Sustainability reporting deadlines in Nigeria: the dates, and the deadline before them

When do the IFRS sustainability disclosure standards become mandatory in Nigeria?

Public interest entities must apply IFRS S1 and IFRS S2 for accounting periods beginning on or after 1 January 2028, and SMEs from 1 January 2030. Both dates come from the FRC's amended roadmap, released on 23 February 2026.

The roadmap sets four phases:

Is your company a public interest entity?

Probably, if it is listed, regulated, a public limited company, a government licensee, or has annual turnover of ₦30 billion or more. The roadmap uses the FRC Act definition, which is far wider than "listed companies".

The roadmap lists ten categories of public interest entity:

• governments and government organisations
• entities listed on any recognised exchange in Nigeria
• unlisted entities that are regulated
• public limited companies
• private companies that are holding companies of public or regulated entities
• concession entities
• privatised entities in which government keeps an interest
• entities engaged by any tier of government for public works worth ₦1 billion or more a year, paid from public funds
• licensees of government
• any other entity with annual turnover of ₦30 billion or more

An SME, by contrast, has no public accountability and, among other conditions, annual turnover of no more than ₦500 million, or a figure the Corporate Affairs Commission sets. If your company sits between those two definitions, the roadmap does not name a separate date for you. Confirm your category with the FRC rather than assume 2030.

What is the deadline before the deadline?

The FRC readiness test. SRG 1 (2026) makes it mandatory for every reporting entity and splits it into three stages, with the first due three months before your reporting period begins.

The three stages and their documents:

SRG 1 times each stage from "the beginning of the reporting date". We read that as the first day of your first mandatory reporting period. If your adviser reads it differently, ask the FRC before you plan around it.

What are your dates by financial year end?

Your first mandatory period is the first full accounting period that begins on or after 1 January 2028. A company with a March or June year end therefore starts later than a December company, and every date below moves with it.

Readiness stages are worked out from SRG 1 (2026). Publication dates are worked out from the roadmap's timing rules and the NGX filing deadline, explained below. Check every date against your own financial year before you rely on it.

When is the first report actually published?

With your financial statements. The FRC roadmap requires sustainability disclosures to be published at the same time as the related financial statements and to cover the same period.

For a listed company, that ties the report to the NGX filing deadline. Under the NGX Regulation circular of January 2022, listed companies file audited annual financial statements within 90 days of year end, or within 60 days if they chose not to file fourth-quarter interim results.

A December company on the 60-day option reports by 1 March 2029, a month earlier than the table shows. Unlisted companies follow their own financial statements deadline.

The roadmap gives one relief in the first year only: you may publish the sustainability disclosure as a stand-alone report, up to six months after year end. From the second year, it sits inside the annual report, after the Directors' Report and before the financial statements, with an index showing where each disclosure appears.

What did the SEC require in 2026?

The SEC confirmed the FRC dates and asked public companies to start preparing. Its circular of 23 September 2026 told every public company and significant public interest capital market operator to submit an IFRS S1 and S2 implementation plan by 15 October 2026.

That date has passed. The circular itself sets no new reporting date: it states that public companies report for periods beginning on or after 1 January 2028, and SMEs from 1 January 2030. A company that did not submit a plan should speak to the SEC or its advisers about its position.

Why do some sources say 2027 or 2030?

Because they are out of date or wrong. 2030 is the SME date, not a date for every company, and no current FRC or SEC document gives 2027 for listed companies.

Several widely shared posts say reporting becomes mandatory "for all Nigerian entities by 2030". That merges two groups.

Under the roadmap, a company that meets the public interest entity definition starts in 2028, whatever its size. The IFRS Foundation's jurisdictional profile of Nigeria, updated June 2025, gave 2028 for public interest entities before the 2026 amendment, so this date has not moved.

What did move in 2026 is assurance. The June 2025 profile shows limited assurance from the third year of reporting. The amended roadmap pushes the stages later, so check any assurance timeline published before February 2026.

When does assurance start?

Assurance is required from the third year of reporting under the amended roadmap, starting with limited assurance. It moves in stages to reasonable assurance on all sustainability disclosures from the seventh year.

For a December public interest entity whose first year is 2028, the seventh year of reporting is 2034. Scope 3 emissions, transition plans and scenario analysis join the assurance scope later than the other disclosures.

Directors should plan for this from year one. At a board event on 26 November 2025, the FRC's chief executive told directors that climate and sustainability governance is now a core fiduciary responsibility. SRG 1 also requires the disclosure to be signed by the member of management who oversees sustainability reporting, with their FRC number.

What can you leave out of your first report?

In your first annual reporting period, the FRC roadmap lets you report on climate only, leave out Scope 3 emissions, skip comparative figures, publish late as a stand-alone report, and keep an emissions method you already use. You must still report Scope 1 and Scope 2, and SRG 1 asks you to name every relief you use at stage two of the readiness test.

The five reliefs, what each lets you exclude, and when it ends:

What no relief removes: Scope 1 and Scope 2 emissions, with Scope 2 also shown on a location basis; the governance, strategy, risk management, and metrics and targets disclosures for climate; the statement of compliance; and the readiness test itself.

Each relief also pushes work into year two. A company that uses all five reports climate only, without Scope 3 or comparatives, in year one, then reports every material topic, Scope 3 and comparatives in year two. Plan year two's data collection before year one ends.

When should you start collecting data?

At the latest, on the first day of your first mandatory period, because every figure in the first report comes from records created during it. For a December company, that is 1 January 2028.

The roadmap's first-year relief means you do not need comparative figures in your first report. A trial year is still worth running. Collecting 2027 data for a December company tests the process before it counts, gives you a baseline, and leaves time to fix gaps before stage two of the readiness test asks for your materiality assessment.

Start with the records behind your largest emission sources: electricity bills, diesel purchase records, fuel stock readings and generator logs. Our guide to what ESG reporting in Nigeria requires covers the full list.

You can start both now, before any deadline applies.

• Start carbon accounting. Emvert's carbon accounting records grid electricity and generator fuel as separate inputs on Nigerian factors, with the bill or log attached to each figure. A trial year gives you Scope 1 and Scope 2 figures, with their evidence, before the first one counts. SRG 1 recommends calculating with Nigerian emission factors.
• Check your readiness. Our readiness assessment reviews your governance, data, evidence, reporting and assurance, and ends with a written gap analysis and a sequenced plan. Those match two of the three documents stage one of the FRC test asks for, though your board still has to adopt them.

Book a demo: we work out your dates, show which reliefs fit your first year, and run your own data through the calculation.