Oman — MSX ESG disclosure, IFRS S1/S2 adoption and CBAM exposure

Oman requires every listed public joint stock company to disclose a fixed set of 30 ESG metrics and publish a sustainability report, under a Muscat Stock Exchange (MSX) decision that carries deadlines and sanctions. The Financial Services Authority (FSA) has adopted IFRS S1 and IFRS S2 on a phased timetable. Omani exporters of aluminium, steel, fertilisers, cement or hydrogen to the EU also sit inside the definitive phase of the EU Carbon Border Adjustment Mechanism (CBAM).

What is in force

MSX ESG Disclosure Guideline. The Guideline states that all companies publicly listed on MSX and registered as SAOG companies are required to disclose 30 metrics through the MSX ESG Disclosure platform and publish their sustainability reports.¹ Disclosures were voluntary in 2024, and from 2025 onwards reporting on activities from the 2024 fiscal year became mandatory.¹ The Guideline is aligned with the Unified GCC ESG Disclosure Metrics for Listed Companies, published in 2022, and with the GRI Standards. Of the 30 metrics, 29 are shared with the other GCC exchanges, and Metric 30, on corporate social responsibility, is specific to MSX.¹ MSX joined the UN Sustainable Stock Exchanges initiative in March 2022,¹ and publishes the guidance and the Unified GCC metrics on its Sustainable Investments pages.²

Administrative Decision No. 77/2025. The Guideline’s “required” became a rule on 1 June 2025, when MSX issued Administrative Decision No. 77/2025 setting out the Requirements for Disclosure of Environmental, Social and Governance Practices. The Decision cites the approval of the FSA board and the MSX board, and took effect from its date of issue.³ The Requirements oblige each listed company to disclose its ESG practices through the Exchange’s disclosure platform and on its own website, according to the attached form.³ The disclosure is due in the first quarter, within 30 days of the end of the financial year and immediately after board approval, or 45 days for a company with subsidiaries, which must show consolidated and parent-company data separately.³ The Requirements also demand adherence to the form, accuracy, realism and clarity, and disclosure of negative information at the same level as positive information; the Exchange may ask for further clarifications after a disclosure.³

EU CBAM, definitive phase. For goods of Omani origin, Regulation (EU) 2023/956 lists cement, electricity, fertilisers, iron and steel, aluminium and hydrogen in Annex I; Annex III excludes only goods originating in Iceland, Liechtenstein, Norway and Switzerland and five territories, so Omani goods are within scope.⁴ The transitional period from 1 October 2023 until 31 December 2025 limited importer obligations to reporting. Applications for authorised CBAM declarant status opened on 31 December 2024 under Article 36(2)(a), and from 1 January 2026 goods may be imported only by an authorised CBAM declarant (Article 4), alongside the declaration, certificate and penalty articles.⁵

What is coming

IFRS S1 and S2. FSA Decision No. E/7/2026, issued on 17 March 2026, adopts IFRS S1 and IFRS S2 for the preparation and assurance of financial reports or sustainability reports of listed public joint stock companies and financial institutions.⁶ It was published in Official Gazette No. 1640 dated 24 March 2026 and, by its own Article Five, took effect the day after publication.⁷ The timetable is phased: full application of IFRS S1 for reporting periods beginning on or after 1 January 2029, and full application of IFRS S2 from the same date, except Scope 3 greenhouse-gas emissions disclosures, which apply for reporting periods beginning on or after 1 January 2030.⁶ The FSA is to issue guidelines, templates and implementation tools; whether any have been issued yet is unconfirmed on a primary source.

Under CBAM, the authorised declarant must submit its CBAM declaration by 30 September of each year, and for the first time in 2027 for the year 2026, and surrender the corresponding certificates by the same date. The quarterly certificate-holding requirement in Article 22(2) applies from 1 January 2027.⁵

Who it binds

The MSX Requirements apply to all public joint stock companies listed on the Exchange.³ The Guideline addresses the same population — companies publicly listed on MSX and registered as SAOG companies.¹ The FSA’s IFRS decision reaches listed public joint stock companies and financial institutions, and binds practitioners of the accountancy and auditing profession to apply the standards when preparing or assuring those reports.⁶ Its sanctions are professional ones: a warning, suspension from the profession for up to two years, or removal from the register of accountants and auditors.⁶ Unlisted Omani companies outside the financial sector are not named in either instrument.

CBAM binds the EU importer, not the Omani producer: an importer established in a Member State must apply for the status of authorised CBAM declarant before importing.⁵ An importer whose CBAM goods do not cumulatively exceed 50 tonnes of net mass in a calendar year is exempt under Article 2a; Regulation (EU) 2025/2083, which introduced that threshold, entered into force on 20 October 2025 and excludes electricity and hydrogen from the exemption.⁸ An Omani producer is reached through its customers’ need for embedded-emissions data.

Verification requirements

Neither MSX instrument requires assurance. The Guideline names verifiability among its reporting principles, and refers Scope 1 and Scope 2 emissions calculations (mandatory) and Scope 3 (optional) to the WRI/WBCSD GHG Protocol. It includes metric G9, External Assurance, which asks whether sustainability disclosures are assured or validated by a third party and which KPIs were verified — a disclosure about assurance, not a requirement to obtain it.¹ The sustainability report must be stand-alone and aligned with global frameworks such as GRI, TCFD and SASB, with fiscal-year boundaries and a materiality assessment, and be published on the MSX platform and the company website; no assurance standard is named.¹ The Requirements add the sanction: on non-compliance the Exchange may, notifying the Authority, warn the company or refer the violation to the FSA to take the necessary procedures.³

The FSA decision changes the assurance picture from the first reporting period beginning on or after 1 January 2029, because it adopts IFRS S1 and S2 for both preparation and assurance and places the duty on the accountancy and auditing profession.⁶

Under CBAM, where embedded emissions are determined on actual emissions, the declarant must have them verified by a verifier accredited under Article 18 on the principles in Annex VI. A declarant may instead use verified information disclosed by an Omani installation registered in the CBAM registry under Article 10. National accreditation bodies accredit the verifiers, taking into account accreditation under Implementing Regulation (EU) 2018/2067.⁵

What an organisation on ESGOS can do

A listed Omani company can find its listing in the directory and claim it from its profile page, or get listed. It can submit its MSX 30-metric disclosure, sustainability report and any third-party assurance statement as evidence, so that the answer it gives under metric G9 is visible alongside the document. Where an organisation produces aluminium, steel, fertilisers, cement or hydrogen for EU customers, a compliance profile lets those importers see the verification status behind the emissions data they need for their declarations, and the exposure check shows how those goods sit against Annex I. The verifiers directory lists accredited verification bodies drawn from national accreditation registers, by standard; verifiers accredited for CBAM are not yet published by the Commission, so the directory does not hold them.

Footnotes

1. MSX ESG Disclosure Guideline, Muscat Stock Exchange. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

2. Sustainable Investments — ESG, Muscat Stock Exchange. ↩

3. Administrative Decision No. 77/2025 issuing the Requirements for Disclosure of Environmental, Social and Governance Practices, Muscat Stock Exchange. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

4. Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, EUR-Lex. ↩

5. Regulation (EU) 2023/956 — consolidated text, EUR-Lex. ↩ ↩² ↩³ ↩⁴

6. Decision No. E/7/2026 On the Adoption of the International Sustainability Disclosure Standards, Financial Services Authority. ↩ ↩² ↩³ ↩⁴ ↩⁵

7. Official Gazette No. 1640, Ministry of Justice and Legal Affairs. ↩

8. Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956, EUR-Lex. ↩