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ADGM - ESG Disclosures Framework Introduction

ADGM (Abu Dhabi Global Market) has introduced an updated ESG Reporting Framework that sets important requirements for ADGM-registered companies, with meaningful implications for compliance, transparency, and sustainable business practices. Sen & Ray is ready to support organizations in meeting these obligations efficiently and strategically. 

ADGM’s ESG (Environmental, Social, Governance) Disclosures Framework applies to certain entities operating within ADGM—including companies with a turnover above $68 million and FSRA-licensed asset or fund managers with Assets Under Management (AUM) exceeding $6 billion. The framework mandates affected companies to start reporting on ESG factors by the third year after incorporation, advancing the UAE’s commitment to net zero by 2050. 

Requirements & Rules

  • Thresholds: Reporting is required for companies with turnover > $68 million, and for fund/asset managers with AUM > $6 billion. Companies have a three-year grace period after incorporation to comply.
  • Standards: Entities must prepare and submit ESG disclosures aligned to internationally recognized standards. ADGM mentions CDP, GRI, ISSB, TCFD, and UNSDG as reference frameworks. Firms can choose the standard most appropriate and globally accepted for their business.
  • Scope and Flexibility: The rules are based on a ‘comply or explain’ principle: companies may opt to explain why they have not disclosed certain ESG information. Branches of foreign companies, certain foundations, LLPs and LPs, and some listed entities may be exempt, but voluntary compliance is encouraged for all.
  • Publication: ADGM encourages all ESG disclosures to be published publicly to support transparency and stakeholder trust.
  • Group Accounts: ESG disclosures made at a consolidated group level may count towards compliance, if they are broadly equivalent to ADGM requirements.

Global Standards Explained

ADGM permits compliance using globally recognized ESG standards, such as:

Each standard has unique metrics, requirements, and reporting practices. Choosing the right fit is essential for credibility and stakeholder alignment.

How can Sen & Ray support my company’s first annual ADGM ESG report?

Sen & Ray can fully support your company in preparing and submitting its first annual ADGM ESG report through a mix of strategic advisory, technical guidance, and operational implementation tailored to ADGM’s requirements.

  • Gap Analysis and Baseline Assessment
    Sen & Ray can conduct a thorough gap analysis of your current policies, practices, and available data against the ADGM framework and global ESG standards like GRI, ISSB, and TCFD. This baseline assessment identifies priority areas and ensures you understand exactly what needs to be disclosed and improved for compliance.
  • Framework Selection and Customization
    Expert consultants will help you choose the most relevant ESG reporting framework for your industry and stakeholders, then adapt templates and reporting protocols to your business model. This makes meeting ADGM’s ‘comply or explain’ rules straightforward and credible.
  • Data Collection, Automation, and Reporting
    Sen & Ray assists in automating ESG-related data capture, ensuring workflows are efficient and deadlines are met. Specialists will guide you in preparing your first ADGM ESG report, ensuring it is accurate, clear, and aligned to required standards.
  • Stakeholder Engagement and Communication Strategy
    Communicating ESG commitments and results is essential. Sen & Ray can craft communication strategies so your disclosures build trust with regulators, investors, and employees. This strengthens your reputation while ensuring transparency.
  • Continuous Improvement and Benchmarking
    After the first report, Sen & Ray will help you set up mechanisms for ongoing improvement, monitoring ESG metrics, and benchmarking against industry peers so future reports are easier and more strategic.

Sen & Ray delivers end-to-end support for ADGM ESG reporting, enabling companies to meet regulatory requirements and unlock additional value from their sustainability journey.


 

 

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