IFRS S1 and S2 reporting, GHG measurement and board governance, delivered by a firm that has been filing IFRS numbers since 2015.
The organizations below work with Prima across several practices. ESG is one of the reasons they do, and every name is one we can stand behind.
ESG consulting services are advisory engagements that help a company measure, report and govern its environmental, social and governance performance against a named standard. In the UAE and Saudi Arabia that usually means IFRS S1, IFRS S2, GRI or the GHG Protocol. The work produces a filed disclosure, not a slide deck.
Most companies come to this because someone outside the business asked a question they could not answer. An auditor, a lender, a regulator, a listing authority. The question is rarely “what is your sustainability vision” and almost always “where are your numbers”.
Between 2024 and 2026 the Gulf moved sustainability reporting from voluntary to legal, and ESG reporting trends across the Middle East show how fast the ground shifted. The UAE now has a federal climate law with financial penalties. Saudi Arabia has made disclosure mandatory for one class of issuer and a market expectation for everyone else.
So the buying question changed too. It used to be “should we report”. Now it is “are we already late”.
| Market | Instrument | Who it applies to | Status |
|---|---|---|---|
| UAE | Federal Decree-Law No. 11 of 2024, the Climate Law | Every UAE-registered entity, free zones included | In force 30 May 2025. Transition period ended 30 May 2026. Fines run from AED 50,000 to AED 2,000,000, and repeat breaches reach AED 4,000,000. |
| UAE | SCA sustainability disclosure guidance | ADX and DFM listed companies | IFRS S1 and S2 alignment from FY2026, with 2025 comparatives. |
| UAE | Annual sustainability report filing | ADX and DFM listed companies | Due within 90 days of financial year end, or before the AGM, whichever falls first. |
| UAE | DFM ESG Reporting Guide 2025 | DFM listed companies | 32 defined metrics. |
| Saudi Arabia | CMA ESG Disclosure Guidelines 2019, Saudi Exchange Guidelines 2021 | Tadawul listed companies | Voluntary, but a firm market expectation. Around 65% of the top 100 by revenue now report. |
| Saudi Arabia | Debt issuance disclosure | Issuers of green, social and sustainability-linked debt | Mandatory. |
| Pakistan | SECP ESG Disclosure Guidelines, revised December 2025 | Listed companies | Aligned to the Pakistan Green Taxonomy. Voluntary until June 2029, then phased and mandatory. |
| Pakistan | ISSB adoption | Listed companies above asset, turnover and headcount thresholds | Phased adoption of IFRS S1 and S2. |
| Standard | What it covers | Who needs it |
|---|---|---|
| IFRS S1 | General sustainability-related financial disclosures. Governance, strategy, risk management, metrics and targets. | Listed companies in jurisdictions adopting ISSB, including UAE from FY2026 |
| IFRS S2 | Climate-specific disclosures. Physical risk, transition risk, Scope 1, 2 and 3 emissions, scenario analysis. | Same population as S1, applied together |
| GRI | Broad impact reporting for a wide stakeholder audience. | Companies reporting to communities and regulators, not only investors |
| SASB | Industry-specific financially material metrics. Now folded into the ISSB architecture. | Anyone applying IFRS S1 sector guidance |
| GHG Protocol | The measurement rules behind emissions numbers. Sets the Scope 1, 2 and 3 boundaries. | Every entity with a GHG reporting duty, including UAE Climate Law filers |
| TCFD | Climate risk disclosure. Substantially absorbed into IFRS S2. | Legacy reporters transitioning to S2 |
IFRS S1 is a financial reporting standard. That is not a technicality. It means the disclosure sits alongside your financial statements, follows the same reporting calendar, and gets tested the same way.
What teams need: a written answer on which obligations reach their legal entities, and which tier they sit in.
How Prima solves it: an applicability review against the Climate Law, Cabinet Resolution 67, exchange rules and the relevant listing authority.
What teams need: one source for every number that goes into the report.
How Prima solves it: a metric register that maps each disclosure to its owner, system and calculation.
What teams need: disclosures that hold up under verification and limited assurance.
How Prima solves it: the report is built to an ISAE 3000 evidence standard from the first draft, and to ISO 14064 where the registry applies.
What teams need: the standard translated into a list of things to produce.
How Prima solves it: a clause-by-clause mapping from S1 and S2 into your existing reporting calendar.
What teams need: physical and transition risk expressed as portfolio numbers.
How Prima solves it: climate risk modelled into your existing IFRS 9 expected credit loss framework rather than reported beside it.
That last one is where most ESG firms stop and most risk teams start. Prima builds ECL models, and our worked ECL model examples under IFRS 9 show the mechanics. So the climate overlay goes into a framework we already understand rather than sitting beside it in a separate report.
What teams need: a governance structure a regulator would recognise.
How Prima solves it: committee terms of reference, oversight calendar and a board reporting pack, drawing on the same structures we use in governance, risk and compliance work.
Two tracks. Track A builds the reporting capability. Track B reviews what already exists.
| Service | What it means for your reporting |
|---|---|
| ESG reporting and disclosure | Your first IFRS S1 and S2 disclosure drafted, referenced and ready to file within your existing year-end calendar. |
| GHG inventory and Scope 1, 2 and 3 | An emissions boundary set under the GHG Protocol, with a calculation file your auditor can follow line by line. |
| Climate risk and transition analytics | Physical and transition risk quantified at portfolio level, built to sit inside your IFRS 9 ECL model rather than beside it. See worked ECL model examples for how those models are structured. |
| ESG strategy and materiality | A materiality assessment that names which metrics you must report and which you can drop, cutting reporting scope before it grows. |
| ESG governance and board advisory | Committee terms of reference, an oversight calendar and a board pack, so directors can evidence they discharged their duty. |
| Sustainable finance and green debt readiness | Disclosure prepared to the standard green bond and sustainability-linked loan investors require before pricing. |
| Service | What it means for your reporting |
|---|---|
| ESG audit and disclosure review | An independent read of a report you already published, flagging what will fail assurance before the auditor finds it. |
| Assurance readiness assessment | Your reporting process tested against ISAE 3000 so limited assurance does not turn into a restatement. |
| ESG due diligence | Target company sustainability practices assessed pre-transaction, with the liabilities priced rather than discovered later. Runs alongside entity risk profiling where the deal needs it. |
| Second-opinion review | A read of another adviser's work, useful when the board wants a check before signing. |
Track B runs on the same independence and evidence discipline as our internal audit consulting and entity risk profiling engagements.
| Step 1: Scope |
We establish which obligations reach which legal entities. | OUTPUT: Applicability memo naming every rule, date, threshold and entity. |
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| Step 2: Baseline |
We measure what you can report today against what the standard requires. | OUTPUT: Clause-level gap register and a first GHG inventory. |
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| Step 3: Build |
We put the data collection, calculations and controls in place. | OUTPUT: Metric register, documented data flows and a control matrix. |
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| Step 4: Report |
We draft the disclosure and reference every figure back to its source. | OUTPUT: Draft IFRS S1 and S2 disclosure with a full evidence file. |
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| Step 5: Embed |
We hand the process to your team with the governance around it, with technical and soft skills training where the team needs it. | OUTPUT: Board pack, reporting calendar and a controls handover. |
Financed emissions and climate risk inside the IFRS 9 ECL model, plus Scope 3 category 15.
Reporting against national programmes, with disclosure built for public scrutiny.
Scope 1 dominance, transition scenario work and the most likely sector to cross the 0.5 MtCO2e threshold.
Underwriting and investment portfolio exposure, reported alongside IFRS 17 disclosures.
Embodied carbon, building performance data and contractor Scope 3, the hardest data set in the region.
Network energy use, tower portfolios and the comparative scoring investors run across regional operators.
Portfolio-level metrics and the disclosure investors now request during mandate reviews.
Process emissions, energy intensity and a supply chain that rarely holds its own numbers.
Insurers reporting sustainability data alongside their IFRS 17 reporting get both handled by one team, on one calendar.
Under the UAE Climate Law, failing to measure, keep records of or report greenhouse gas emissions carries fines from AED 50,000 to AED 2,000,000. Repeat violations within two years double to AED 4,000,000. The transition period ended on 30 May 2026, so a company that has not started is not preparing, it is exposed.
For listed companies the exposure is different and slower. A disclosure that fails assurance becomes a restatement, and a restatement in a company first sustainability filing is read by investors as a control weakness rather than a reporting error.
There is a third cost that shows up on no penalty schedule. Lenders, insurers and institutional investors now ask for climate and governance data during credit review, renewal and mandate selection. Not having it does not trigger a fine. It quietly narrows who will do business with you.
ESG reporting is not an administrative cost. It is the record that lets a regulator, an auditor and a lender each verify the same set of facts about your business.
Two working days gives you a written view of which obligations reach your entities, which Climate Law tier you sit in, and where your data gaps are. No preparation needed from your side.
ESG consulting is advisory work that helps a company measure, report and govern its environmental, social and governance performance against a named standard. The standard is usually IFRS S1, IFRS S2, GRI or the GHG Protocol. The output is a filed disclosure supported by evidence an auditor can test.
Fewer people than most teams expect. We need one data owner per metric, usually spread across finance, facilities, HR and procurement, plus somebody with authority to sign off the reporting boundary. Collecting and calculating is our side of it; your team confirms sources and approves the numbers that go out.
A first disclosure typically runs 12 to 16 weeks from scoping to draft. Data collection is the long pole, not drafting. Companies with existing energy and HR data move faster.
Yes. Federal Decree-Law No. 11 of 2024 applies to all public and private entities generating emissions in the UAE, including free zone entities and state-owned enterprises. There is no size threshold and no sector exemption.
Yes, and it works in two tiers. Every UAE entity has had a Scope 1 and 2 reporting duty since 30 May 2026 under the Climate Law. Entities emitting 0.5 MtCO2e or more per year also had to register with the National Carbon Credit Registry, prepare an ISO 14064 aligned inventory and obtain third-party verification.
Largely voluntary. The CMA issued ESG Disclosure Guidelines in 2019 and the Saudi Exchange followed in 2021, and neither makes reporting compulsory for listed companies generally. One exception: issuers of green, social and sustainability-linked debt face mandatory disclosure. Adoption is rising regardless, with 94 listed companies reporting in 2024.
If you are listed in the UAE, IFRS S1 and S2, because that is what the SCA expects from FY2026. If you have a GHG reporting duty under the Climate Law, the GHG Protocol sets your measurement boundaries. GRI is added where community and regulator audiences matter alongside investors.
Narrow scope, real numbers, and a process that can be repeated next year without heroics. Mid-market reporters fail by over-scoping: chasing every GRI indicator instead of the handful that are financially material. Start with a materiality assessment and report fewer metrics well.
Yes. Our disclosure review reads a published report against the standard it claims to follow and flags what will not survive assurance. This is the most common first engagement for companies that used a generalist adviser.
Yes, including category 15 financed emissions for banks and investors. Scope 3 is where most first reports break, because the data sits with suppliers and portfolio companies rather than inside your systems. We set the boundary before collection starts, which avoids the usual restatement.
Yes. Prima delivers ESG consulting services across the GCC, Pakistan, Ireland and Germany. Jurisdiction changes the obligation, not the method.
Transition risk changes obligor creditworthiness and physical risk changes collateral value, and both flow into ECL through forward-looking scenarios. Most ESG advisers produce a climate report that sits beside the credit model. We build the overlay into the ECL framework itself, because we build ECL models.
Fines start at AED 50,000 and reach AED 2,000,000, and repeat violations within two years double to AED 4,000,000. For listed companies, a missed or late sustainability filing is also a disclosure breach with the exchange and is visible to the market. Neither is resolved by filing quietly the following year.
IFRS S1 covers sustainability-related financial disclosure generally: governance, strategy, risk management, metrics and targets. IFRS S2 covers climate specifically, including physical risk, transition risk, Scope 1, 2 and 3 emissions and scenario analysis. They are applied together, and S2 sits inside the S1 architecture.
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