What the Central Bank of Bahrain ESG Requirements Module introduced, who it applies to, and how it positions Bahrain in the GCC's sustainable-finance landscape.
Part of the reading lists: GCC and Jordan ESG disclosure and Climate risk and banking regulation
Updated 20 October 2026: this article now sets out the module’s exact scope (listed companies and specified classes of CBB licensees, not all licensees), its place in the Common Volume of the CBB Rulebook, the 31 mandatory KPIs, and the absence of any IFRS S1/S2 or assurance requirement.
Introduction
Bahrain has long punched above its weight as a regional financial centre, and on ESG disclosure it moved early. In November 2023, the Central Bank of Bahrain issued an ESG Requirements Module in the Common Volume of its Rulebook, which applies across sectors, and made an annual ESG report mandatory from financial year 2024. That made it one of the earlier formal ESG-disclosure regimes in the GCC. This article explains what it introduced and how it positions Bahrain in the regional landscape. It sits within the wider GCC sustainable-finance map.
What the module introduced
The module turns what had been voluntary, ad hoc reporting into a structured requirement:
- Who reports: listed companies and specified classes of CBB licensees, including banks and insurance firms. It does not reach every CBB licence type.
- What they report: an annual ESG report to the CBB, stand-alone or inside the annual report, carrying 31 KPIs set by the CBB: 10 environmental, 11 social and 10 governance. Each KPI is disclosed, or its non-disclosure or partial disclosure is explained.
- Frameworks: each KPI is referenced to GRI, TCFD or the GHG Protocol. Emissions cover Scope 1 and 2, with Scope 3 “if applicable”. There is no requirement to report in accordance with GRI or any other single framework.
- Governance: companies must have a governance framework and reporting process for ESG reporting, with responsibility on the board.
- Deadline for listed issuers: the Bahrain Bourse Listing Rules of 13 November 2024 require the ESG report within six months of the financial year end.
The Bahrain Bourse ESG Reporting Guide, which carries the GCC Exchanges Committee’s 29 metrics, remains voluntary. The binding list is the CBB’s 31 KPIs.
Bahrain has always traded on being a credible, well-regulated financial centre. Moving early on ESG disclosure is the same playbook applied to a new expectation.
Where it fits in the GCC
Five of the six GCC states now make some ESG report mandatory for listed companies, and Bahrain and Oman both prescribe a mandatory list of ESG metrics. Bahrain has not adopted IFRS S1/S2: there is no adoption decision, roadmap or consultation. Qatar has them in effect from FY2026 and Oman has adopted them from 1 January 2029. External assurance is not required either; KPI G.10 asks only whether the disclosures were assured. On climate risk for banks, the CBB’s 2021 circular and March 2022 Guidance Note are guidance, not binding rules. The full comparison is in ESG disclosure rules in the GCC, country by country. As regional expectations move toward IFRS S1/S2, Bahrain’s structured KPI base is a head start.
How to respond
For Bahraini institutions the path is clear: disclose every one of the 31 KPIs or explain each gap, put the board-level governance and reporting process in place, and build the data beneath the KPIs. Assurance is optional, but designing for it keeps the numbers defensible. Institutions that also reference IFRS S1/S2 do so by choice, and that choice prepares them for the rules tightening tomorrow.
How ESGweise helps
ESGweise helps Bahraini banks and listed companies meet the CBB ESG Requirements Module — building structured, framework-aligned disclosure, the data and governance beneath it, and assurance readiness. See our reporting and strategy practices and our work with banking and financial services.
Conclusion
Bahrain’s CBB ESG Requirements Module made it one of the GCC’s earlier movers on formal ESG disclosure, consistent with its role as a credible regional financial centre. It requires 31 KPIs, disclosed or explained, from listed companies and specified classes of CBB licensees. For Bahraini institutions, the head start is real, and building to the leading regional standard is how to keep it.
Frequently asked questions
What is the CBB ESG Requirements Module?
It is the Environmental, Social and Governance Requirements Module in the Common Volume of the CBB Rulebook, issued in November 2023. It requires an annual ESG report from financial year 2024 that discloses 31 KPIs set by the Central Bank of Bahrain, or explains why a KPI is not disclosed. It replaced ad hoc voluntary reporting with a structured, comparable requirement.
Who does the CBB ESG module apply to?
Listed companies and specified classes of CBB licensees, including banks and insurance firms. The module sits in the Common Volume of the Rulebook, which applies across sectors, but it does not cover every CBB licence type. Listed issuers file within six months of their financial year end under the Bahrain Bourse Listing Rules of 13 November 2024.
How does Bahrain compare to other GCC markets?
Bahrain made its ESG report mandatory from FY2024, ahead of Kuwait (FY2025) and while Saudi Arabia's listed reporting is still voluntary. Bahrain and Oman both prescribe a mandatory list of ESG metrics. Bahrain has not adopted IFRS S1 and S2: Qatar has them in effect from FY2026 and Oman has adopted them from 1 January 2029.
What should Bahraini institutions do to comply?
Disclose all 31 KPIs or explain each omission, put in place the governance framework and board accountability for ESG reporting that the module requires, and build the data behind the KPIs. Assurance is not required, but KPI G.10 asks whether the disclosures were assured by an independent third party, so readers will see the answer. Referencing IFRS S1/S2 is a voluntary choice that prepares an institution for tighter rules.