The Securities and Exchange Commission (SEC) has given public companies and significant public-interest capital market operators until October 15, 2026, to submit plans showing how they will prepare for mandatory IFRS sustainability reporting from 2028.
The directive is the latest step in Nigeria’s transition to mandatory sustainability disclosures and will require companies to demonstrate their readiness for IFRS S1 and IFRS S2, the international standards covering sustainability-related financial and climate-related disclosures.
The SEC’s directive was contained in a circular dated September 23, 2026, issued under the Investments and Securities Act (ISA) 2025.
Under the directive, each covered entity must submit an implementation plan detailing its governance arrangements, readiness gaps, reporting systems, internal controls, staff capacity and expected timeline for adopting the standards.
The move effectively puts listed companies and key market infrastructure operators on a formal preparation timetable ahead of the January 1, 2028 commencement of mandatory sustainability reporting for public-interest entities.
What Companies Have to Submit
The implementation plans must cover:
- Board and governance oversight of sustainability reporting;
- An assessment of gaps between existing practices and IFRS S1 and IFRS S2 requirements;
- An implementation roadmap, including timelines for data collection and reporting systems;
- Internal control and assurance arrangements;
- Capacity-building and staff training plans;
- The expected year of the entity’s first sustainability report under the Financial Reporting Council of Nigeria (FRCN) roadmap; and
- Key challenges expected during implementation.
The SEC said it will continue to engage regulated entities and monitor compliance with the prescribed timelines.
Exchanges and Other Market Operators Included
The October 15 deadline extends beyond listed companies to significant public-interest capital market operators whose activities include market infrastructure functions.
These include exchanges, central securities depositories, clearing houses and trade repositories, as well as other operators involved in clearing, settlement, trading and market data functions. The operators must equally indicate when they expect to commence sustainability reporting in line with the FRCN roadmap.
Nigeria adopted the IFRS Sustainability Disclosure Standards in June 2023, becoming the first African country to adopt the standards developed by the International Sustainability Standards Board (ISSB).
IFRS S1 establishes requirements for sustainability-related financial disclosures, while IFRS S2 focuses on climate-related disclosures.
Implementation Timeline
Nigeria’s implementation follows a phased timetable. Voluntary adoption currently applies to entities that are not yet subject to mandatory reporting, while mandatory sustainability reporting for public-interest entities begins for reporting periods starting on or after January 1, 2028 while mandatory reporting for SMEs is scheduled to begin from January 1, 2030.
The latest SEC directive gives the regulator an entity-by-entity view of preparedness ahead of the 2028 deadline, moving sustainability reporting from broad corporate commitments towards specific governance, data and reporting requirements.
For companies, the requirement means sustainability reporting will increasingly become part of financial reporting infrastructure, requiring investment in data systems, controls, governance and assurance well before the mandatory deadline.
