Boards preparing for mandatory adoption should begin with three artefacts that cannot be produced in a quarter: a scenario analysis that yields a result, a position on the amount and percentage of assets vulnerable to physical climate risk, and internal control over the data that produces both. The reasoning follows.

Adoption of the IFRS Sustainability Disclosure Standards becomes mandatory for public interest entities in Nigeria for accounting periods beginning on or after 1 January 2028. Four entities have reported ahead of that date: Access Bank Plc, Fidelity Bank Plc, MTN Nigeria Communications Plc and Seplat Energy Plc.

This article sets out what those four disclosed in their 2025 annual and sustainability reports, measured against the four content pillars of IFRS S1 and IFRS S2 — governance, strategy, risk management, and metrics and targets and against the readiness requirements of Sustainability Reporting Guideline 1 (SRG 1) in Nigeria (2026). Every observation comes from the companies’ own published documents.

First, the status of the four reports

Paragraph 72 of IFRS S1 provides:

“An entity whose sustainability-related financial disclosures comply with all the requirements of IFRS Sustainability Disclosure Standards shall make an explicit and unreserved statement of compliance. An entity shall not describe sustainability-related financial disclosures as complying with IFRS Sustainability Disclosure Standards unless they comply with all the requirements of IFRS Sustainability Disclosure Standards.”

The four describe their reporting basis in compliance-oriented terms, each with a qualifier.

MTN states that its sustainability-related financial disclosures “are prepared in accordance with the IFRS Sustainability Disclosure Standards” an unqualified in-accordance-with statement, made notwithstanding that the disclosures are themselves presented as “abridged”. Abridgement does not by itself defeat compliance; it invites the question whether all required disclosures remain present.

Seplat heads its section “Basis of Statement of Compliance” and states that its abridged disclosures are “an extract from the Group’s general Sustainability Report prepared in accordance with IFRS Sustainability Disclosure Standards,” adding that the abridged version “equally complies”. That is a dual claim: compliance asserted for a general sustainability report that does not form part of the reviewed pack, and separately for the abridged version that does.

Access states that the Standards are its “primary reporting basis,” within a report that blends IFRS-based financial-materiality disclosures with broader impact-materiality disclosures aligned with the GRI Standards. IFRS S1 permits the use of other frameworks, so the GRI overlay does not qualify the IFRS claim; the report presents the Standards as its primary basis while pursuing wider sustainability-reporting objectives alongside.

Fidelity states that it “applied IFRS S1 and IFRS S2 as issued by the ISSB” — a statement of application rather than of compliance with all requirements.

What none of the four presents is the clean paragraph 72 statement the Standard describes: an explicit and unreserved statement that the disclosures comply with all the requirements. MTN’s in-accordance-with claim carries the “abridged” qualifier; Seplat’s compliance statement is made principally for a report not in evidence; Access’s is a primary-basis claim within a multi-framework report; Fidelity’s is application language.

This article does not seek to resolve whether any of the four in fact satisfies every requirement needed to support paragraph 72 statement. That would require a full compliance review of each report against the Standards.

The practical question for boards is the useful one. Whether these reports are treated as compliant, as substantially applied, or as works in progress, the same exercise answers the board’s question: comparing what the four disclosed against the requirements of IFRS S1, IFRS S2 and SRG 1 shows what a Nigerian public interest entity must build before reporting becomes mandatory and subject to assurance in 2028.

The transitional reliefs: an open question, and evidence pointing to an answer

The transitional reliefs are specific, and each is worth knowing by paragraph.

IFRS S1 Appendix E. Paragraph E2 fixes the date of initial application as the beginning of the annual reporting period in which an entity first applies the Standard. Paragraph E3 removes the requirement to disclose comparative information in that first period. Paragraph E4 permits sustainability-related financial disclosures to be published after the financial statements. Paragraph E5 permits disclosure of only climate-related risks and opportunities in the first period and requires the entity to disclose that it has used the relief. Paragraph E6 extends comparative relief into the second period for non-climate disclosures.

IFRS S2 Appendix C. Paragraph C2 uses the same trigger. Paragraph C4(b) permits an entity, in the first annual reporting period in which the Standard applies, not to disclose Scope 3 greenhouse gas emissions, including certain financed-emissions information for financial institutions. Paragraph C4(a) permits continued use of a non-Greenhouse-Gas-Protocol measurement method carried forward from the preceding period.

Every one of those reliefs attaches to the first annual reporting period in which an entity applies the Standard. Not to a fixed date. Not expressly to first mandatory application.

That is where the question arises.

MTN, Seplat and Access state that their disclosures are prepared in accordance with, or on the primary basis of, the Standards; Fidelity describes application of them. Whether any of the four has thereby entered its first period of application, for the purposes of the transitional reliefs, is not settled — and the answer may bear differently on an entity that has asserted in-accordance-with preparation than on one that has described application. The availability of first-period reliefs may therefore depend partly on the nature of the claim an entity has already made about its sustainability disclosures.

The interpretation is not settled. One view is that entities already reporting in accordance with the Standards may have commenced application and therefore may have exhausted some or all of the first-period reliefs before mandatory adoption. Another view is that the reliefs remain available upon mandatory adoption in Nigeria, notwithstanding earlier voluntary reporting.

The construction of SRG 1 bears on the question. The second-stage readiness submission that is due not more than three months after the beginning of the reporting date requires entities to identify and apply transitional reliefs. The requirement assumes that boards will make deliberate decisions about which reliefs to use and when those reliefs expire.

If voluntary reporting before 2028 automatically exhausted those reliefs, the requirement would have limited practical significance for many early adopters and for much of the voluntary-reporting cohort. The structure of the readiness framework therefore provides at least some support for the view that transitional reliefs may still be available at mandatory adoption.

That is not conclusive as a matter of IFRS interpretation, and no inference is drawn regarding the FRC’s intention. It does narrow the request considerably: the FRC should state clearly how the transitional reliefs apply to entities that reported voluntarily before the mandate takes effect.

Whatever the answer, one practical point remains for every board. Relief is a deadline deferred, not a deadline removed. A disclosure omitted in the first period because of relief is generally a disclosure omitted in a later period. A board that has not decided which reliefs it intends to use has not decided its implementation timetable.

Pillar one: Governance

IFRS S1 requires identification of the body or individual responsible for oversight of sustainability-related risks and opportunities; disclosure of how that responsibility is reflected in terms of reference, mandates, role descriptions and other policies; how the body determines whether appropriate skills and competencies are available to oversee the responsive strategies; how and how often it is informed; and how it oversees target-setting and monitors progress, including whether related performance metrics are included in remuneration policies.

What the four disclose. Each identifies a responsible board committee and describes its oversight. Seplat states that its board is ultimately accountable for overseeing sustainability and climate strategy, that these considerations are integrated into risk management and financial decision-making in line with IFRS S1 and IFRS S2, and that dedicated committees meet quarterly.

On the remuneration requirement, Seplat discloses that 30 per cent of the key performance indicators on its 2025 corporate scorecard were dedicated to sustainability targets, with a 5 per cent component tied to completion of the end-of-routine-flaring programme for the onshore assets.

What is less developed across the four. The Standard does not require publication of a committee charter. It requires disclosure of how sustainability oversight is reflected in mandates, terms of reference, role descriptions and related policies. The four reports provide governance structures, oversight responsibilities and varying levels of information on board competence, training and remuneration linkage. What is less consistently developed is direct visibility of the underlying governance instruments themselves, and the degree to which the disclosures explain how those instruments are updated, tested and embedded in governance practice. Boards may therefore find that the governance architecture exists before the reporting architecture is fully visible.

Governance arrangements mature overboard cycles rather than reporting cycles. Where boards intend to strengthen sustainability oversight, clarify committee mandates, or expand director competence, waiting until the year of adoption may leave insufficient time for those changes to become embedded in practice.

Pillar Two: Strategy

IFRS S1 requires disclosure of the sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s prospects; their effects on the business model and value chain, on strategy and decision-making, and on financial position, performance and cash flows for the period, with the anticipated effects over the short, medium and long term.

IFRS S2 paragraph 22 requires the entity to use climate-related scenario analysis to assess its climate resilience, using an approach commensurate with its circumstances: its exposure, and the skills, capabilities and resources available to it — and to explain how and when the assessment was carried out.

The proportionality condition governs everything in this section. The Standard prescribes no single method, and an upstream oil producer’s exposure is not a bank’s or a telecommunications operator.

Seplat discloses a quantitative climate modelling assessment across its value chain, comparing the net present value of its portfolio under selected scenarios against a base case. It discloses the driving assumption — a net-zero oil price outlook averaging approximately $25 per barrel by 2050, against a constant base case of $65 — and the result: no major short-term revenue effect, medium-term revenue falling by over $1 billion, and long-term by more than $3 billion. Named scenarios, stated assumptions, and a result. Among the four reports reviewed, it is the only disclosure that presents a fully quantified modelled outcome.

Access discloses a 2023 pilot climate transition risk assessment conducted with the International Finance Corporation and 1in1000, using the 1in1000 TRISK platform — an asset-level, bottom-up climate stress-testing tool — alongside the Paris Agreement Capital Transition Assessment. In 2025 it screened all commercial and industrial loans and project finance transactions under the Equator Principles. The scenario work described is a pilot performed in 2023 and reported without evident update in 2025. Paragraph 22 asks for an assessment of resilience at the reporting date.

Fidelity sets out how physical and transition risks may affect financial position, performance and cash flows, and states that it responds through climate scenario analysis, stress testing, and integration of climate risk into credit monitoring, pricing and collateral valuation. It describes a transition plan of key actions, assumptions, dependencies and resources. The disclosure describes the process; it does not present the result of the analysis under a named scenario over a stated horizon.

MTN states that scenario analysis was conducted in line with IFRS S2 and discloses scenario-specific operational, financial and strategic consequences under different temperature pathways.

The distinction is narrower than when it first appears. All four entities describe climate scenario analysis or resilience assessment, and Seplat and MTN both disclose named scenarios and scenario outcomes. The difference lies in the level of specificity. Seplat provides quantified portfolio impacts under stated oil-price assumptions. MTN provides scenario-specific operational, financial and strategic consequences under different temperature pathways. Access and Fidelity place greater emphasis on the assessment process, governance arrangements and risk-management response than on the disclosure of scenario outputs.

A result need not be a monetary figure. It may be a strategic conclusion, an operational consequence, a portfolio reallocation or a capital deployment decision. The closer a disclosure comes to explaining what the scenario analysis produced, the easier it becomes for investors and boards to assess resilience. On that measure, Seplat and MTN presently provide more visibility into outcomes than Access and Fidelity.

Pillar three: Risk management

IFRS S1 requires disclosure of the processes used to identify, assess, prioritise and monitor sustainability-related risks, including the inputs and parameters used, whether and how scenario analysis informs identification, how the entity prioritises those risks relative to other types of risk, and whether and how the processes are integrated into and inform the overall risk management process.

What the four disclose. Fidelity describes a framework for identifying sustainability and climate-related risks and opportunities, evaluation of impacts on business continuity, financial resilience and long-term strategic positioning, and continuous monitoring against key performance indicators. Seplat states that sustainability and climate considerations are fully integrated into its overall risk management and financial decision-making frameworks. MTN states that transition risks across its supply chain, operations and energy-intensive infrastructure are systematically identified, assessed and managed within its broader enterprise risk management framework. Across the four, integration into enterprise risk management is now largely stated rather than implied. The question that remains less visible is how sustainability and climate-related risks are prioritised once they enter that framework.

The most limited disclosure across the four relates to prioritisation. How climate-related risk ranks relative to other enterprise risks is ultimately a question about the risk register: where climate sits, who owns it, what tolerance applies, and through which escalation pathway it is managed. While the reports describe integration into enterprise risk management, they provide less visibility into how climate risk is prioritised against credit, operational, cyber, liquidity, regulatory or other principal risks.

Integration is easier to assert than to demonstrate. A climate risk recorded on the enterprise risk register, with a named owner, a defined tolerance and an escalation pathway, demonstrates integration. A statement that climate is integrated into enterprise risk management describes it. An assurer will look for the former.

SRG 1’s third-stage readiness submission requires an Enterprise and Sustainability Risk Management Framework, together with evidence of board approval. The emphasis is noteworthy. Sustainability risk is not presented as a parallel system. The expectation is a framework through which sustainability risks are identified, assessed, monitored and governed alongside other enterprise risks, using a common taxonomy and a board-approved risk architecture.

Pillar four: Metrics and targets

IFRS S2 paragraph 29 sets out cross-industry metric categories every entity must disclose regardless of sector. These include absolute gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions measured in accordance with the Greenhouse Gas Protocol Corporate Standard, together with the Scope 3 categories used (29(a)); the amount and percentage of assets or business activities vulnerable to climate-related physical risks (29(c)); the amount and percentage vulnerable to climate-related transition risks (29(d)); the amount and percentage aligned with climate-related opportunities (29(e)); the amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities (29(f)); whether and how an internal carbon price is applied (29(g)); and whether and how climate-related considerations are reflected in remuneration (29(h)). Paragraph 32 requires industry-based metrics derived from the SASB Standards.

Paragraph 29(c) calls for a monetary amount and a percentage. The requirement is unusually specific. It is not satisfied by identifying vulnerable assets or activities alone. Metric requires quantification. A reader should be able to see both the scale of exposure and its relative significance within the business.

What the four disclose.

MTN reproduces the metric in its cross-industry metrics table, quoting the Standard’s requirement for “the amount and percentage of assets or business activities vulnerable to climate-related physical risks”, with the unit of measure stated as “the amount and percentage”. The disclosure states that telecommunications towers, data centres, operational vehicles and freehold and leasehold buildings are vulnerable, and that the towers, being the most vulnerable, have been outsourced to third-party partners, reducing financial and operational exposure. The asset classes are identified. The amount and percentage are not disclosed.

Fidelity states that it has conducted physical and transition climate risk assessments to determine the amount and percentage of portfolio assets vulnerable to climate-related risks. Elsewhere, the same determination appears as an objective, including evaluation of the proportion of the portfolio exposed to high-risk sectors and regions. The resulting figure does not appear in the report.

Access discusses climate-related risks, transition assessment and portfolio screening activities, but does not appear to disclose the amount and percentage of assets or business activities vulnerable to climate-related physical risks required by paragraph 29(c).

Seplat provides qualitative concentration disclosures, identifying operations and infrastructure exposed to climate-related impacts, including production facilities and oil and gas assets in vulnerable regions. It does not disclose a monetary amount or percentage.

The amount and percentage required by paragraph 29(c) do not appear to be disclosed in any of the four reports reviewed, notwithstanding broader discussions of climate-related physical risk exposure.

Materiality governs. A company may assess its exposure to physical climate risk, conclude that it is not material, and decide not to quantify the metric. That can be a legitimate conclusion and, for some entities, maybe the correct one.

None of the four explicitly states that conclusion. A reader therefore cannot distinguish between a metric omitted because management concluded that the exposure is not material and a metric that has not yet been produced or disclosed. Those are different positions. One communicates a judgement. The other leaves the judgement unknown.

The practice to adopt now costs nothing. Where a required cross-industry metric is not quantified, state why. A materiality conclusion, together with its basis, is a complete disclosure. Silence is not.

Elsewhere in this pillar, the four disclose more than is often recognised. Fidelity reports financed emissions under Category 15 of the Scope 3 framework using the Partnership for Carbon Accounting Financials (PCAF) Global GHG Accounting and Reporting Standard for the Financial Industry. MTN discloses Scope 1, Scope 2 and Scope 3 emissions and restates its 2024 comparative figures.

On internal carbon pricing, paragraph 29(g) asks whether and how a carbon price is applied. MTN states that it does not currently operate an internal carbon pricing policy and is evaluating the approach in accordance with IFRS S2. Fidelity states that it is actively exploring implementation. Both disclosures answer the question being asked.

One point for 2028. Scope 3 emissions benefit from a first-period relief under IFRS S2 paragraph C4(b). They are also excluded from limited assurance during the fourth and fifth years of the SRG 1 roadmap. Both reliefs expire. The data that will eventually be assured is already being collected today.

Connectivity

IFRS S1 requires an entity to provide information that enables primary users to understand the connections between sustainability-related risks and opportunities and the entity’s financial statements. The objective is not simply consistency of narrative. The sustainability disclosures and the financial statements should relate to the same reporting entity and the same reporting period, be published at the same time, and be based on consistent data, assumptions and judgements.

The route to the financial statements differs by sector. For Seplat, it runs through revenue and asset valuation. A scenario produces an oil price assumption, the assumption affects projected cash flows, and the cash flows affect portfolio value. For a bank, the route typically runs through expected credit loss modelling, provisioning, sectoral concentration limits, collateral valuation and capital allocation. Fidelity’s disclosure identifies that route when it describes integrating climate risk into credit monitoring, pricing and collateral valuation. For a telecommunications operator, connectivity may emerge through asset impairment, resilience-related capital expenditure, energy costs or business interruption.

What the four disclose

Seplat provides the clearest numerical illustration of connectivity. Its scenario analysis is linked directly to projected financial effects through portfolio valuation outcomes under stated assumptions. The disclosure connects climate assumptions to estimated impacts on future revenues and asset values, allowing the reader to follow the path from climate risk to financial consequence.

MTN also provides examples of connectivity. The report discloses approximately ₦91.8 million of climate-related infrastructure damage during the year and identifies approximately ₦8.1 billion of energy-related savings from gas-powered electricity initiatives, together with additional savings from efficiency measures. Climate-related risks and opportunities are discussed in terms of their effects on financial position, performance and cash flows.

Fidelity describes how physical and transition climate risks are considered within credit monitoring, pricing, collateral valuation, stress testing and transition planning. The disclosure explains the mechanism through which climate considerations affect financial outcomes, although it provides less visibility into the resulting financial effects.

Access discusses climate risk assessment, portfolio screening and sector-level climate considerations, demonstrating how sustainability-related matters enter lending and risk-management decisions. The linkage between sustainability matters and financial outcomes is described, although less emphasis is placed on quantified financial effects.

The distinction is therefore narrower than it first appears. All four reports attempt to connect sustainability-related risks and opportunities to financial consequences. The difference lies in the extent to which the resulting financial effects are disclosed. Seplat provides quantified scenario-driven outcomes. MTN discloses current financial effects and cost impacts. Fidelity and Access describe the mechanisms through which sustainability matters affect financial performance but provide fewer quantified outcomes.

Connectivity ultimately ends in financial statements. That is reflected in SRG 1’s third-stage readiness submission, which requires disclosure of the current financial effect of sustainability-related risks and opportunities. Whatever route connectivity takes within a particular sector — revenue, impairment, capital expenditure, provisioning, financing costs or operating expenditure eventually reaches the accounts. At that point, sustainability reporting ceases to be solely a sustainability exercise and becomes a finance exercise as well. A sustainability function may identify the risk, but the financial effect ultimately must be measured, supported and reported through the finance function.

The word “robust” appears

Language and evidence

31 times in the Access report and 25 times in Fidelity’s. “Committed to” appears 36 times in Fidelity’s and 23 times in MTN’s. Seplat, whose disclosures are generally the most quantified of the four reports reviewed, uses both expressions less frequently.

Word counts do not establish non-compliance. A company can comply and write poorly; a company can write elegantly and omit what is required. The observation is offered as a signal rather than a finding.

The signal is this. Boilerplate tends to accumulate where decision-useful evidence would otherwise appear. Phrases such as “systematically identified, assessed and managed within our broader enterprise risk management framework” provide context. Standing alone, they provide little that can be independently verified, measured or assured. The Standards were written for existing and potential investors, lenders and other creditors. Where such language appears, the useful question is what evidence sits behind it.

Four constructions are worth retiring before they become house style:

“We are committed to …” state the target, the baseline year, the metric and the progress against it.

“Robust framework” name the framework, identify the approving body and state when it was approved.

“Actively exploring” state whether the instrument exists. MTN’s disclosure that it does not currently operate an internal carbon pricing policy directly answers IFRS S2 paragraph 29(g); a statement that an entity is exploring one does not answer the same question.

“Integrated into our enterprise risk management framework” identify the relevant risk, the risk owner, the escalation route and, where appropriate, the relevant risk tolerance or appetite.

Each substitution replaces an assertion with a fact.

The FRC has made a related point in SRG 1. In discussing content that obscures sustainability information, the guideline identifies disclosures of interviews, pictures of corporate social responsibility activities, pictures of awards, and appendices that merely reproduce standard requirements as examples of material that can obscure material sustainability information.

The principle extends beyond those examples. Sustainability disclosures become more useful when assumptions, metrics, judgements, financial effects and progress against targets occupy the space that would otherwise be filled by promotional material, generic narrative or unsupported assertions.

Ultimately, investors are not being asked to assess commitment. They are being asked to assess performance. Performance is evidenced by data, judgements and financial effects, not adjectives.

Internal control over sustainability reporting

SRG 1 paragraph 17 states that Internal Control over Sustainability Reporting (ICSR) must not be interpreted as the same as Internal Control over Financial Reporting (ICFR). Instead, it describes the controls needed to ensure that sustainability information can be trusted, defended, independently verified and assured. Examples include clear ownership of sustainability data by responsible officers, documented methodologies such as greenhouse gas calculations, review and approval of assumptions and estimates, data validation and reconciliation checks, and audit trails with evidence retention.

A Scope 3 emissions figure has no ledger and no trial balance. The underlying evidence often originates outside the finance function, outside the entity and, in many cases, outside the jurisdiction. The controls that make a financial figure auditable — segregation of duties, reconciliation to control accounts and established approval hierarchies — have no natural equivalent and frequently need to be designed specifically for sustainability reporting.

The most effective place to build those controls is at the point of data collection. Once source data has been aggregated, adjusted and reported, deficiencies in ownership, methodology, validation or evidence retention become significantly harder to repair.

The FRC’s timing is instructive. SRG 1 places Internal Control over Sustainability Reporting within the readiness assessment, not within the assurance timetable. By the third stage of the readiness process, entities are expected to submit Internal Control over Sustainability Reporting alongside scenario-analysis models, their Enterprise and Sustainability Risk Management Framework, board approvals and evidence of current financial effects.

The assurance path is deliberately later. SRG 1 provides for limited assurance in the fourth and fifth years after reporting, excluding Scope 3 emissions, scenario analysis and transition plans. Those items enter limited assurance in the sixth year, with reasonable assurance over all disclosures expected in the seventh year.

The sequence is logical. Assurance does not create reliable data. It tests the reliability of data that already exists. Controls must therefore precede assurance.

Data gathered without appropriate controls may prove difficult, costly and, in some circumstances, impracticable to assure retrospectively through systems implemented years later. The risk is particularly acute for Scope 3 emissions, where evidence often resides within suppliers’ systems and may not be retained for future assurance purposes.

That is why the FRC places Internal Control over Sustainability Reporting in the readiness test rather than the assurance timeline. The Council’s message is implicit but clear: entities should not wait until assurance is required before building the controls that will make assurance possible.

The dates

The binding date is not 1 January 2028.

SRG 1 paragraph 14 establishes a three-stage readiness process measured from the beginning of the reporting period, not from the publication date of the sustainability disclosures.

First stage: Three months before the beginning of the reporting period. Required submissions include a board resolution approving adoption of the IFRS Sustainability Disclosure Standards, a gap analysis report and an implementation plan. For a 31 December year-end entity, the deadline falls on 30 September 2027. Each submission requires preparation in advance of the board meeting at which it is considered and approved.

Second stage: Not more than three months after the beginning of the reporting period. Required submissions include IFRS Sustainability Disclosure Policies; identification and application of transitional reliefs; identification and materiality assessment of sustainability-related and climate-related risks and opportunities; evidence of an established governance structure for sustainability reporting; evidence of board approval of the disclosure policies; and evidence of sustainability reporting training for directors, management and preparers delivered by an organisation recognised by the FRC.

Third stage: Not more than six months after the beginning of the reporting period. Required submissions include evidence of registration of the entity and the sustainability reporting professionals engaged in the reporting process with the FRC; a description of scenario-analysis models; an Enterprise and Sustainability Risk Management Framework with evidence of board approval; a description of cross-industry and industry-specific metrics and targets with evidence of board approval; disclosure of the current financial effect of sustainability-related risks and opportunities; and Internal Control over Sustainability Reporting.

Four of those submissions require board approval. The roadmap is therefore not primarily a reporting exercise. It is a governance exercise with reporting consequences.

One point of construction matters for entities without a 31 December year-end. SRG 1 paragraph 18 provides that mandatory reporting applies to accounting periods beginning on or after 1 January 2028. An accounting period that begins in 2027 and ends in 2028 does not fall within the mandatory regime. A company with a 31 March or 30 June year-end therefore enters mandatory reporting later than a 31 December reporter and will have correspondingly later readiness deadlines. The first step in any implementation plan is to establish the entity’s own dates rather than assume someone else’s.

One further requirement is easily missed. SRG 1 paragraph 15 requires sustainability disclosures to be signed by the member of management responsible for sustainability reporting, together with that individual’s FRC registration number. Paragraph 16 requires entities engaging sustainability professionals or firms for corporate reporting purposes to verify that those professionals are registered with the FRC.

What to build, and in what order

Three building blocks cannot be produced in a quarter. Begin with them.

A scenario analysis that produces a result. A named scenario, stated assumptions, and an outcome that can be evaluated financially, strategically or operationally. The approach must be commensurate with the entity’s circumstances. Seplat’s methodology is not a template for a bank. What its disclosure illustrates is what an outcome looks like.

A position on paragraph 29(c). Either disclose the amount and percentage of assets vulnerable to climate-related physical risk, or disclose a materiality conclusion explaining why the metric is not presented. Both are complete disclosure outcomes. Silence is neither.

Internal Control over Sustainability Reporting. Assign a named owner to each significant data stream. Document the methodology supporting each metric, including emission factors and estimation methods. Maintain an assumption register with identified approvers. Retain supporting evidence. The sustainability data collected in 2028 is the sustainability data that will eventually be assured.

Then two governance actions, one board meeting each.

Amend the relevant committee’s terms of reference to include sustainability and climate oversight, approve the amendment and disclose it appropriately.

Place climate-related risk within the enterprise risk register, assign ownership, define escalation arrangements and establish the applicable risk tolerance or appetite.

And one decision to take deliberately.

Which transitional reliefs will the entity apply in its first period of application, and when will each relief expire? That decision has disclosure consequences. IFRS S1 paragraph E5 permits climate-only reporting in the first period of application but requires the entity to disclose that the relief has been used. Relief used without disclosure is not a compliant use of relief.

One item for the next board agenda

Which of the third-stage readiness submissions does this company possess today, in a form the Financial Reporting Council would accept?

If answering that question requires more than a page, the gap analysis has already started. The board now has its implementation agenda and, more importantly, its deadline.

Stransact Chartered Accountants advises boards on governance, risk and compliance. This commentary is based on the 2025 annual and sustainability reports of Access Bank Plc, Fidelity Bank Plc, MTN Nigeria Communications Plc and Seplat Energy Plc, as published by those companies; on IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures; and on Sustainability Reporting Guideline 1 (SRG 1) in Nigeria (2026). Adoption of the IFRS Sustainability Disclosure Standards is voluntary in Nigeria until accounting periods beginning on or after 1 January 2028. The view expressed on the availability of transitional reliefs is an interpretation and is not a settled position.