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International standards
International standards

IFRS S1 and S2, and what they mean in Nigeria.

Nigeria’s requirements are built on the ISSB’s two standards. Understanding them is the fastest route to understanding everything you will be asked to disclose — here and in every other adopting jurisdiction.
S1

General sustainability disclosures

S2

Climate-related disclosures

Issued

June 2023

Structure

Four pillars

10 min read
Reviewed September 2026

Where these came from

Before 2023, a company wanting to report on sustainability chose from an uncomfortable number of overlapping frameworks: TCFD, SASB, CDSB, the Integrated Reporting framework, GRI, and a long tail of sector schemes. Investors complained, reasonably, that comparing two companies was nearly impossible.

The IFRS Foundation — the body behind the accounting standards most of the world uses — created the International Sustainability Standards Board to consolidate that landscape. In June 2023 the ISSB issued its first two standards: IFRS S1 and IFRS S2. They absorbed the TCFD recommendations and the SASB standards, and TCFD itself was disbanded shortly afterwards with monitoring responsibility transferred to the IFRS Foundation.

This is why Nigeria’s route was adoption rather than authorship. The whole value of the standards is that they are the same everywhere; a national variant would have thrown away the comparability that justifies them.

What each standard covers

IFRS S1 IFRS S2
Subject All sustainability-related risks and opportunities that could reasonably be expected to affect your prospects Climate-related risks and opportunities specifically
Role Sets the general requirements — how to report, what counts as material, where the information sits Sets the topic-specific requirements, including greenhouse gas emissions
Notable requirement Connected information: sustainability data must connect to the financial statements rather than sit apart from them Scope 1, 2 and 3 emissions measured to the GHG Protocol, plus climate resilience assessment
First-year relief May be deferred so year one reports climate only Scope 3 may be deferred to year two

The four pillars, in the order you will build them

  1. GovernanceWhich body oversees sustainability-related risks and opportunities, how that responsibility is reflected in terms of reference, how it satisfies itself that appropriate skills are available, how often it is informed, how it considers these matters when overseeing strategy and major transactions, and how it oversees target-setting. Management’s role is disclosed too, including whether it uses controls integrated with other internal functions.
  2. StrategyThe risks and opportunities themselves, the time horizons over which they could reasonably occur, their current and anticipated effects on your business model and value chain, their effects on strategy and decision-making, their effects on financial position, performance and cash flows in the current period and over the short, medium and long term, and — for climate — the resilience of your strategy.
  3. Risk managementThe processes used to identify, assess, prioritise and monitor these risks, including inputs, parameters, scenario analysis where used, how you assess likelihood and effect, how you prioritise relative to other risks, whether the processes changed from the prior period, and how they are integrated into overall risk management.
  4. Metrics and targetsCross-industry metric categories including gross Scope 1, 2 and 3 emissions in tonnes of CO₂ equivalent, the measurement approach, inputs and assumptions, any industry-based metrics, and every target you have set or are required to meet — with the objective, the part of the entity it applies to, the period, the base period, milestones, and performance against it.

Materiality: the distinction that decides what you leave out

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 — existing and potential investors, lenders and other creditors — make on the basis of those reports.

That is a narrower test than the one GRI applies, and narrower than the double materiality used in the European CSRD. It does not ask whether your operations affect the world; it asks whether a sustainability matter could affect your cash flows, your access to finance or your cost of capital.

In practice the difference is smaller than it sounds, because over any reasonable time horizon the two converge: a company causing serious environmental harm is a company facing regulatory, litigation and licence risk. But when you are deciding whether a particular disclosure is required, the ISSB test is the one to apply — and applying the wrong test produces a report that is either bloated or incomplete.

Connected information is the underrated requirement

What scenario analysis actually requires

The climate resilience requirement in S2 is where first-time reporters most often over-engineer. The standard asks for an approach commensurate with your circumstances.

  • It is not necessarily quantitative modellingThe standard permits a qualitative approach where that is commensurate with your circumstances and available skills, capabilities and resources. A mid-sized Nigerian manufacturer is not expected to commission the analysis a global insurer would.
  • Disclose the method, not just the conclusionWhatever you do, you must say which inputs you used, which scenarios and why, whether they were associated with a climate-related transition, and over what time horizons.
  • It should inform somethingAn assurance provider will ask what changed as a result. Scenario analysis that sits in an appendix and affects no decision reads as an exercise, because it is one.
  • Physical and transition risk are both in scopeFor Nigerian operations, physical risk — flooding, heat, water stress, and the effect of both on supply chains — is frequently more material than transition risk, and is more often under-analysed.

Questions

Do we have to report Scope 3 from the first year?

No. IFRS S2 provides relief from disclosing Scope 3 in the first annual reporting period. That is a year to identify which of the fifteen categories are material and start collecting, not a year to ignore it — supplier data has long lead times and year two arrives quickly.

What global warming potential values do we use?

The standard requires disclosure of the GWP values used and their source. Most reporters use the values from the most recent IPCC assessment available at the reporting date. What matters for assurance is that you state which you used and apply them consistently.

Does this replace our GRI report?

Not necessarily — they answer different questions for different audiences. Many companies file to the ISSB standards and continue reporting against GRI for stakeholders interested in impact. The efficiency is in collecting once and mapping twice, which is a data architecture decision rather than a reporting one.

How prescriptive is the standard about format?

Less than you might expect about layout, and considerably more than you might expect about content. There is no mandated template, but there is a defined set of disclosures, and omitting one requires you to say so and why. The IFRS Foundation also publishes a digital taxonomy for tagging, which is where structured filing comes in.

Check this yourself

A summary of a regulation is not the regulation. These are the primary documents this page is based on.

IFRS S1 General Requirements for Disclosure of Sustainability-related Financial InformationIFRS FoundationThe standard itself. The Basis for Conclusions that accompanies it is unusually readable and explains why several of the harder requirements exist.
The Greenhouse Gas Protocol Corporate StandardWorld Resources Institute and WBCSDIFRS S2 requires emissions to be measured in accordance with this standard, so it is effectively part of the requirement.
SEC 2027 · 105 days

File with confidence, before the deadline files you.

Companies that start now collect a full clean year before they ever have to file. Companies that start late reconstruct one — and that is the expensive part.

Check your deadline

Four questions, and you get the year you first file, the framework, and what to collect first.

Read the requirement

Plain-language explainers of the FRC and SEC rules, ISSB S1 & S2, and what each asks you to disclose.

Compare the cost

What a consultant-led reporting cycle costs against an annual licence, in Naira.