ISSB Two Years On: Where Does Africa Stand?

The International Sustainability Standards Board issued IFRS S1 and IFRS S2 in June 2023. Both standards became effective for annual reporting periods beginning January 1, 2024. Two years later, the real test is no longer whether Africa supports global sustainability disclosure. It is whether regulators, companies and investors have actually moved from commitment to implementation. Who in Africa has genuinely translated ISSB adoption into working practice, and what does that mean for companies now caught inside these timelines?

Africa’s ISSB Adoption Scorecard

Africa’s progress does not fit neatly into a single story. Consequently, it helps to group jurisdictions by what regulators have actually done, rather than by geography alone.

Nigeria sits furthest along. Its Financial Reporting Council formally embedded IFRS S1 and S2 into national regulatory practice through a phased roadmap. That roadmap has since been amended twice, most recently in February 2026. 

Kenya follows closely. The Institute of Certified Public Accountants of Kenya published a phased roadmap in September 2023. It fixes mandatory adoption for public interest entities from January 1, 2027, large non-public interest enterprises from 2028, and small and medium enterprises from 2029.

South Africa illustrates a different category altogether. There is no mandatory ISSB adoption date on the table yet. Instead, the Johannesburg Stock Exchange maintains Sustainability Disclosure Guidance that references IFRS S1 and S2 principles. 

South Africa’s companies registry also updated its reporting taxonomy in October 2024, so voluntary early adopters could tag ISSB-aligned disclosures. That is guidance, not compulsion, and the distinction matters for any company assuming South African listing rules already require ISSB reporting.

Beyond these three, the IFRS Foundation names Ghana, Tanzania and Zambia among African jurisdictions actively aligning with or considering the standards. However, public, dated roadmaps comparable to Nigeria’s or Kenya’s are not yet widely available for these markets. Readers should treat that distinction carefully. Alignment intent and a binding adoption timeline are not the same thing.

Nigeria: From Early Adoption to Mandatory Reporting

Nigeria’s position deserves the closest attention, partly because it moved early and partly because 2026 brought real clarification. The Financial Reporting Council first framed its approach around a four-stage sequence. This was covering early adoption, voluntary adoption, mandatory adoption, and a later phase for government and public sector entities. 

The FRC’s original 2024 roadmap positioned 41 Nigerian entities on the verge of full compliance, including four early adopters. On February 23, 2026, the Council unveiled an amended Roadmap Report together with Sustainability Reporting Guideline 1. This followed a December 2025 exposure draft, a public comment window, and a technical session in Abuja.

SRG 1 2026 introduces an Adoption Readiness Test Assessment. This diagnostic tool helps entities identify gaps in data collection and governance before mandatory deadlines apply. It also clarifies recent amendments to IFRS S2, reporting timelines, assurance expectations, and which professionals may legitimately prepare sustainability disclosures. 

Under the accompanying schedule, significant public interest entities must begin mandatory reporting from January 1, 2028. Small and medium enterprises follow from January 1, 2030.

Several listed Nigerian companies are already reporting ahead of that deadline. The FRC has publicly identified Access Bank, Fidelity Bank, MTN Nigeria and Seplat Energy as early adopters aligning their reporting with the standards. Their experience matters, since it shows what voluntary application looks like in practice, well before the mandatory phase reaches the wider market.

What Does “Adoption” Actually Mean?

Because these terms get used loosely, it is worth separating them properly. Adoption means a jurisdiction has formally incorporated or endorsed the standards through a regulator or standard setter. Voluntary application means companies may report under IFRS S1 and S2 before any mandatory date arrives, exactly as Nigeria’s early adopters have done. 

Phased implementation means different categories of company become subject to requirements at different points, typically sorted by size or public interest status. Mandatory reporting only applies once a company falls within a scope date that has actually passed.

In Nigeria’s case, adoption happened in 2024. Voluntary application has been running since then. Mandatory reporting has not yet started for most companies, since the earliest binding deadline falls in 2028. A company that calls itself “ISSB compliant” today, without saying which of these stages applies, is not being precise.

What IFRS S1 and S2 Mean for a Nigerian Company

For a listed or public interest entity, the practical work spans governance, strategy, risk management, and metrics and targets. These mirror the four pillars both standards share with the TCFD framework. 

Boards need to show real oversight of sustainability-related risks and opportunities, not simply approve a report written elsewhere. Management needs a strategy narrative connecting climate transition risk and physical climate risk to the business model. That narrative must sit alongside greenhouse gas emissions data that meets audit-grade standards, not marketing-grade estimates.

None of this is decorative. IFRS S1 and S2 are designed to pull financially material sustainability information into mainstream corporate reporting, sitting beside the financial statements rather than apart from them. That shift demands internal controls over sustainability data comparable to those already required for financial figures, plus genuine connectivity between the two disclosures.

Are African Companies Actually Ready?

Regulation has moved faster than readiness in most markets. In South Africa, one recent survey found only 28.4 percent of respondents felt prepared to comply with mandatory-style requirements. Independent assurance also remains rare among JSE-listed companies. 

In Kenya, commentators are now urging companies to treat 2026 as a rehearsal year. Running a practice reporting cycle before the 2027 mandatory deadline lets data gaps surface while there is still time to fix them.

Common obstacles repeat across markets. Companies struggle to measure Scope 3 emissions consistently, since that requires supply chain data many suppliers cannot yet provide. Climate scenario analysis remains underdeveloped outside the largest banks and multinationals. 

Assurance capacity is thin, and few local audit firms currently offer sustainability assurance at the depth regulators expect. Smaller entities often lack the structured data systems that sustainability disclosure requires. None of this means Africa is unready in absolute terms. It means the gap between regulatory ambition and operational capacity remains real, and closing it will take longer than issuing a roadmap.

Why Investors Should Care

Sustainability disclosure is no longer a side conversation for investors weighing African assets. Comparable, decision-useful data affects how capital gets priced and how lenders assess climate-related risk. It also shapes how easily a company can access sustainability-linked financing. Poor or inconsistent disclosure raises the cost of capital. It also invites greenwashing concerns that erode trust precisely when African issuers need international investors most.

What Happens Next?

Over the next twelve to twenty-four months, Nigeria’s early adopters will face growing scrutiny as more entities approach the readiness assessment stage. Kenya’s public interest entities will meanwhile be running their own rehearsal cycles before the 2027 deadline. Companies still waiting for a mandatory date to force action are taking an unnecessary risk. Data systems, governance structures and assurance relationships cannot be built overnight.

Africa’s ISSB journey should not be measured only by how many regulators announce adoption. The bigger test is whether companies can produce reliable, decision-useful sustainability information that investors can actually use.