SEC issues deadline for public companies to submit IFRS sustainability reporting plans

Nigeria’s Securities and Exchange Commission (SEC) has given public companies and significant public interest capital market operators until October 15, 2026, to submit plans for adopting the IFRS Sustainability Disclosure Standards.

The directive was contained in a circular dated September 23, 2026, issued under the Investments and Securities Act (ISA) 2025.

The mandatory sustainability reporting for public interest entities is scheduled to begin on January 1, 2028.

SEC demands IFRS readiness plans

The SEC is requiring each covered entity to submit an implementation plan outlining how it intends to adopt IFRS S1 and IFRS S2, as well as the challenges it expects to face during implementation.

• The plans are expected to show how companies and market infrastructure operators will prepare for the mandatory reporting regime, leaving roughly 15 months between the October 15 submission deadline and the January 1, 2028 commencement date.
• Governance arrangements for sustainability reporting, including Board oversight.
• A gap assessment against the requirements of IFRS S1 and IFRS S2.
• An implementation roadmap and timelines, including data collection and reporting systems.
• Internal control and assurance arrangements, capacity-building and training plans.
• The expected year of first sustainability reporting under the Financial Reporting Council of Nigeria (FRCN) Roadmap, and key implementation challenges.

The SEC said it will continue engaging regulated entities and monitoring compliance with the timelines as part of its oversight of financial reporting and corporate governance.

Nigeria’s IFRS sustainability roadmap

The SEC’s circular relies on the FRCN’s roadmap for adopting the standards, which provides for a phased transition from voluntary to mandatory sustainability reporting.

• The International Sustainability Standards Board (ISSB) launched IFRS S1, covering sustainability-related financial information, and IFRS S2, covering climate-related disclosures, in June 2023.
• Nigeria adopted the IFRS Sustainability Disclosure Standards that same month, becoming the first African country to do so.
• Early adoption was encouraged for entities reporting for periods ending on or before December 31, 2023.
• Voluntary adoption applies to entities not yet subject to mandatory reporting for periods beginning on or after January 1, 2024, through periods ending on or before December 31, 2027.
• Mandatory reporting for public interest entities applies to periods beginning on or after January 1, 2028.
• Mandatory reporting for SMEs applies to periods beginning on or after January 1, 2030.

The roadmap for mandatory reporting by public interest entities by 2028 was launched with NGX Group, the FRC and the ISSB. The Nigerian Stock Exchange, now NGX, had also released its own sustainability disclosure guidelines in 2019.

Companies face uneven ESG readiness

Readiness for the sustainability reporting requirements has been uneven across sectors, as Nairametrics had earlier reported.

• Nairametrics reported in March 2026 that banks were stepping up ESG compliance ahead of the 2028 deadline while insurers lagged, with some industry leaders still lacking a basic understanding of sustainability concepts.
• The SEC’s plan requirement is the first time the regulator has asked each company for its own preparedness plan and expected challenges.
• The requirement is intended to show how prepared companies are ahead of the mandatory reporting date.
• When the FRCN roadmap was unveiled, Chief Executive Mr Rabiu Olowo said the regulator “will not tolerate greenwashing” in sustainability reporting by entities.

The SEC’s latest requirement therefore places greater emphasis on individual company preparedness ahead of the 2028 mandatory reporting deadline.

Who must submit sustainability plans

The October 15 deadline covers both listed companies and significant public interest capital market operators, including entities that facilitate clearing, settlement, trading or data functions in the market.

This means market infrastructure providers face the same submission deadline as listed issuers under the SEC directive.

The covered market infrastructure operators include, but are not limited to:

• All exchanges.
• Central securities depositories.
• Clearing houses.
• Trade repositories.

The plans must also state the expected year of first sustainability reporting, tied to the FRCN Roadmap.