From Voluntary to Mandatory Sustainability Reporting in Nigeria: A SanityInnocent Okwuosa

At present, sustainability reporting in Nigeria has been a voluntary initiative by companies engaging in such practice. Although, the premium board listed companies are required by the Stock Exchange to engage in sustainability reporting, it is not a mandatory requirement. The motivation for engaging in such reporting has been traced to philanthropy, Corporate Social Responsibility (CSR) and giving back to the society. It is seeking for good image and reputation. This is why such reporting has been criticised for its greenwashing.

A look at some of the published sustainability reports in the Nigerian capital market will show pictures of commissioning community projects such as water, roads, hospitals, schools or donations, scholarships etc. Greenwashing is the act of making inflated, bogus, exaggerated, or misleading statements in corporate reporting. Images of the pictures in sustainability reports may not be a true reflection of the reality on ground example oil spills of oil and gas companies, or health problems caused by cement companies or casual workers and financed emissions of banks. No pictures capture these.

The marketing, or good image making and enhancement motivation behind such sustainability reporting can also be seen in the claim that one company’s sustainability report complies with multiple sustainability reporting standards and guidelines example the GRI, SASB, IIRC, CDP, CDSB, TCFD, Sustainable Banking Principles, Equator Principles, UN Global Compact principles, UN SDGs among others. How? From the above, one can have a glimpse of the insanity and chaos pervading voluntary sustainability reporting in Nigeria at the moment. This calls for sanity restoration.

The starting point for restoring sanity in sustainability reporting can be traced to events at the global level which saw the merger between IIRC and US SASB to form the Value Reporting Foundation (VRF) in 2020. VRF was subsequently absorbed by ISSB along with CDSB after COP 26 in Glasgow. This was in response to IFAC calling on the IFRS Foundation to come and restore sanity in the sustainability reporting landscape, in which accountants are expected to play a leading role. TCFD formed the foundation of the ISSB’s initial standards.

The ISSB’s Chairman, Mr Emmanuel Faber personally launched the Nigerian adoption roadmap in a ceremony organised by FRC and NGX RegCo at the NGX building in Lagos. Nigeria had earlier become the first country in Africa to adopt the ISSB’s standard. The roadmap was midwifed by the Adoption Readiness Working Group (ARWG) which FRC inaugurated on 6 June 2023.

Under the roadmap there are 4 categories of adopters with assigned adoption dates. These are (1) early adopters for accounting period ending on or before December 31, 2023 (2) voluntary adopters for accounting period ending or before December, 2026 (3) mandatory adopters for accounting period beginning on or after 1 January, 2027. This mandatory phase is categorized into three which includes (1) Significant Public Interest Entities (PIEs) (2027); (2) Other PIEs (2028) and finally (3) SMEs (2030). So, we are at the voluntary phase which will last till 2027 before it becomes mandatory.

The fourth category is public sector entities (2030), which date is to allow the International Public Sector Accounting Standard (IPSASB) come up with public sector sustainability standard. Already the IPSASB has announced in June 2023 that it would begin developing a Climate-related Disclosures standard, a first for the public sector and is currently doing so with the support from the World Bank. The aim is to develop a global baseline for sustainability reporting in the public sector as ISSB has done for the private sector.

The FRC and Nigerian Integrated Reporting Committee (NIRC) have signed an MOU under which the NIRC supports FRC in the ISSB’s sustainability standards adoption, advocacy, capacity building and technical implementation works. As part of the capacity building effort, FRC-NIRC has conducted Sustainability Awareness capacity building for the financial sector in Abuja between 10th and 11th July, 2024 with Oil and Gas and Telecommunication scheduled to hold on 4th and 5th September, 2024 in Lagos. This will be followed by the manufacturing sector, the Regulators and assurance providers. A regulatory Round Table on implementation of the standards took place on July 15, 2024 in Abuja, where all the regulators agreed to work collaboratively to achieve the objective of the adoption.

Globally, over 20 jurisdictions have already adopted or are taking steps to introduce ISSB Standards in their legal or regulatory frameworks. Together, these jurisdictions account for: (1) nearly 55% of global GDP; (2) more than 40% of global market capitalisation; and (3) more than half of global greenhouse gas emissions. Together, the 20 plus jurisdictions that have taken steps to adopt or otherwise use ISSB Standards account for around 75% of global market capitalisation excluding the United States. The IOSCO has already endorsed the ISSB’s sustainability standards

Thus there is unprecedented move from voluntary to mandatory sustainability reporting both at the global and national level in Nigeria.
Under the ISSB’s Sustainability Standards, verifiable metrics and targets which preparers and users can lean on to measure entities’ true performance on the sustainability topics will define sustainability reporting. It will no longer be pictures of commissioning CSR projects that will define sustainability reporting. Professional accountants will come in with their expert reporting skills, internal control over information system, assurance and professional scepticism, working with sustainability professionals to bring, authenticity and trust to sustainability reporting thereby exorcising the spirit of greenwashing and bringing sanity to the landscape.

This sanity will be evidenced by professional accountants bringing the same level of rigour in financial reporting to sustainability reporting. Already IFRS S1 has stipulated the two fundamental qualitative characteristics that underpin financial reporting to also underpin sustainability reporting. These are relevance and faithful representation. Similarly, enhancing qualitative characteristics of financial reporting such as comparability, verifiability, timeliness and understandability also underpin sustainability reporting. Then with these, reasonable assurance will kick in and users can now trust sustainability information as they currently do for financial reporting. That is final sanity restored.

Okwuosa PhD, FCA is the Chairman, Nigerian Integrated Reporting Committee and Immediate Past President, Institute of Chartered Accountants of Nigeria
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