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Scope of the mandate
Scope of the mandate

Are you a public interest entity?

The FRC mandate does not stop at listed companies. Public interest entity is a wider category, and a great many companies discover they are inside it later than they should.
Mandate

FRC Nigeria

First year

2028

Includes

Banks, insurers, large unlisted

Test

Public interest, not just listing

6 min read
Reviewed September 2026

What the category is for

The public interest entity concept exists because the people affected by a company’s reporting are not always its shareholders. A deposit money bank holds the public’s savings. An insurer holds their claims. A pension operator holds their retirement. A very large private employer shapes a local economy. In each case a wider group than the owners has a stake in whether the reporting is true.

Regulators therefore apply their strongest reporting and assurance requirements to this category rather than to listing status alone. It is why an unlisted bank can face a heavier reporting burden than a small listed company.

Categories that are commonly missed

Listing status is the obvious test and the one everybody checks. These are the ones companies overlook.

  • Unlisted banks and financial institutionsDeposit-taking and lending institutions are typically caught regardless of whether their shares are traded. Microfinance and mortgage institutions above certain thresholds frequently are too.
  • Insurers and pension operatorsInsurance companies, pension fund administrators and pension fund custodians hold long-dated obligations to the public and are routinely inside the category.
  • Large unlisted companiesSize-based thresholds — commonly expressed in terms of turnover, total assets and employee numbers — bring in substantial private businesses. Family-held groups are a frequent surprise here.
  • Public sector and state-owned enterprisesGovernment business entities and state-owned enterprises are often covered by their own parallel requirements as well as the general framework.
  • Subsidiaries of in-scope groupsA subsidiary may be outside the definition itself while being inside its parent’s reporting boundary. The data obligation reaches you either way, and it usually reaches you with a shorter deadline.
  • Regulated utilities and infrastructure operatorsEntities holding a licence to supply an essential service frequently attract public interest treatment, and may also face sector-specific sustainability reporting from their own regulator.

Thresholds are set in the instrument and can change

What to do if you are near a threshold

Prepare as though you are in. The asymmetry is stark: a company that prepares and turns out to be outside scope has a measured baseline, a governance habit and a head start on its customers’ Scope 3 requests. A company that does not prepare and turns out to be inside scope has to reconstruct a year of data it never collected.

There is also a commercial argument that has nothing to do with the mandate. If you supply a listed company or a bank, their Scope 3 reporting will generate a data request to you on their timetable. Companies that can answer that request quickly win the tender. Companies that cannot answer it at all increasingly do not get asked again.

Not sure which side of the line you are on?

The deadline checker walks four questions — listing status, entity type, size and export exposure — and tells you the mandate most likely to apply, with what to collect first. It takes about a minute and does not require an email to begin.

Questions

We are a subsidiary of a foreign parent that already reports. Are we covered?

Possibly both. Your parent’s consolidated disclosure does not necessarily discharge a Nigerian entity-level obligation, and the two may be measured on different boundaries. Establish early which entity files what — this is a question for your auditor, and getting it wrong is expensive in both directions.

Does being a public interest entity change the assurance requirement?

Generally yes. Public interest entities typically face the strongest assurance expectations, and those expectations are being phased in across adopting jurisdictions. Ask your assurance provider what they will require and when, well before your first mandatory year.

We fell below the threshold this year. Are we out?

Do not assume so. Definitions often include provisions about entities that have been in scope, and in any case a company oscillating around a threshold is better served by a stable reporting process than by starting and stopping.

Check this yourself

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

Financial Reporting Council of Nigeria Act 2011Federal Republic of NigeriaThe statute establishing the FRC and the public interest entity concept in Nigerian law.
Financial Reporting Council of NigeriaFRC NigeriaCurrent definitions, thresholds and any amendments. This is the only place to confirm your status.
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.