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Guide

Preparing for the 2028 FRC deadline.

A month-by-month plan for a public interest entity that has not started, working backwards from the filing date — and blunt about what is and is not recoverable.

Target

FRC first mandatory year

Data period

The year before filing

Unrecoverable if missed

Generator logs, governance

Plan length

Twelve months

10 min read

Reviewed September 2026

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.

Generator run logsFrequently kept on paper at the site and discarded. Effectively unrecoverable, and for most Nigerian companies this is the largest emissions source in the inventory.
Board and committee minutes showing oversightCannot be created retrospectively without misrepresenting what happened. This is the one item with an ethical dimension as well as a practical one.
Fuel delivery recordsPartially recoverable from suppliers, rarely at the site-and-period granularity you need, and never quickly.
Electricity billsRecoverable from your DisCo but slowly and incompletely. Budget weeks, not days, and expect gaps.
Supplier engagement for Scope 3Recoverable 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

Confirm scope and boundaryWhich entities are public interest entities, which sites are inside the boundary, which consolidation approach. Written down and agreed with your auditor.
Name the ownerOne named person accountable for the disclosure, with a named board committee holding oversight. Both minuted.
Start collectingElectricity 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.
Get governance onto the agendaA real discussion, properly minuted, with terms of reference updated. This is the item that must start first.

Months 4 to 8 — widening

Screen Scope 3Spend analysis, materiality assessment across all fifteen categories, exclusions documented with reasons while the reasoning is fresh.
Issue supplier requestsTop twenty by spend, asking for specific things — kilowatt-hours and litres, not a questionnaire. Attach the request to a procurement cycle.
Run a scenario analysisAn 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.
Draft the narrative sectionsGovernance and strategy, written while the year is running rather than after it closes.

Months 9 to 12 — closing

Dry run a full disclosureComplete, on a year you are not filing. Every gap found here is found cheaply.
Engage an assurance providerAsk what they will test and what evidence they expect. Provider capacity in the first mandatory years will be tight — book early.
Close the evidence gapsWhatever the dry run surfaced. This is the month the year’s discipline pays off or does not.
Take it to the boardA 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

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 NigeriaFRC NigeriaConfirm the current timetable and scope here rather than relying on any secondary source.

IFRS S1 and IFRS S2 — transition reliefsIFRS Foundation

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.