Climate Change Act & IFRS S1/S2 Roadmap

Climate Change Act & IFRS S1/S2 Roadmap: nigerian climate duties active now with mandatory ifrs s1/s2 sustainability disclosure phased in for public interest entities from fy 2028.

Jurisdiction
Status
active
Category
climate
First deadline
Climate duties active now; IFRS S1/S2 mandatory from FY 2028 for Public Interest Entities
Who must comply
All companies (public or private) operating in Nigeria with 50 or more employees are subject to the Climate Change Act's core duties. Public Interest Entities, including listed companies, banks, pension funds, insurers, and large corporates, must adopt IFRS S1/S2 from FY 2028, with SME phase-in from FY 2030.
Penalties
Under the Climate Change Act, non-compliance can result in fines, enforcement notices, and potential facility shutdowns. Under Financial Reporting Council oversight of IFRS reporting, companies face monetary penalties, legal liability for defective or missing disclosures, and heightened investor risk.

What it is

Nigeria's Climate Change Act (2021) establishes economy-wide climate obligations administered by the National Climate Change Council, requiring larger organizations to track emissions, set reduction targets, and adapt to climate risk. Alongside it, the Financial Reporting Council is rolling out IFRS S1 and S2 sustainability and climate disclosure standards. Together they move Nigeria from voluntary climate action toward mandatory, ISSB-aligned corporate sustainability reporting.

Who must comply

All public or private companies with at least 50 employees must meet the Climate Change Act's duties, including maintaining a GHG inventory and appointing a climate officer. Public Interest Entities such as listed companies, banks, pension funds, insurers, and large corporates must adopt IFRS S1/S2 from FY 2028, with SMEs phased in from FY 2030.

What you must disclose

Under the Climate Change Act, entities must prepare an organization-wide GHG inventory, set carbon-reduction targets aligned with national goals, maintain an annually updated adaptation strategy, and designate a climate officer. Under IFRS S1/S2, companies must disclose governance, strategy, risk management, metrics and targets, mandatory Scope 1 and 2 emissions (Scope 3 if material), scenario analysis, and ESG data within statutory filings.

Timeline

The Climate Change Act was introduced on November 18, 2021, with core obligations taking effect January 1, 2022. From 2024 to 2027, IFRS S1/S2 adoption is voluntary. Mandatory IFRS S1/S2 reporting begins for Public Interest Entities from FY 2028, with an SME phase-in from FY 2030 onward.

Stay ahead of this regulation.

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