Nigeria was the first country in Africa to adopt the IFRS Sustainability Disclosure Standards, signing up to IFRS S1 and IFRS S2 in June 2023, the same month the International Sustainability Standards Board published them. For a while that felt like a distant policy story, but the timeline is now close enough that boards and finance teams are being asked to show their hand.
On 23 September 2026 the Securities and Exchange Commission issued a circular asking listed companies and significant public interest capital market operators, including exchanges, clearing houses, central securities depositories and trade repositories, to submit their plans for adopting the standards by 15 October 2026. Under the Financial Reporting Council of Nigeria roadmap, reporting becomes mandatory for public interest entities for accounting periods beginning on or after 1 January 2028, with small and medium-sized enterprises following from 1 January 2030.
What the two standards ask for
IFRS S1 sets out the general requirements for disclosing sustainability-related risks and opportunities that could reasonably be expected to affect a company's cash flows, its access to finance or its cost of capital. IFRS S2 focuses on climate, and asks companies to explain how climate risk is governed, how it shapes their strategy, how it is identified and managed, and which metrics and targets they use to track it, including Scope 1 and Scope 2 greenhouse gas emissions and, where material, Scope 3 emissions from across the value chain.
The SEC wants each company's implementation plan to cover board oversight, a gap assessment against both standards, a roadmap for data collection and reporting systems, internal controls and assurance, training, the year it expects to report for the first time and the challenges it anticipates. That gives a fair picture of the work involved, and most of it sits in the underlying data rather than in the report itself.
Why this reaches beyond listed companies
It would be easy for a private business to read this as a matter for the Nigerian Exchange and the big banks, and for now the legal obligation does sit with public interest entities. In practice the effect travels down the supply chain much sooner. A listed manufacturer or retailer that has to estimate its Scope 3 emissions will need figures from the companies that transport its goods, supply its packaging and maintain its fleet, and specialists estimate that building that kind of supplier data can take 18 to 24 months. If your business is one of those suppliers, the request for information is likely to arrive well before 2030.
The Climate Change Act 2021 already expects companies with 50 or more employees, whether public or private, to take measures on emissions and to designate someone responsible for climate change matters. The Act and the new reporting standards point in the same direction, and a business that starts collecting reliable data now will find both much easier to meet.
The timeline is not completely settled
There has been some uncertainty about dates. At a conference in July 2026 the SEC Director-General spoke of large public interest entities reporting from 2027, a step that does not appear in the FRC roadmap, which keeps a single mandatory start of 1 January 2028. The September circular refers companies back to the FRC roadmap, which suggests 2028 is the date to plan around, although anyone close to the line would be wise to prepare as if the earlier date could apply. The FRC roadmap also expects companies aiming for the 2028 start to file a readiness submission, with a board resolution, gap analysis and implementation plan, by 30 September 2027.
Where to start
For most organisations the hardest part is knowing their own numbers rather than writing the disclosure. Fuel and electricity use, vehicle mileage, generator hours and supplier information are often scattered across departments or kept on paper, and pulling them together into something an auditor would accept takes time. A sensible first step is a gap assessment that maps what the standards ask for against the data you already hold, followed by a plan to close those gaps over the next few reporting cycles, with someone at board level clearly responsible for it.
At SMG we work with organisations on sustainability data, emissions measurement and reporting, with particular experience in transport and logistics, where fuel and fleet data make up a large share of a company's footprint. If you would like to talk through where your business stands, get in touch through our contact page.
Sources: Securities and Exchange Commission Nigeria, circular of 23 September 2026; Financial Reporting Council of Nigeria, Roadmap Report for the Adoption of IFRS Sustainability Disclosure Standards in Nigeria (amended 2026); Climate Change Act 2021.