QFC Regulatory Authority issues the GENE (Corporate Sustainability Reporting) and Minor and Technical Amendments Rules 2025
Doha, Qatar, Thursday, 26 June 2025
The QFC Regulatory Authority (“Regulatory Authority”) has today issued its GENE (Corporate Sustainability Reporting) and Minor and Technical Amendments Rules 2025 and the Guidance on “How to start the journey in applying the International Sustainability Standards Board (“ISSB”) Standards” (“the Guidance”), specifically the IFRS S1 General Requirements for Sustainability-related Disclosures (“IFRS1”) and IFRS S2 Climate-related Disclosures (“IFRS 2”).
Schedule 1 to the Rules contains amendments to the General Rules (“GENE”) relating to corporate sustainability reporting (“the CSR Rules”). Schedule 2 to the Rules contains minor and technical amendments to various QFCRA rulebooks.
The CSR Rules are being issued following public consultation and feedback received on Consultation Paper No. 2024/03 – Proposed Amendments to General Rules on Corporate Sustainability Reporting.
The CSR Rules (amendments to GENE) and the Guidance
In-scope firms
The Regulatory Authority is applying the corporate sustainability reporting framework to all Category A firms (larger firms such as banks and insurers). In addition, the Regulatory Authority will implement a designation process allowing the Regulatory Authority to apply the reporting framework to a firm upon the firm receiving a written notice from the Regulatory Authority.
Consultation feedback requested further detail on the criteria that will be applied by the Regulatory Authority for the designation process.
In response to the consultation feedback, guidance has been included under Rule 9A.1.2 (2) stating that the Regulatory Authority will take into account the following non-exhaustive factors when making a decision to designate an authorised firm:
a the size of the firm;
b the amount and nature of the firm’s assets and its assets under management;
c the firm’s client base; and
d any other matters, for example, where a firm is voluntarily preparing corporate sustainability reports and the Regulatory Authority elects to designate the firm based on the significance of the
reporting.
The guidance under Rule 9A.1.2 also clarifies that upon designation, the Regulatory Authority will aim to give a firm sufficient time to prepare the report.
QFC branches and subsidiaries reporting
The CSR Rules state that QFC branches and subsidiaries forming part of a legal entity or wider corporate group may rely on sustainability reports issued at the legal entity or group level (see Rule 9A.1.4). Consultation feedback requested clarification on when a branch may be able to rely on a report prepared for the legal entity as a whole and on how the Regulatory Authority will approach the issue of ensuring that legal entity or group-level reports meet the requirements set out in the CSR Rules.
In response to this feedback:
a guidance inserted under Rule 9A.1.4 (1) states that branches required by the Regulatory Authority to submit branch-level financial statements are unlikely to be permitted to rely on legal
entity-level sustainability reports;
b guidance inserted under Rule 9A.1.4 clarifies that where the legal entity or corporate group report is made under a standard that the International Sustainability Standards Board (“ISSB)” has
formally recognised as highly aligned with IFRS S1 and S2, the Regulatory Authority will generally consider this report as substantially similar to a report made under the CSR Rules; and
c The Guidance (see Chapter 7) has been updated to:
i set out the measures reporting firms need to take in respect of preparing disclosure requirements and information to enable compliance with both the firm’s jurisdiction requirements and the
ISSB sets of standards; and
ii provide for the circumstances where ISSB has not yet deemed a jurisdiction’s reporting standard to be highly aligned but where the Regulatory Authority will exercise its own judgement on
alignment between the ISSB standards and the relevant jurisdiction’s approach.
Additional amendments to the Guidance
The Guidance (see Chapter 5) incorporates recent consultation papers issued by the ISSB and other standard-setting bodies since December 2024. In addition, the Conclusion section of the Guidance also reflects the Regulatory Authority’s recommendations to firms on the preparatory steps necessary for the implementation of IFRS S1 and S2 by 1 January 2026.
Commencement date
Schedule 1 to the General Rules (Corporate Sustainability Reporting) and Minor and Technical Amendments Rules 2025 containing the CSR Rules commences on 1 January 2026.
Schedule 2 containing minor and technical amendments across several rulebooks commences on 1 October 2025.
Please click here to access the GENE (Corporate Sustainability Reporting) and Minor and Technical Amendments Rules 2025 and click here to access the Guidance on “How to start the journey in applying the International Sustainability Standards Board (“ISSB”) Standards”.
