Work backwards, not forwards
The instinct is to count forward from today to the filing date and divide the work evenly. That produces a plan that fails, because the work is not evenly distributed and because some of it has a hard start date rather than a hard end date.
Work backwards instead. Your disclosure reports on a completed financial year.
That year has to be collected as it happens. Therefore the binding constraint is not the filing date — it is the start of the reporting year, and everything that must be in place by then.
Two things must be in place by then and cannot be added later: activity data collection, and governance. Everything else — calculation, drafting, review — can be done afterwards, and is comparatively cheap.
What cannot be recovered, ranked
If you read nothing else, read this. These are the items where starting late means paying multiples or misrepresenting the record.
- 01
Generator run logs
Frequently kept on paper at the site and discarded. Effectively unrecoverable, and for most Nigerian companies this is the largest emissions source in the inventory.
- 02
Board and committee minutes showing oversight
Cannot be created retrospectively without misrepresenting what happened. This is the one item with an ethical dimension as well as a practical one.
- 03
Fuel delivery records
Partially recoverable from suppliers, rarely at the site-and-period granularity you need, and never quickly.
- 04
Electricity bills
Recoverable from your DisCo but slowly and incompletely. Budget weeks, not days, and expect gaps.
- 05
Supplier engagement for Scope 3
Recoverable in principle but the lead times are long. A supplier who has never been asked takes months to answer the first time.
Months 1 to 3 — the foundations
- 01
Confirm scope and boundary
Which entities are public interest entities, which sites are inside the boundary, which consolidation approach. Written down and agreed with your auditor.
- 02
Name the owner
One named person accountable for the disclosure, with a named board committee holding oversight. Both minuted.
- 03
Start collecting
Electricity and fuel, every site, monthly, with evidence attached. Do not wait for a perfect system — a shared folder and a discipline beats a system that arrives in month eight.
- 04
Get governance onto the agenda
A real discussion, properly minuted, with terms of reference updated. This is the item that must start first.
Months 4 to 8 — widening
- 01
Screen Scope 3
Spend analysis, materiality assessment across all fifteen categories, exclusions documented with reasons while the reasoning is fresh.
- 02
Issue supplier requests
Top twenty by spend, asking for specific things — kilowatt-hours and litres, not a questionnaire. Attach the request to a procurement cycle.
- 03
Run a scenario analysis
An approach commensurate with your circumstances. Qualitative is permitted where that is appropriate; what matters is that the method is disclosed and that it informs something.
- 04
Draft the narrative sections
Governance and strategy, written while the year is running rather than after it closes.
Months 9 to 12 — closing
- 01
Dry run a full disclosure
Complete, on a year you are not filing. Every gap found here is found cheaply.
- 02
Engage an assurance provider
Ask what they will test and what evidence they expect. Provider capacity in the first mandatory years will be tight — book early.
- 03
Close the evidence gaps
Whatever the dry run surfaced. This is the month the year's discipline pays off or does not.
- 04
Take it to the board
A complete draft, a cycle before you have to. The questions directors ask are the questions the market will ask.
If your reporting year has already started
Do not spend the remaining months reconstructing what you missed. Capture the remainder of the year cleanly, disclose the partial-year limitation explicitly, and put the effort into making next year complete. A disclosed gap is a far better position than a reconstructed figure you cannot evidence.
Questions
We have eighteen months. Is that enough?
Comfortably, if you start collecting now. Eighteen months gives you a full reporting year plus a run-up, which is the ideal position. The companies that struggle are not the ones with less time — they are the ones who spent the time planning rather than collecting.
Can we buy our way out of a late start?
Partially and expensively. Consultants can reconstruct what is reconstructible, and that will cost multiples of what collection would have. What money cannot buy is a generator log that was thrown away or a board minute that was never written.
What if the deadline moves?
Adoption timetables have shifted in several jurisdictions and it is possible. What does not move is the data: a company that has been collecting for two years is ready whenever it lands, and is equally protected against the date being brought forward.
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
FRC Nigeria
Confirm the current timetable and scope here rather than relying on any secondary source.
- IFRS S1 and IFRS S2 — transition reliefs
IFRS Foundation
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