The FRC is the body that sets financial reporting standards in Nigeria and oversees the accounting, auditing and actuarial professions. It is the same institution that brought IFRS into Nigerian financial reporting, and it has taken the same route with sustainability: rather than write a national standard from scratch, it has adopted the ISSB’s IFRS S1 and IFRS S2.
That decision matters more than it first appears. It means a Nigerian disclosure is structurally the same document as a South African, Malaysian or British one — the same four pillars, the same notion of materiality, the same expectation that figures are prepared on a stated basis. For a company raising capital internationally, that comparability is the point.
It also means the detail of what you must disclose is set out in the ISSB standards themselves, not in a Nigerian rulebook. The FRC’s adoption instrument tells you who must apply them and from when; the standards tell you what to say.
Every requirement in IFRS S1 and S2 sits under one of these four headings. If you know them, you can read any framework on this site.
The FRC mandate is framed around public interest entities rather than listed companies. That category is deliberately broad: it captures organisations whose failure or misreporting would affect a wide group of people beyond their own shareholders.
In practice that typically includes deposit money banks, insurers, pension fund administrators and custodians, and large unlisted companies that meet size thresholds — as well as listed companies, who are also caught by the SEC requirement on an earlier timetable.
If you are close to a threshold, the practical answer is to prepare as though you are in scope. The work of building a baseline is the same either way, it becomes materially more expensive if started late, and a company that discovers it is a public interest entity six months before its first mandatory year has a genuine problem.
IFRS S1 and S2 include reliefs for first-time reporters. They are there to make a first cycle achievable, not to make it optional.
If you are a listed company, you are likely to be caught by both. The SEC requirement reaches listed companies first; the FRC framework applies to the wider public interest entity population on a later timetable.
They are not two separate reporting projects. Both rest on the same underlying standards and the same underlying data. A company that builds one properly structured disclosure — correct boundary, traceable figures, stated basis of preparation — satisfies both, with the differences handled as presentation rather than as separate measurement exercises.
The failure mode to avoid is running them as two workstreams with two datasets. That is how a company ends up publishing two different numbers for the same year, which is a far worse outcome than being late.
The order matters. Each step makes the next one cheaper.
Not in your first mandatory year — the transition relief removes the comparative requirement. From year two onward comparatives are required, and if you later revise a figure or change a method you will need to explain the restatement. That is why recording which emission factor and version produced each number matters from the first day, not from the first restatement.
The ISSB standards use financial materiality: information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports. That is a narrower test than the impact materiality GRI uses, and the distinction matters when you are deciding what to leave out.
Often, but independence rules and local requirements apply, and some jurisdictions restrict it. Ask early. Assurance providers have finite capacity and the first mandatory years will compress demand considerably.
Consequences are set by the regulator and can include sanctions, but in our experience the more immediate cost is commercial: a missing or qualified disclosure becomes a question in every lender review, capital raise and large customer tender you enter afterwards.
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.
