ESG Disclosures
Framework

• In scope: all ADGM entities unless out of scope, exempt or do not meet the Threshold Conditions.
• Comply or explain: In-scope ADGM companies meeting the Threshold Conditions must either comply with the disclosures or explain non-compliance.
• Out of scope or exempt ADGM entities: Foundations, LLPs, Partnerships, Restricted Scope Companies, Listed Entities with equivalent disclosures, Investment Companies, and Branches of foreign companies. However, these entities can choose to voluntarily comply.

• Turnover threshold: More than US$ 68 million in a financial year, or
• AUM threshold: FSRA-licensed fund and asset management companies with AUM over US$ 6 billion at any time during the financial year.
• Disclosure requirement no longer applies to entities who cease to meet the Threshold Conditions for two consecutive years until they meet that threshold again.

Submissions must be in accordance with a globally recognised standard (e.g., CDP, GRI, ISSB, TCFD).

1. Determine if you're in scope: Check if you are in scope and meet the turnover or AUM thresholds. If not, you can still choose to voluntarily comply.
2. Choose an ESG standard: Select a globally recognised disclosure standard that aligns with your business.
3. Prepare and submit disclosures: Submit with annual accounts. Disclosures typically become mandatory in your third year of operation if you meet the thresholds.
4. "Comply or Explain": If you are in scope but choose not to fully comply, you must submit a clear explanation for not doing so to the Registrar.