Deposit money banks are the archetypal public interest entity: you hold the public’s savings, your failure would affect a group far wider than your shareholders, and you are already subject to the most intensive reporting and supervisory regime in the Nigerian economy.
That means the FRC sustainability framework reaches you whether or not your shares are listed, and it means the assurance expectations attached to it will be at the stronger end. If you are also listed, the SEC requirement reaches you earlier.
The practical reading: assume you are in scope, assume assurance, and plan against the reporting year rather than the filing date.
Smaller than the loan book and considerably more measurable. This is the part you can finish in a first cycle.
You are not starting from zero on sustainability. The Nigerian Sustainable Banking Principles have required environmental and social risk management in lending for some years, and most banks have an E&S function, a policy framework and some form of annual sustainability reporting.
That infrastructure is genuinely useful — particularly the governance and the E&S screening in credit — but it is not the same as an ISSB-based disclosure. The new requirement is more prescriptive about the basis of preparation, requires quantified emissions across all three scopes, and expects sustainability information to connect to the financial statements.
Expect to extend rather than replace. The E&S data you already gather on borrowers is, notably, the beginning of a financed emissions dataset.
Your reporting boundary should follow your consolidation approach, and you should state which you have used. Subsidiaries inside the boundary contribute their operational emissions; entities you hold as investments rather than consolidate fall into financed emissions instead. Getting this wrong double counts or under counts, so settle it before you collect.
Minimally. A branch manager’s view should be one screen with a meter reading, a fuel figure and a place to attach the bill. If it takes longer than the email they currently receive, adoption fails — that is a design constraint, not an aspiration.
Fuel purchased by a contractor for equipment you control is still your Scope 1. Your contract should give you the consumption data; if it does not, add it at renewal. This is a common and easily-fixed gap.
A summary of a regulation is not the regulation. These are the primary documents this page is based on.
Four questions, and you get the year you first file, the framework, and what to collect first.
Plain-language explainers of the FRC and SEC rules, ISSB S1 & S2, and what each asks you to disclose.
What a consultant-led reporting cycle costs against an annual licence, in Naira.
