Implementation Of The
IFRS Sustainability Disclosure Standards In Nigeria Published: September 23, 2026

CIRCULAR TO ALL PUBLIC COMPANIES AND SIGNIFICANT PUBLIC INTEREST CAPITAL MARKET OPERATORS

Pursuant to its powers under the Investments and Securities Act (ISA) 2025, the Securities and Exchange Commission ("the Commission") wishes to draw the attention of all Public Companies and Significant Public Interest Capital Market Operators to Nigeria's adoption of the IFRS Sustainability Disclosure Standards ("IFRS S1 – General Requirements for Disclosure of Sustainability-related Financial Information" and "IFRS S2 – Climate-related Disclosures") as part of the Federal Government's commitment to strengthening sustainability reporting and promoting transparent, comparable, and decision-useful sustainability-related financial disclosures.

Following Nigeria's commitment to adopt the IFRS Sustainability Disclosure Standards, the Financial Reporting Council of Nigeria (FRCN), in collaboration with relevant stakeholders, including the Commission, developed the Roadmap for the Adoption of IFRS Sustainability Disclosure Standards in Nigeria to facilitate the phased implementation of the Standards across reporting entities in the country.

The Roadmap report provides for a phased implementation comprising:

• Early Adoption – entities were encouraged to voluntarily adopt the Standards for accounting periods ending on or before December 31, 2023, ahead of the Standards’ effective date;
• Voluntary Adoption – entities not yet subject to mandatory reporting may voluntarily adopt the Standards for accounting periods beginning on or after January 1, 2024 through periods ending on or before December 31, 2027; and
• Mandatory Adoption – Public Interest Entities (including all Public Companies and Significant Public Interest Capital Market Operators) are required to prepare sustainability-related financial disclosures in accordance with IFRS S1 and IFRS S2 for accounting periods beginning on or after January 1, 2028. Small and Medium-sized Entities (SMEs) will be subject to mandatory adoption for accounting periods beginning on or after January 1, 2030.

Accordingly, all Public Companies and Significant Public Interest Capital Market Operators are required to commence preparations for sustainability reporting in accordance with the IFRS Sustainability Disclosure Standards and the implementation timelines set out above, as prescribed in the FRCN Roadmap.

To enable the Commission to monitor the preparedness of regulated entities and facilitate a smooth transition to mandatory sustainability reporting, every Public Company and Significant Public Interest Capital Market Operator is hereby directed to submit to the Commission, on or before 15 October 2026, its Implementation Plan for adopting the IFRS Sustainability Disclosure Standards, together with any challenges anticipated in the implementation process.

The Implementation Plan should, at a minimum, address the following:

1. Governance arrangements for sustainability reporting, including Board oversight;
2. Gap assessment against the requirements of IFRS S1 and IFRS S2;
3. Implementation roadmap and timelines;
4. Data collection and reporting systems;
5. Internal control and assurance arrangements;
6. Capacity building and training plans;
7. Expected year of first sustainability reporting in accordance with the FRCN Roadmap; and
8. Key implementation challenges.

The Commission will continue to engage with regulated entities and monitor compliance with the implementation timelines as part of its oversight of financial reporting and corporate governance practices in the Nigerian capital market.

The Significant Public Interest Capital Market Operators are the entities that facilitate clearing, settlement, trading or data functions in the capital market. This includes but is not restricted to all exchanges, central securities depositories, clearing houses and trade repositories.

Please be guided accordingly.

Signed:

Management