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Guide

The complete guide to FRC sustainability reporting.

Everything the Financial Reporting Council’s framework requires, who it applies to, what a compliant disclosure contains, and how to get from nothing to a filed document.

Framework

IFRS S1 & S2, as adopted

Applies to

Public interest entities

First year

2028

Reports on

A completed financial year

13 min read

Reviewed September 2026

What this guide covers

This is the long version. The compliance section has a shorter explainer; this guide is for the person who has to actually deliver the thing and needs to know the whole shape of it before starting.

It covers who is in scope, what the four disclosure pillars require in detail, which transition reliefs exist and how to use them well, what assurance will test, and a twelve-month sequence that puts the expensive items first.

Part one — establishing that you are in scope

Check the public interest entity definitionNot listing status alone. The category typically covers banks, insurers, pension operators, public sector entities and large unlisted companies meeting size thresholds. Confirm the current definition with the FRC or your auditor rather than inferring it.
Identify every entity you must file forA group may have several entities individually in scope, each needing its own disclosure on its own boundary. Settle this before collecting anything.
Establish your first mandatory reporting periodAligned to your financial year, which for a non-calendar year end may start earlier than you expect.
Check whether the SEC requirement also appliesIf any entity is listed, it reaches you earlier. Both rest on the same standards and the same data — build one disclosure, present it twice.

Part two — what the four pillars require

GovernanceThe body or individual responsible for oversight; how that responsibility is reflected in terms of reference, mandates and policies; how it determines whether appropriate skills and competencies are available; how and how often it is informed; how it considers these matters when overseeing strategy, major transactions and risk management; how it oversees target setting and monitors progress. Management’s role is disclosed too, including whether controls are integrated with other internal functions.
StrategyThe sustainability and climate risks and opportunities that could reasonably be expected to affect your prospects; the time horizons and why those horizons; the current and anticipated effects on your business model and value chain; the effects on strategy and decision-making including transition plans; the effects on financial position, performance and cash flows for the period and expected over the short, medium and long term; and, for climate, the resilience of your strategy.
Risk managementThe processes used to identify, assess, prioritise and monitor these risks — inputs and parameters, whether scenario analysis was used and how, how likelihood and effect are assessed, how these risks are prioritised relative to others, whether the processes changed from the prior period — and how all of it integrates into your overall risk management.
Metrics and targetsGross Scope 1, 2 and 3 emissions in tonnes of CO₂ equivalent measured to the GHG Protocol; the measurement approach, inputs and assumptions; industry-based metrics where relevant; and every target, with its objective, the part of the entity it applies to, the period, the base period, milestones, and performance against it including an analysis of trends.

Governance is the pillar that must start first

Part three — transition reliefs, used well

Climate-only in year oneYou may report only climate-related risks and opportunities in the first annual reporting period, deferring S1’s broader sustainability disclosures. For most Nigerian filers this is the right route — climate is where both the data burden and the scrutiny sit.
No comparatives in year oneThe relief that makes a first disclosure possible without historic data. It also means year two is when your figures start being read as a trend, so a boundary you regret will follow you.
Scope 3 deferred to year twoUse the year to screen all fifteen categories, identify the material ones and start supplier requests. Supplier data has long lead times and a deferred obligation is not a removed one.
Timing relief on simultaneous reportingReliefs exist around publishing at the same time as the financial statements in the first year. Check the current position; the direction of travel is firmly toward simultaneous reporting.

Part four — a twelve-month sequence

Ordered by what is most expensive to recover if skipped.

Months 1–2: boundary and governanceFix the consolidation approach, list entities and sites, get board oversight minuted, name management responsibility, update terms of reference.
Months 1–12: collectElectricity and fuel monthly, per site, with evidence attached at entry. Running from month one is the difference between collecting and reconstructing.
Months 3–6: screen Scope 3 and start requestsSpend analysis, materiality screening across all fifteen categories, supplier requests to your top twenty by spend.
Months 6–9: dry run and engage assuranceProduce a complete disclosure on a year you are not filing. Talk to an assurance provider about what they will test — capacity will be tight in the first mandatory years.

Questions

How long should the final document be?

Long enough to contain the required disclosures and no longer. The standards prescribe contents, not length. Disclosures that run to a hundred pages are usually padding a thin evidence base, and experienced readers recognise it.

Can we publish it separately from the annual report?

In the first year there are timing reliefs. The direction across adopting jurisdictions is toward publication at the same time as, and cross-referenced from, the financial statements — which has practical consequences for your close timetable well before it becomes a hard requirement.

What if we are not ready?

Disclose what you have, state what is missing and why, and set out what you are doing about it. An acknowledged gap with a remediation plan is a far better disclosure than a confident figure you cannot evidence, and it is treated as such.

Who should own this internally?

Sustainability usually owns collection; finance usually ends up owning the control environment and the sign-off, particularly once assurance is involved. Name both early. The failure mode is a disclosure nobody owns until the month before filing.

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 NigeriaFRC NigeriaThe adoption instrument, roadmap and any amendments. Confirm dates and scope here.

IFRS S1 and IFRS S2IFRS Foundation

The Greenhouse Gas Protocol Corporate StandardWorld Resources Institute and WBCSD

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.