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Nigeria-ISSBRoadmap issued March 2024 and amended February 2026 (with SRG 1 2026); voluntary phase runs to periods ending 31 December 2027; mandatory application for public interest entities from 2028

Local adoption of IFRS S1 / S2 (ISSB Standards)

Nigeria · Financial Reporting Council of Nigeria (FRCN)

The Financial Reporting Council of Nigeria adopted IFRS S1 and S2 through a March 2024 roadmap, amended in February 2026 alongside Sustainability Reporting Guideline 1. Voluntary application runs to 2027. Mandatory application starts for public interest entities with periods beginning on or after 1 January 2028 and for SMEs from 2030, and governments move to the IPSASB climate standard from 2028.

Category
ISSB-aligned sustainability disclosure
Enforcement
Mandatory
Effective date
Early adopters: periods ending on or before 31 December 2023. Voluntary: accounting periods beginning on or after 1 January 2024 through periods ending on or before 31 December 2027. Mandatory: accounting periods beginning on or after 1 January 2028 for public interest entities; 1 January 2030 for SMEs (early adoption encouraged). Governments and government organizations: IPSASB SRS 1 from financial years beginning 1 January 2028. Assurance or verification required from the third year of reporting, reaching reasonable assurance on all disclosures from the seventh year
Covered entities
Public interest entities as defined in the FRC Act 2011 (as amended): listed entities, regulated non-listed entities, public limited companies, private holding companies of public or regulated entities, concession entities, privatized entities in which government keeps an interest, entities doing government public works with annual contract sums of N1 billion or more, government licensees, and other entities with annual turnover of N30 billion or more; SMEs from 2030. Governments and government organizations (also PIEs under the Act) apply IPSASB SRS 1 from 2028 instead of IFRS S1 and S2
Notes
Sources: FRC announcement of 26 February 2026 on the amended roadmap and SRG 1 2026, released 23 February 2026 after exposure drafts in December 2025 (https://frcnigeria.gov.ng/2026/02/26/frc-unveils-amended-roadmap-and-sustainability-reporting-guideline-to-strengthen-adoption-of-ifrs-sustainability-disclosure-standards-in-nigeria/). The amended roadmap requires disclosures in general purpose financial reports after the directors' report; allows first-year stand-alone disclosures up to 6 months after year end; applies a three-stage readiness test to all reporting entities; and requires entities and professionals to register with the FRC. Assurance under ISSA 5000: assurance or verification from the third year of reporting; limited assurance (excluding Scope 3, transition plans and scenario analysis) in years four and five; limited assurance on those items and reasonable assurance on the rest in year six; reasonable assurance on all disclosures from year seven. The IFRS Foundation profile is still dated 12 June 2025 (verified 2026-09-23).

Sources

Related regulations

Plastic Waste Control Regulations, 2026 gazetted, with phased implementation; EPR for EEE and food and beverage packaging continues under NESREA's EPR program

Nigeria's National Environmental (Plastic Waste Control) Regulations, 2026 make plastic EPR mandatory across the value chain. Producers, importers and brand owners must fund and organize recovery of the plastics they place on the market, obtain permits and registrations, report through a central data platform, and meet recycled-content targets for PET packaging of 25% from 2028 and 50% from 2030. EPR for electronics and food and beverage packaging continues under NESREA's EPR program.

Enforcement
Mandatory for plastics (phased); other streams under NESREA's EPR program and sector regulations
Effective date
Sanitation and Wastes Control Regulations effective 2009; NESREA EPR program from 2014 (food and beverage) and 2016 (EEE); Plastic Waste Control Regulations, 2026 gazetted by June 2026 and publicly unveiled 4 September 2026, with recycled PET content of 25% required from 1 January 2028 and 50% from 1 January 2030
Covered entities
Producers, converters, brand owners, importers, retailers, recyclers and waste managers across the plastics value chain; producers, importers and distributors of electrical and electronic equipment and food and beverage packaging
Primary source ↗Verified 2026-09-23
Effective. Group 1 has reported since financial years beginning 1 January 2025 and Group 2 since financial years beginning 1 July 2026. Treasury is consulting on changes to reduce reporting costs (closes 2 October 2026).

Australia has adopted ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory for entities within Chapter 2M of the Corporations Act and is phased in across three groups from 2025 to 2027. AASB S1 (general sustainability) is voluntary. ASIC administers the regime and has published guidance in RG 280.

Enforcement
AASB S1: voluntary. AASB S2: mandatory under Corporations Act 2001 for in-scope entities.
Effective date
Financial years beginning on or after 1 January 2025 (Group 1), 1 July 2026 (Group 2) and 1 July 2027 (Group 3). AASB S2025-1 amendments apply to annual periods beginning on or after 1 January 2027, with early application permitted.
Covered entities
Entities that must prepare annual financial reports under Chapter 2M of the Corporations Act and meet a s292A threshold. Group 1: at least two of consolidated revenue of AUD 500m or more, consolidated gross assets of AUD 1bn or more, and 500 or more employees; or NGER registered corporations in groups that meet the s13(1)(a) NGER threshold. Group 2: at least two of revenue of AUD 200m or more, assets of AUD 500m or more, and 250 or more employees; all other NGER registered corporations; and registered schemes, RSEs and retail CCIVs with assets of AUD 5bn or more. Group 3: at least two of revenue of AUD 50m or more, assets of AUD 25m or more, and 100 or more employees.
UK-SRS

UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2)

United Kingdom · UK Government (Department for Business, Innovation, Science and Trade, renamed from DBT in July 2026) / FRC; FCA for listed-entity application
Final standards published 25 February 2026 for voluntary use; FCA consultation CP26/5 closed 20 March 2026; FCA policy statement expected autumn 2026 (not published as of 23 September 2026)

UK SRS S1 and S2 are the UK government's endorsed versions of IFRS S1 and S2, published on 25 February 2026 for voluntary use. Voluntary users can apply the Scope 3 and non-climate reliefs with no time limit. The FCA has consulted on listing rules that would make UK SRS S2 climate reporting mandatory for listed companies, with Scope 3 emissions and UK SRS S1 non-climate reporting on a comply-or-explain basis.

Enforcement
Voluntary at publication. FCA proposes mandatory UK SRS S2 for listed issuers (Scope 3 and broader sustainability on comply-or-explain).
Effective date
Voluntary use: no effective date (entities apply the standards when they choose). FCA proposal, subject to the final policy statement: rules in force 1 January 2027 for accounting periods beginning on or after 1 January 2027; using the transitional reliefs, Scope 3 reporting from periods beginning on or after 1 January 2028 and UK SRS S1 non-climate reporting from periods beginning on or after 1 January 2029.
Covered entities
Any entity (voluntary). The FCA proposal covers issuers in the commercial companies (UKLR 6), non-equity and non-voting equity shares (UKLR 16), transition (UKLR 22), secondary listing (UKLR 14) and depositary receipts (UKLR 15) categories. No mandate yet for unlisted companies.
Canada-CSDS

CSDS 1 and CSDS 2 – Canadian Sustainability Disclosure Standards

Canada · Canadian Sustainability Standards Board (CSSB), under FRAS Canada
Final standards published (voluntary); CSA mandatory rule paused since April 2025 (no resumption found); CSDS 2 GHG emissions amendments proposed April 2026

CSSB issued final CSDS 1 and CSDS 2 on 18 December 2024, aligned with IFRS S1 and S2 with extra transition reliefs. The standards are voluntary. The CSA paused its mandatory climate disclosure rulemaking on 23 April 2025. In April 2026 the CSSB proposed CSDS 2 amendments matching the ISSB's IFRS S2 amendments: limiting Scope 3 Category 15 to financed emissions, allowing an industry classification other than GICS, and allowing other GHG measurement methods or GWP values where a jurisdictional authority or exchange requires them.

Enforcement
Voluntary
Effective date
Standards effective for annual reporting periods beginning on or after 1 January 2025, for entities that choose to apply them (with transition reliefs). Voluntary; no mandatory reporting date exists.
Covered entities
Any Canadian entity (voluntary). CSA paused work on mandatory rule citing global developments.
Japan-SSBJ

SSBJ Sustainability Disclosure Standards (Application, General, Climate)

Japan · Sustainability Standards Board of Japan (SSBJ)
Final standards published 5 March 2025; mandatory under the FSA's Cabinet Office Order amendment promulgated 20 February 2026, first cohort from the fiscal year ending March 2027

SSBJ published its Application, General and Climate Standards on 5 March 2025, and the SSBJ and ISSB confirm they are functionally aligned with IFRS S1 and S2. The FSA amended the Cabinet Office Order on Disclosure of Corporate Affairs on 20 February 2026 to require SSBJ-based disclosures in Annual Securities Reports for large Prime Market companies from the fiscal year ending March 2027, with third-party assurance one year later.

Enforcement
Mandatory for Tokyo Stock Exchange Prime Market companies, phased by market cap, through Annual Securities Reports under the Cabinet Office Order on Disclosure of Corporate Affairs. Voluntary for other entities.
Effective date
Voluntary for annual periods ending on or after 5 March 2025. Mandatory for Prime Market companies by average market cap (average of the last five fiscal year-ends): ¥3 trillion or more from the fiscal year ending March 2027; ¥1 trillion or more from the fiscal year ending March 2028; ¥500 billion or more from the fiscal year ending March 2029. Timing for other Prime Market companies to be decided later. Mandatory assurance starts one year after each cohort's first mandatory year.
Covered entities
Tokyo Stock Exchange Prime Market companies with average market capitalization of ¥500 billion or more, in three cohorts (¥3 trillion, ¥1 trillion, ¥500 billion). Timing for other Prime Market companies not yet set.
HongKong-HKFRS

HKFRS S1 and HKFRS S2 – Hong Kong Sustainability Disclosure Standards

Hong Kong · Hong Kong Institute of Certified Public Accountants (HKICPA)
Adopted (effective 1 August 2025; voluntary use until mandated by relevant authority)

HKICPA published HKFRS S1 and HKFRS S2 on 12 December 2024, fully aligned with IFRS S1 and S2. The Hong Kong SAR Government's December 2024 Roadmap sets out the phased path to mandatory adoption for publicly accountable entities.

Enforcement
Voluntary at HKICPA level. The Hong Kong SAR Government's roadmap (10 December 2024) sets out phased mandatory adoption for publicly accountable entities.
Effective date
Annual reporting periods beginning on or after 1 August 2025
Covered entities
Any Hong Kong entity (voluntary). Mandatory phased rollout per government roadmap.