IFRS S1 and S2 Adoption in Nigeria: the FRC Roadmap and Readiness Submissions

A global standard does not bind a company until a country puts it into law or listing rules, and each country decides who must apply it and when.

Nigeria’s Financial Reporting Council announced its intention to adopt the International Sustainability Standards Board (ISSB) standards early and has published a roadmap that moves entities from voluntary reporting to mandatory reporting in stages, with a readiness test that each entity must pass by submitting a set of documents on a timetable measured from the start of its reporting period.

This topic covers the roadmap and its phases, who is covered, the documents and timelines in the readiness assessment, the assurance timetable, the role of the Securities and Exchange Commission and the Nigerian Exchange, and how an entity should prepare. The next topic starts the syllabus area on ethics, current issues and technology.

The roadmap is a topical subject for a written question on sustainability. The dates have changed since the first roadmap, so this page states the position as at 5 November 2026 and notes that the study material gives different dates.

In the diets reviewed, the sustainability questions (November Diet, 2025, Question 6 and May Diet, 2026, Question 6) tested the features of sustainability reporting, the ISSB and the concepts in International Financial Reporting Standard (IFRS) S1 and not the roadmap dates. Read the International Sustainability Standards Board and the first sustainability disclosure standard first.

The Nigerian roadmap

The Financial Reporting Council of Nigeria (FRC) announced Nigeria’s intention to adopt IFRS S1 and IFRS S2 early, and its Adoption Readiness Working Group published a roadmap in 2024. After the experience of early adopters the FRC issued an amended roadmap and the first Sustainability Reporting Guideline (Sustainability Reporting Guideline (SRG) 1) in February 2026. The phases are:

• Phase 1, early adoption: for periods ending on or before 31 December 2023, for entities that chose to apply the standards early, often multinationals or entities with strong environmental, social and governance (ESG) frameworks. They had to submit readiness documents and follow assurance protocols.
• Phase 2, voluntary adoption: from periods beginning on or after 1 January 2024 to periods ending on or before 31 December 2027. Entities build capacity, assess gaps and test their disclosures.
• Phase 3, mandatory adoption: for periods beginning on or after 1 January 2028, mandatory for public interest entities, as defined in the Financial Reporting Council of Nigeria Act 2011 (as amended) and including listed entities. Small and medium-sized entities follow, from 2030.
• Government and public sector entities: the dates are to be communicated later by the FRC and the public financial management institutions, and are likely to follow the developments of the International Public Sector Accounting Standards Board.

Entities that adopt voluntarily are called voluntary adopters, and those that have elected to apply the standards when they become mandatory are mandatory adopters. The roadmap lets regulators, preparers and auditors build capacity and put training and assurance in place before compliance is compulsory.

The Securities and Exchange Commission has drawn the attention of public companies and significant public interest capital market operators to the roadmap and told them to begin preparing for sustainability reporting under the IFRS Sustainability Disclosure Standards in line with the timelines (a circular reported in September 2026). The Nigerian Exchange’s Sustainability Disclosure Guidelines (see the earlier topic) continue to apply to its listed companies.

The readiness test: documents and timelines

An entity that intends to adopt the standards must pass a structured readiness assessment by submitting documents to the FRC within the timelines measured from the start of its first reporting period under the standards.

At least three months before the beginning of the reporting period

• A board resolution approving the adoption of the IFRS Sustainability Disclosure Standards (board-level commitment and accountability).
• A gap analysis report: the differences between current ESG reporting and the requirements of IFRS S1 and S2, the data, people and control systems needed.
• An implementation plan: steps, timelines, responsibilities, resources, training, systems and stakeholder engagement.

Not more than three months after the beginning of the reporting period

• The sustainability disclosure policies: the principles, processes and methods.
• The transitional reliefs that the entity will use in the first period.
• An enterprise risk management and sustainability framework that integrates ESG risks into overall risk management.
• Evidence of board approval of the disclosure policies, and of the risk management and sustainability framework.
• Evidence of sustainability and ESG training for the board, management and preparers by accredited providers.

Not more than six months after the beginning of the reporting period

• Evidence of registration of the entity and its professionals with the FRC.
• A description of the models used for scenario analysis, such as a 1.5°C climate scenario.
• The sustainability and climate-related risks and opportunities identified.
• Evidence of the governance structure for sustainability reporting (for example an ESG committee or sustainability office).
• The targets and metrics set to manage the risks and opportunities.
• The aspects of the financial reports that need updating, such as asset valuation, provisions and contingent liabilities.
• The current and anticipated effects on the business model and value chain and the analysis of how ESG issues affect operations, strategy and long-term value, and a description of the internal control over sustainability reporting.

Assurance and preparation

The roadmap also phases in assurance on sustainability information, starting with limited assurance in the third year of reporting and moving to reasonable assurance for all sustainability-related matters from the sixth year, so that the credibility of the information rises as capacity grows.

An entity preparing for the roadmap should:

• obtain board approval
• carry out a gap analysis against IFRS S1 and S2
• identify its risks and opportunities and the data needed, including from its value chain
• build the governance structure and the internal controls over sustainability data
• train the board, management and preparers
• plan the connection to the financial statements (provisions, impairment, valuation)
• decide on the reliefs it will use

Working out the dates

An entity with a 31 December year end whose first mandatory period begins on 1 January 2028 must submit the first group of documents at least three months before, on or before 30 September 2027, the second group within three months after, by 31 March 2028, and the third group within six months after, by 30 June 2028.

An entity whose year ends on 31 March has a first period beginning on or after 1 January 2028 which is the year beginning 1 April 2028: the first group is due on or before 31 December 2027, the second by 30 June 2028 and the third by 30 September 2028.

The ideas in more depth

Why a readiness test and not only a date

Reporting sustainability information that investors can rely on needs governance, data and controls that take time to build. A test tied to the start of the period makes entities show the foundations before they report, and protects investors from reports that cannot be supported.

A note on dates

The roadmap has been revised, and the dates differ between earlier publications and the amended 2026 roadmap. Candidates should use the position stated in the question or the latest official roadmap, and check the FRC’s website for any further amendment.

Sources and references

• Financial Reporting Council of Nigeria, Roadmap Report for the Adoption of IFRS Sustainability Disclosure Standards in Nigeria (2024; amended 2026) and Sustainability Reporting Guideline 1 (February 2026); Financial Reporting Council of Nigeria Act 2011 (as amended); reports of the Securities and Exchange Commission circular of September 2026.

These points are stated as at 5 November 2026.

Worked examples

1. Phase. Voluntary adoption (2024 to 2027), because the standards are not yet mandatory for its periods.

1. First period. The year beginning 1 January 2028.
2. First documents. Board resolution, gap analysis and implementation plan on or before 30 September 2027.

1. Limited assurance. In the third year of reporting.
2. Reasonable assurance. From the sixth year.

How to answer in the exam

• State the phases with dates and the entities covered.
• List the documents by timing (before, three months after, six months after).
• Mention assurance and the roles of the FRC, the Securities and Exchange Commission and the Exchange.
• Say if the dates may have changed and give the position as stated in the question.

Common mistakes in the exam

• Stating out-of-date mandatory dates.
• Mixing up the three groups of documents.
• Stating that all entities must comply from the same date.
• Forgetting government entities and small and medium-sized entities.
• Ignoring assurance.
• Confusing the roadmap (FRC) with the Exchange’s guidelines.

Quick revision

• Phases: early (to 31 December 2023), voluntary (2024 to 2027), mandatory (periods beginning on or after 1 January 2028 for public interest entities; 2030 small entities).
• Documents: before (resolution, gap analysis, plan); within three months (policies, reliefs, enterprise risk management (ERM), approvals, training); within six months (registration, scenarios, risks, governance, targets, internal control).
• Assurance: limited from year three, reasonable from year six.

Practice questions

These are original questions written in the style of the Institute’s exams. Try each one before you open the answer. Section A is a recall check, because the paper itself is written.

Recall check: multiple choice

Section B style: written questions

A further written question

Model answers

Spotted a mistake? Tell us and we will check it.