Sustainability Report - Nigeria
Nigeria Has Made Sustainability Reporting Mandatory — Your First Deadline May Be 2027
Sustainability reporting is now a legal obligation in Nigeria, not a voluntary best practice. The Financial Reporting Council (FRC) has issued two binding instruments; the Amended 2026 Roadmap and Sustainability Reporting Guideline 1 (SRG 1). Together they adopt the global IFRS sustainability standards (IFRS S1 and S2) and back them with enforcement powers. The Roadmap is the calendar while SRG 1 is the rulebook.
The good news first:
The deadlines are real but workable. The catch is that the first filing falls well before the 2028 start date. For a company with a January financial year, Stage 1 of the FRC Readiness Test is due on 30 September 2027, three months before your financial year begins. The work to get there starts now.
Are you in scope?
The framework applies to Public Interest Entities (PIEs), a deliberately broad category. Many privately held and government-linked businesses are caught for the first time.
When |
Who is caught |
Mandatory from 1 Jan 2028 |
Listed companies; CBN-regulated financial institutions; all public limited companies; holding companies of public or regulated entities; private companies with turnover ≥ ₦30bn; concessions, government licensees, and privatised entities; public-works contractors ≥ ₦1bn; and government bodies (CPSEs). |
Mandatory from 1 Jan 2030 |
SMEs with turnover ≤ ₦500m and total assets ≤ ₦200m (both thresholds must be met). |
An entity that exceeds either SME threshold is treated as a PIE, not an SME.
The dates that matter
Date |
What happens |
16 Feb 2026 |
SRG 1 takes effect; FRC enforcement powers apply. |
23 Feb 2026 |
Amended 2026 Roadmap released and the two together form the binding framework. |
30 Sep 2027 |
Readiness Test Stage 1 filing for Jan 2028 adopters: board resolution, gap analysis, and implementation plan. |
1 Jan 2028 |
Mandatory reporting begins for most entities (PIEs). |
31 Mar 2028 |
Stage 2 filing: Sustainability Disclosures Policy, materiality assessment, and governance evidence. |
30 Jun 2028 |
Stage 3 filing: FRC registration, scenario analysis, risk framework, and sustainability controls (ICSR). |
1 Jan 2030 |
Mandatory reporting begins for SMEs. |
Years 4 – 7 |
External assurance phases in – limited assurance first, reasonable (full) assurance by year 7. |
Deadlines anchor to your own financial year. Stage 1 is always three months before your financial year begins, so non-January year-ends shift accordingly.
Three things that catch most businesses off guard
- Separate controls: sustainability data needs its own internal controls (ICSR), separate from your financial controls. Strong financial controls do not cover it.
- Personal sign-off: a named, FRC-registered manager must personally sign the disclosures, with their registration number. This is personal accountability, not a formality.
- Interim reporting: listed companies must also file interim (quarterly) sustainability disclosures, which means quarterly data collection, and not just an annual report.
What to do now
- Confirm whether you are a PIE. The definition is broader than most expect.
- Get board approval to adopt IFRS S1 and S2 (the foundational Stage 1 document).
- Commission a gap analysis of your governance, data, and registration position.
- Register your entity and sustainability professionals with the FRC early. It takes time.
How we can help
Our dedicated team advises on scope assessment, governance, and policy drafting; the three-stage Readiness Test filings, and disclosure review; and the areas where getting it wrong creates personal liability for directors and regulatory exposure for the entity. The fastest place to start is a confidential PIE Status Assessment, which we can complete within a week.
Not sure whether you are caught or when?
Contact us to arrange a no-obligation PIE status session.
