BAHRAIN Law and Practice Contributed by: Noor Radhi, Fatima Alali, Saifuddin Mahmood and Hasan Sanad, Hassan Radhi & Associates
Generally, companies make voluntary contributions to the environment as part of their social responsibility. The CBB issued the ESG Module in November 2023, which requires listed companies and CBB licensees to submit an ESG report to the CBB on an annual basis. 7.2 ESG Developments No material shift has been noted in Bahrain in the con - text of the current global political climate.
The most significant practical development in 2025 was the “General Policy for the Use of Artificial Intel - ligence” of the Information & eGovernment Authority (iGA), which sets out internal government principles and pillars, and allocates roles and responsibilities for AI use across government entities. In practice, AI oversight is usually handled through the existing governance structure rather than through a dedicated AI committee. The board typically retains oversight through its ordinary governance processes, while management remains responsible for implemen - tation and day-to-day use. The risk, compliance and internal audit functions generally support this, in line with the entity’s broader risk and controls framework. 8.3 Liability Exposures Arising From AI Use Please see the overview in 8.1 Board Oversight of AI . As Bahrain does not currently have a single AI-specific law, the board and officers typically face AI-related liability exposure under existing legal and regulatory regimes, depending on the AI use case and the nature of the harm. In broad terms, the key issues typically involve per - sonal data and privacy, cybersecurity, misleading statements or confidentiality breaches. Enforcement will depend on the underlying regime and the sector, and may include action by the relevant regulator or authority, as well as civil or criminal proceedings in some cases. 8.4 Key Disclosure Requirements for AI Use Please see the overview in 8.1 Board Oversight of AI . There is no single Bahrain-wide AI-specific disclosure requirement obliging companies to describe their AI strategy, governance, risks, incidents or controls in their reports. In practice, any disclosure obligation is usually derived from existing requirements pertaining to AI use or AI- related incidents, including sector-specific expecta - tions for regulated entities. Separately, government entities may have internal reporting and documenta - tion expectations under the iGA AI policy and related procedures, even in the absence of a nationwide AI disclosure framework.
8. Artificial Intelligence 8.1 Board Oversight of AI
Bahrain does not currently have a dedicated AI law setting out AI-specific board composition require - ments or committee mandates, nor does it have a standalone AI governance regime. In practice, AI oversight is typically addressed through existing governance frameworks. For regulated enti - ties, particularly CBB-regulated financial institutions, AI-related oversight generally falls within the estab - lished corporate governance, risk management and internal controls expectations under the CBB Rule - book. For other entities, the primary constraints are the generally applicable legal regimes that AI use can involve – most commonly personal data protection, cybersecurity and IP. Additionally, certain public-sector entities are subject to internal government guidance on AI use, including the Information and eGovernment Authority policy and related procedures. This guidance sets out principles, roles and accountability for government AI initiatives. 8.2 AI Use-Related Risks Please see the overview in 8.1 Board Oversight of AI . While Bahrain does not currently have a single, comprehensive AI governance framework, AI-related risks are typically managed through existing regula - tory regimes and the internal policies and guidelines of the entity in question.
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