For most of the last decade, sustainability reporting in the Gulf was a narrative exercise. A glossy report, a set of commitments and some carefully chosen metrics, produced annually by a small team with a large spreadsheet. That era has ended.
IFRS S1 and S2 set the expectation that sustainability-related financial disclosures are prepared with the same rigour as the financial statements they sit beside. UAE Decree-Law No. 11 and national agendas in Saudi Arabia and Qatar reinforce the direction. Regulators, auditors and increasingly investors expect the numbers to be traceable, controlled and repeatable.
If your ESG number lives in a spreadsheet, it is an opinion, not a disclosure.
The data problem underneath the reporting problem
When we look inside a large regional bank's ESG process, the pattern is familiar. Dozens of business units submit data by email. A central team consolidates it manually. Definitions differ between submitters. Nobody can reproduce last year's number from first principles, and the audit trail is a folder of versions.
At one large UAE bank this consumed thousands of hours a year and produced disclosures that the finance function was uncomfortable signing. Replacing the manual collection with an automated pipeline and real-time dashboards, mapped to IFRS S1 and S2 and to Decree-Law No. 11, cut processing time by seventy percent and saved more than 1,200 hours annually. More importantly, every number now has a lineage.
Treat it like financial reporting, because it is
The institutions handling this well have done four things. They have appointed a data owner for every disclosed metric. They have written a control framework for the ESG close that mirrors the financial close. They have automated collection and calculation so that the annual scramble becomes a monthly routine. And they have run a dry-run audit before the real one.
Financed emissions will be the hard part
Scope 3, and in particular financed emissions across the lending and investment book, is where the data is thinnest and the methodology is still settling. Banks that start building counterparty-level data now will have a defensible number in two years. Those that wait will be estimating under pressure.
The practical advice is unfashionable: fix the data and the controls before worrying about the narrative. The report writes itself when the numbers are right.
