A sustainability disclosure reports on a completed financial year. That sentence is unremarkable until you work through what it implies.
If your first mandatory reporting year is 2027, the document you file describes what happened during 2027. The meter readings, fuel deliveries and supplier responses it is built from are being generated right now — and are either being captured or being lost.
Which means the filing date is not your deadline. The start of the reporting year is.
Companies that count forward to the filing date arrive at it with no data and exactly one option: reconstruct a year from old invoices, bank statements and the memory of whoever was there.
That reconstruction costs more than the collection would have, takes longer, and produces a visibly weaker evidence trail — which is precisely what an assurance provider looks for. It also produces a first-year figure that becomes your comparative and your target baseline, so a weak reconstruction follows you for three years.
Take your first mandatory filing year, subtract one, align it to your financial year end. That is the period your data has to cover.
If it has already started, do not spend the remaining months reconstructing what you missed. Capture the rest of the year cleanly, disclose the partial-year limitation, and make next year complete. A disclosed gap is a far stronger position than a reconstructed figure nobody can evidence.
A summary of a regulation is not the regulation. These are the primary documents this page is based on.
Four questions, and you get the year you first file, the framework, and what to collect first.
Plain-language explainers of the FRC and SEC rules, ISSB S1 & S2, and what each asks you to disclose.
What a consultant-led reporting cycle costs against an annual licence, in Naira.
