul disclosure expectations — and get ahead of the binding requirements coming next.

✓ Written by Prima Consulting’s advisory team  ·  ✓ Serving GCC, Europe & APAC  ·  ✓ Actuaries + CPAs + CFAs

TL;DR

ESG reporting in Saudi Arabia is shifting fast. What the CMA and Tadawul label “voluntary” today is already becoming a market access requirement, especially for companies seeking green financing or foreign institutional capital. This article covers what the CMA and Tadawul currently mandate for listed companies across the Middle East, how Vision 2030 sustainability targets translate into disclosure obligations, and the IFRS S1/S2 adoption path SOCPA is building. Start your first ESG report before regulators force your hand.

Why ESG Reporting in Saudi Arabia Is No Longer a Choice

When the CMA published its first ESG disclosure guidelines in 2019, most listed companies filed them away and moved on. Five years later, that decision looks different. In 2024, 94 Tadawul-listed firms issued sustainability reports, up from just 81 in 2023. Among the top 100 companies by revenue, roughly 65% now report on ESG.

That jump didn’t happen because the rules changed. It happened because the investors did.

Saudi Arabia’s Public Investment Fund, now managing over $941 billion in assets, has formally integrated ESG criteria into its investment decisions. Foreign institutional investors — who entered the market after Saudi Arabia’s inclusion in the MSCI Emerging Markets Index — increasingly screen for ESG transparency before allocating capital. If your company doesn’t report, you’re not just behind on best practice. You’re invisible to a growing category of capital allocator.

This article covers what you actually need to know:

• What CMA and Tadawul currently mandate versus recommend for listed companies
• How Vision 2030 sustainability targets connect to corporate disclosure obligations
• Where IFRS S1 and S2 adoption stands in KSA and what that means for your timeline

Prima Consulting has been advising Saudi and GCC companies on ESG readiness since the CMA first issued its 2019 guidelines. The picture now looks very different from four years ago.

What Does the CMA Actually Require Right Now?

Here’s the honest answer: full mandatory ESG reporting for all listed companies has not been set. The CMA has not published a universal binding deadline. But that framing misses what’s actually happening on the ground.

The 2019 Guidelines — and Why They Still Matter

The CMA’s 2019 ESG disclosure guidelines were issued as recommendations, not rules. They asked companies to report on governance structures, board composition, risk management, and social policies. Most companies ignored them, at least in the early years.

That posture is now risky. The CMA has progressively tightened its governance regulations, and ESG considerations are being folded into those rules, not issued alongside them. Think of it less as a separate ESG law and more as a creeping integration into the corporate governance framework every listed company already has to follow.

The 2025 Green Debt Framework: Where Mandatory Crept In

This is the part most boards aren’t tracking closely enough.

In 2025, the CMA formalized its framework for green, social, sustainability, and sustainability-linked debt instruments. If your company issues any bonds or sukuk under this framework, ESG disclosure is not optional. You must report on the use of proceeds, the environmental or social impact of projects, and provide ongoing disclosure for the life of the instrument.

Green debt issuance in Saudi Arabia is growing. If you’re planning to access that market — and many listed companies are — the reporting obligation arrives with the financing. You don’t get to treat it as a separate question.

For more on how ESG reporting affects financial performance, and why institutional lenders are increasingly pricing ESG readiness into deal terms, that’s worth reading before your next capital raise.

Tadawul’s ESG Framework: Voluntary on Paper, Essential in Practice

Tadawul issued its ESG disclosure guidelines in 2021. Like the CMA’s framework, they’re technically voluntary. And like the CMA’s framework, treating them as optional is a calculation that gets harder to justify every year.

The Saudi Exchange published its own sustainability report in 2025, using GRI, SASB, IFRS sustainability disclosure standards, and the UN SDGs as reference frameworks. When the exchange itself reports against those standards, the signal to listed companies is not subtle.

The Saudi Exchange ESG Index — and Who Gets Left Out

Tadawul maintains a dedicated ESG index. Inclusion is based on a combination of ESG scores, transparency of disclosure, and alignment with the exchange’s reporting guidelines. Companies not reporting get excluded from the index. That matters more than it sounds.

Passive and ESG-screened funds tracking the index will not hold your stock. More practically, when an investor asks your IR team which ESG indices you’re included in and the answer is none, that’s a conversation you don’t want to repeat in front of your board.

By the end of 2023, only 13 out of 217 listed companies on Tadawul had submitted formal sustainability reports, a 6% adoption rate. The jump to 94 in 2024 shows how quickly that changed. Companies that started early built the data infrastructure first. Those starting now are under more pressure to catch up fast.

“Prima Consulting supported one of Saudi Arabia’s leading real estate developers in preparing their inaugural GRI-aligned sustainability report, mapping materiality across 14 disclosure categories in under six months.” — Read more about Prima’s ESG practice.

How Vision 2030’s Sustainability Targets Translate to Your Disclosure

Vision 2030 is not an ESG framework. But it sets national sustainability commitments that flow directly into what regulators expect from listed companies.

Saudi Arabia has committed to 50% renewables in its national energy mix by 2030. PIF is responsible for developing 70% of the Kingdom’s renewable energy infrastructure. The National Transformation Program sets specific targets on water efficiency, waste management, and carbon emissions.

Here’s the question worth sitting with: if the Kingdom is reporting against those targets at the national level, what happens when your company can’t show how its own operations connect to them?

National Transformation Program: The Targets Sitting Behind ESG

The NTP isn’t well understood by most corporate finance teams outside the energy sector. That’s a gap worth closing.

The program includes sector-specific sustainability targets for energy, water, and social development. For listed companies in those sectors, the alignment between national targets and investor expectations for corporate disclosure is direct. But even companies in banking, real estate, and retail need to map their Scope 1 and Scope 2 emissions as a starting point. Investors aligned with Saudi Vision 2030 are asking for it, and they’re starting to ask more loudly.

Saudi Arabia currently ranks 108th on the Environmental Performance Index — 13 positions below where its own 2024 target placed it. That gap creates pressure on regulators to move faster on corporate disclosure. Listed companies that treat reporting as optional may find they’re reacting to a mandatory requirement rather than getting ahead of it.

You can read how these pressures compare to broader ESG reporting requirements in the UAE, where mandatory timelines are further along and penalties for non-compliance are already in force.

IFRS S1 and S2 in KSA: Where the Kingdom Stands in 2026

The ISSB published IFRS S1 (general sustainability disclosures) and S2 (climate disclosures) in mid-2023. Countries across the UK, Australia, and Japan have set binding adoption timelines. Saudi Arabia has not.

What Saudi Arabia has done is task SOCPA — the Saudi Organization for Chartered and Professional Accountants — with developing ISSB-aligned standards consistent with Vision 2030 commitments. That work is ongoing. No binding adoption date is confirmed as of mid-2026.

I’ll be direct about what I don’t know here: the exact timeline for SOCPA to finalize and publish those standards is unclear. The trajectory is toward adoption. The pace is uncertain. What’s not uncertain is that companies building IFRS S1/S2-aligned reporting infrastructure now will face a shorter path to compliance when the mandate arrives.

The practical difference between IFRS S1/S2 and GRI is important. GRI is a stakeholder-focused framework, reporting on your impact on the world. IFRS S1/S2 is investor-focused, reporting on how sustainability risks and opportunities affect your financial position. Most Saudi listed companies that are reporting at all are using GRI. Building toward IFRS S1/S2 means adding a financial materiality lens to existing disclosure work, not starting from scratch.

For a full breakdown of what choosing the right framework means for your first report, the ESG implementation guide covers GRI vs IFRS S1/S2 vs SASB selection criteria for Saudi and GCC companies.

What Foreign and Sovereign Investors Expect From Saudi Companies

Global ESG-focused institutional assets are projected to hit $33.9 trillion by 2026. That pool of capital doesn’t flow to companies it can’t assess.

Saudi Arabia’s Qualified Foreign Investor program opened the market to a new class of institutional capital after the MSCI inclusion. Those investors come with ESG screening criteria built into their mandates. Transparency on Scope 1 and 2 emissions, board diversity, supply chain governance, and anti-corruption policies aren’t requests. They’re table stakes for staying on the shortlist.

PIF’s 2026-2030 strategy, approved by the board in early 2026, places explicit emphasis on governance standards and institutional transparency. When the Kingdom’s largest sovereign investor is publishing that language in its strategic priorities, portfolio companies notice.

That said, not every institutional investor uses the same screen. European pension funds running SFDR-aligned mandates apply more stringent climate metrics than, say, Gulf-based institutional buyers. If you’re building your first ESG report, you need to know who your top ten institutional holders are and what frameworks they care about. That one step changes the whole structure of what you report and what you skip.

Your First ESG Report: Where to Start and What Data to Collect

Most companies freeze at the start. The framework options, the data requirements, the assurance question — it can feel like the entire program needs to be designed before any work begins. That’s the wrong approach.

Step 1 — Pick Your Framework

For Saudi listed companies starting today, GRI Standards are the most commonly used baseline and the one Tadawul’s guidelines recommend. If your investor base is heavily weighted toward European or global institutional funds, layer IFRS S2 climate disclosures on top. Don’t attempt TCFD, GRI, SASB, and IFRS S1/S2 simultaneously in year one. Pick one. Do it well. Add the others over two to three reporting cycles.

Step 2 — Run a Materiality Assessment

This is the step most companies skip or do badly. A materiality assessment identifies which ESG topics are significant to your business specifically — not every sector peer, not your parent company’s global framework. For a Saudi bank, the material topics look different from a Riyadh-listed petrochemical producer.

Talk to your top ten investors, your largest institutional lenders, and two to three senior managers across operations. That’s your materiality process at minimum. It takes four to six weeks done properly. Skipping it means your first report covers everything and says nothing of value to anyone.

Step 3 — Collect the Data

Start with energy consumption and greenhouse gas emissions. These are Scope 1 (direct) and Scope 2 (purchased electricity) data points, and they’re the baseline requirement for virtually every framework. Scope 3 — upstream and downstream value chain emissions — is harder and you can tackle it in year two.

Beyond emissions: employee turnover, gender pay gap, board independence ratio, and anti-bribery policy coverage. Those six to eight data points form the backbone of a credible first report. You already have most of this data somewhere in the business. The challenge is getting it into a consistent format.

Step 4 — Structure and Publish

Your report does not need to be a 150-page document in year one. A focused 30-40 page report with clear GRI index, honest commentary on data gaps, and a forward-looking commitment is more credible than a comprehensive document full of boilerplate language. Assurance is optional for year one but signals maturity quickly — a limited assurance engagement from a Big Four firm on your environmental data adds credibility without the full cost of reasonable assurance.

ESG consulting firms with KSA-specific experience can compress this timeline significantly. The data collection and materiality stages are where most companies lose six months unnecessarily.

What You Now Know

• ESG reporting in Saudi Arabia is technically voluntary for most listed companies, but the CMA’s 2025 green debt framework made it mandatory for bond and sukuk issuers, and Tadawul’s ESG index exclusion creates real market consequences for non-reporters.
• Saudi Arabia is working through SOCPA to develop ISSB-aligned standards (IFRS S1/S2), with no confirmed binding date yet — but the direction is clear, and companies building the data infrastructure now will have a shorter compliance path when the mandate lands.
• Your first ESG report doesn’t need to cover everything. A GRI-aligned report focused on your material topics, with honest disclosure on data gaps, is more valuable to investors than a comprehensive document with no substance behind it.

ESG reporting in Saudi Arabia is in the window where early movers still get credit for initiative and late movers are starting to look like they’re waiting for enforcement. That window closes as mandatory timelines firm up, as more sovereign and institutional capital applies ESG screens, and as the Tadawul ESG index becomes a more prominent benchmark for index-tracking funds.

The companies that will handle this best are not the ones with the biggest sustainability teams. They’re the ones that ran a proper materiality assessment, picked one framework, and published something honest in year one. That foundation makes every subsequent disclosure cycle faster and cheaper.

Prima Consulting’s KSA advisory team has supported listed companies through every stage of this process, from first materiality assessment to GRI-aligned publication to IFRS S1/S2 gap analysis. If your board is asking whether esg reporting saudi arabia requirements apply to you yet, the answer is: probably more than you think.

Frequently Asked Questions

Is ESG reporting mandatory for companies listed on Tadawul in 2026?

Full mandatory ESG disclosure has not been set for all Tadawul-listed companies as of 2026. The CMA’s 2019 guidelines and Tadawul’s 2021 framework remain voluntary for most firms. However, companies issuing green or sustainability-linked debt under the CMA’s 2025 framework must disclose ESG data. Regulatory direction points toward binding requirements in the next reporting cycle.

Which ESG framework should Saudi listed companies use?

GRI Standards are the most widely adopted baseline for esg reporting saudi arabia and are recommended by Tadawul’s disclosure guidelines. Companies with European or global institutional investors should also align climate disclosures with IFRS S2. Starting with GRI and adding IFRS S1/S2 alignment over subsequent reporting cycles is the standard approach for KSA-listed companies.

What are the CMA’s current ESG disclosure requirements for Saudi companies?

The CMA issued voluntary ESG disclosure guidelines in 2019 covering governance, environmental, and social disclosures. In 2025, the CMA added mandatory ESG reporting requirements for issuers of green and sustainability-linked bonds under its green debt framework. ESG criteria are also being progressively integrated into broader corporate governance regulations for all listed firms.

How does IFRS S1 and S2 affect esg reporting requirements in KSA?

Saudi Arabia’s SOCPA is developing ISSB-aligned standards consistent with IFRS S1 and S2, but no binding adoption date has been confirmed. Listed companies building IFRS S1/S2-aligned data infrastructure now will have a shorter compliance path when the mandate arrives. Starting with IFRS S2 climate disclosures is the recommended first step for companies currently using GRI.

How long does it take to prepare a first ESG report for a Saudi listed company?

A focused first ESG report typically takes four to six months from materiality assessment to publication, assuming data collection infrastructure exists. Companies starting from zero on emissions data may need six to nine months. Working with an experienced ESG consultant in Saudi Arabia can reduce that timeline and prevent common first-report errors.