The Nigerian filer's IFRS reference library.

Relevant laws and official guidance

The FRCN operates under the Financial Reporting Council Act (as amended). It issues the corporate governance code: under Section 51(c) of the FRC Act, the Council is empowered to issue the Code of Corporate Governance — the Nigerian Code of Corporate Governance (NCCG) 2018. On sustainability, Nigeria is an early mover: the FRCN has adopted the ISSB's IFRS S1 (general sustainability-related disclosures) and IFRS S2 (climate-related disclosures) as the national baseline, with mandatory reporting for Public Interest Entities beginning January 2028 and SMEs following from 2030. The FRC unveiled an amended 2026 Roadmap and the Sustainability Reporting Guideline 1 (SRG 1), which introduces an “Adoption Readiness Test Assessment.” Public-sector bodies follow IPSAS-based frameworks. Confirm the current phase and timelines with the FRCN.

Who the obligations may apply to

Depending on size, sector and public-interest status, this may apply to public and larger private companies, regulated entities, and — for sustainability standards — Public Interest Entities first, with wider application over time. NCCG 2018 applies to public companies (whether or not listed), holding companies of public companies, regulated entities and others, with every other company encouraged to key into it.

Basic compliance expectations

In general terms, entities are expected to prepare financial statements aligned with applicable standards (IFRS for the private sector; IPSAS-based frameworks for the public sector), report on their application of the NCCG where it applies, and prepare for phased sustainability disclosure under IFRS S1/S2. The FRC Readiness Test is positioned as a prerequisite, with entities advised to contact the Council before beginning the adoption journey.

Common filings and submissions

These commonly include filing of financial statements, NCCG application reports using the FRCN reporting template, FRCN registration for applicable professionals and entities, and — as timelines take effect — sustainability/climate disclosures aligned with IFRS S1 and S2.

Documents or records usually required

Typically: financial statements and supporting schedules, governance policies and board records for NCCG reporting, materiality and gap analyses for sustainability readiness, ESG/ERM data and an implementation plan, and evidence of board approval of relevant policies.

Practical readiness checklist

• Confirm whether and how the NCCG 2018 applies to your entity, and prepare your application report.
• Map your reporting to the correct framework (IFRS or IPSAS-based).
• Begin a gap analysis against IFRS S1/S2 ahead of your applicable deadline.
• Build the ESG data systems and governance the readiness test looks for.
• Confirm any FRCN registration requirements for those who sign financial statements.

Common mistakes to avoid

Treating sustainability reporting as future-only and leaving data systems unbuilt; assuming the NCCG applies only to listed companies; underestimating the readiness-test and governance evidence required; and relying on outdated timelines. Confirm the current position with the FRCN.

How Outliers Professionals can support

We support clients with financial reporting readiness, IFRS and sustainability-reporting alignment, governance documentation, gap analysis, review and advisory guidance. We are not a regulator and cannot guarantee acceptance, certification or a specific outcome.