You are accountable for a filing built from data you do not own, produced by people who do not report to you, on a deadline you cannot move. Nothing about that is unusual for a company secretary — it is most of the job — but sustainability reporting makes it sharper than usual for three reasons.
First, the data is genuinely scattered. Electricity consumption sits with facilities, fuel with operations, supplier information with procurement, and none of them have historically been asked to produce it on a reporting timetable. Second, the requirement is new enough that there is no institutional muscle memory: nobody in the business has done this eleven times before. Third, the failure is public. A late or qualified sustainability disclosure is visible to the market in a way that a late internal report is not.
What you need is not a sustainability platform. It is a compliance instrument that happens to calculate emissions: something that tells you what is outstanding, who owns it, and whether the thing you are about to file is complete.
Which mandate applies to each legal entity you act for, the first mandatory reporting year, and what is outstanding against it right now.
Disclosures assembled into FRC and SEC Nigeria structures aligned to IFRS S1 and S2, so review is review rather than reformatting.
A list of every required disclosure that is unanswered or lacks a stated reason for omission — before it reaches an agenda, not after.
Every site, supplier and data item has a named owner and a status. Chasing becomes a list rather than a series of remembered conversations.
Who approved which section of which version, and when. The approval chain is part of the record rather than an email thread.
When a director asks where a figure came from during the meeting, you can open it four levels down to the document it came from.
Of the four pillars a disclosure is built on, governance is the one that lands squarely in your remit — and it is the one most first-time reporters leave until last, which is exactly backwards.
The requirement is to describe the governance processes, controls and procedures used to oversee sustainability-related risks and opportunities: which body holds it, how that is reflected in terms of reference, how it satisfies itself the right skills are available, how often it is informed, and how it oversees target-setting and monitors progress.
That is a description of what actually happened, which means it has to have happened. A governance disclosure cannot be written retrospectively without misrepresenting the record — and unlike an emissions figure, there is no estimation method that rescues you.
The practical consequence: get the item onto a board or committee agenda in the year before your first mandatory year, minute it properly, and update terms of reference. That is a small amount of work done early, and an impossible amount of work done late.
Yes — each entity has its own boundary, reporting years and status, under one account. Where entities consolidate, the group disclosure draws from the same underlying data rather than from separately keyed figures, which is what prevents a subsidiary and its parent publishing different numbers for the same site.
No. Filing remains the company’s act, through the channel the regulator specifies. Be wary of any vendor claiming otherwise. What is removed is the reformatting, chasing and reconciliation that sit before filing.
The change is recorded with who made it and when, and any sign-off attached to the superseded version is visibly attached to that version rather than silently carried forward. If the change is material you will see it; if it is not, you have the record either way.
Yes, with a scoped role. An adviser preparing your disclosure, or an assurance provider testing it, can be given access limited to the reporting year in question and removed when the engagement ends.
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.
