Sustainability reporting roadmaps: Nigeria and Kenya
When IFRS sustainability reporting becomes mandatory in Nigeria and Kenya, when assurance follows, and what accounting firms should tell clients now.
By Achekam · · 4 min read · For Accountants & audit firms in Nigeria, Kenya
For most of the clients an accounting firm serves in Nigeria and Kenya, sustainability reporting still sounds like something for listed giants. That is changing on a published timetable. Both countries have roadmaps for adopting the IFRS Sustainability Disclosure Standards, and both reach beyond public interest entities to larger private companies and, eventually, to smaller ones.
Firms that wait for clients to ask will find themselves explaining, in the year a requirement starts, why nobody mentioned it sooner. The useful work now is to know the dates, understand where assurance fits, and help clients start collecting information before it becomes mandatory.
This article summarises both roadmaps as recorded at the time of writing. Roadmaps are amended, Nigeria's already has been, so confirm current dates with the FRC and ICPAK before advising a client.
Nigeria's amended roadmap
Under the Financial Reporting Council of Nigeria's amended roadmap, IFRS sustainability reporting becomes mandatory:
- for public interest entities, for periods beginning on or after 1 January 2028;
- for SMEs, from 1 January 2030.
Governments follow their own track, from 1 January 2028, under the IPSASB's sustainability standard SRS 1.
The FRC has published its amended roadmap and Sustainability Reporting Guideline 1 for adopting IFRS S1 and S2 in Nigeria. Read the guideline itself for scope and transition detail rather than relying on summaries, including this one.
Kenya's ICPAK roadmap
Under ICPAK's roadmap, IFRS sustainability reporting becomes mandatory in Kenya:
- for public interest entities, from 1 January 2027;
- for large non-PIEs, from 1 January 2028;
- for SME non-PIEs, from 1 January 2029.
Reporting has been voluntary for all organisations for periods beginning on or after 1 January 2024. So a Kenyan client that wants to prepare early, perhaps because a lender or a multinational customer is asking, can do so now within the roadmap.
The two timetables side by side
| Group | Nigeria | Kenya |
|---|---|---|
| Public interest entities | Periods beginning on or after 1 January 2028 | From 1 January 2027 |
| Large entities that are not PIEs | Check the FRC roadmap | From 1 January 2028 |
| SMEs | From 1 January 2030 | SME non-PIEs from 1 January 2029 |
| Voluntary reporting | Check the FRC's guideline | From periods beginning on or after 1 January 2024 |
| Governments | From 1 January 2028, under SRS 1 | Check with the relevant authority |
The definitions behind each group, such as what makes an entity "large" or an SME, come from the roadmaps and the regulators, not from this table. Check them before telling a client which group they fall into.
Assurance comes later
In Nigeria, assurance starts from the third reporting year. That gives a reporting entity a short runway to get its processes working before an assurance provider examines them, and gives firms time to build capability.
Firms planning to offer assurance should start now anyway. Assurance on sustainability information needs people who understand both the subject matter and the assurance framework, and the methodology to go with it. Achekam ships working-paper template packs written in its own words, including packs for ISAE 3000 engagements, for a firm to adopt and approve. The catalogue is marked as unapproved platform content until the firm adopts it, so a firm should review the pack, adapt it to its own methodology and approve it before use. Assurance engagements under ISAE 3000 covers the general framework.
What Achekam covers, and what it does not
Be precise with clients about the tools. Achekam's financial statements Studio builds a draft set of annual financial statements from a mapped trial balance, including the directors' report, the primary statements, policies, notes and a detailed income statement. Sustainability disclosures under IFRS S1 and S2 are a different report, built from different information, much of it non-financial: emissions, energy, governance processes, risks and targets. Plan to gather and prepare that information separately.
Achekam also does not pull a live feed of standards and regulatory changes. Its Standards & Regulatory Updates page shows what its knowledge base records. When either roadmap is amended again, the firm will hear it from the FRC, ICPAK or the IFRS Foundation first, so someone in the firm should be watching those sources directly.
Preparing clients now
A practical approach for client conversations over the next year:
- Sort your client list. Mark which clients are likely PIEs, which may be large non-PIEs in Kenya, and which are SMEs, noting that the definitions need confirming.
- Tell the first group now. PIEs in Kenya face a 2027 start; in Nigeria, 2028. Their first reporting periods may already be in planning.
- Start with governance and data. Before any disclosure is drafted, a client needs to know who owns climate and sustainability matters, and where the data will come from.
- Use the voluntary window. Kenyan clients can report voluntarily now; a first, partial report is a useful rehearsal.
- Separate advice from assurance. If the firm helps prepare a client's sustainability report, consider the independence implications before also offering assurance on it.
- Diarise a check of both roadmaps. Put a date in the calendar to re-read the FRC's and ICPAK's current documents.
For the broader standards picture in both countries, see auditing and quality standards in Nigeria and Kenya.
Choose the three clients most likely to be affected first, and raise sustainability reporting at your next meeting with each.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
