Nigeria FRC / NGX
FRC Nigeria Amended 2026 Roadmap and Sustainability Reporting Guideline 1 (IFRS S1/S2); NGX ESG Guidelines
Topic : ESG disclosure · Level : National
Today
IFRS S1/S2 binding via FRC SRG 1 (16 Feb 2026): PIEs from 1 Jan 2028, SMEs 2030. SEC implementation plans were due 15 Oct 2026.
Summary
Nigeria's FRC made IFRS S1/S2 binding through SRG 1 and an amended 2026 roadmap. Public interest entities, including large private firms, must report from 2028 and SMEs from 2030.
Who is concerned
- Turnover
- Private firms >= NGN 30bn turnover are PIEs
- Employees
- non précisé
- Listed company
- cotées et non cotées
- Sectors
- Listed companies
- Banks (CBN-regulated)
- Public limited companies
- Govt contractors, SOEs
- Triggering activities
- Being a public interest entity (PIE)
- Private company turnover >= NGN 30bn
- Public-works contractor turnover >= NGN 1bn
- Extraterritorial reach
- No
non précisé
- Examples
- NGX-listed cement producer
- Chinese EPC contractor on Nigerian public works
What the law requires
- Submit IFRS S1/S2 implementation plan to SEC (listed)
- Pass FRC readiness stages (board resolution, gap analysis, materiality)
- Report IFRS S1/S2 disclosures from periods starting 1 Jan 2028
- Obtain limited then reasonable assurance (years 4 to 7)
Penalties
No amounts set. FRC enforcement applies from 16 Feb 2026, but the Roadmap says sanctions are not expected at the early adoption stage.
What this changes for a supplier in China
Chinese contractors on Nigerian public works above NGN 1bn turnover can be PIEs themselves. Others supply listed buyers needing Scope 3 data.
Expected evidence
- Scope 1-2 inventory of Nigerian operations
- Governance and board ESG resolution
- Product carbon data for supplied goods
Tiers : Tier 1