Every reporting season, Nigerian banks publish sustainability reports that are longer, more polished and more standardised than the year before. Access Holdings published its report for 2025 on the Nigerian Exchange in August 2026, prepared under IFRS S1 and S2 with GRI and SASB as supporting frameworks. Zenith Bank followed in July with a report labelled as assured. By any count, there is more to read than ever.

The question is whether there is more to learn. A report can grow in length while the information a reader can check, challenge or act on stays flat. Here is how that looks in practice.

The progress is real

It would be unfair to pretend nothing has improved. A review of Nigeria’s largest lenders found that only Access Holdings explicitly claimed IFRS S1 and S2 compliance for its 2023 report, while Zenith and GTCo cited older frameworks such as TCFD. That gap has narrowed quickly.

Regulation is driving it. Voluntary adoption of IFRS S1 and S2 has been open since 1 January 2024, and the mandatory window opens on 1 January 2028. The category of entities covered includes CBN-regulated financial institutions. Banks are rehearsing for a deadline, and some of the rehearsal shows in the quality of disclosure.

A standard built for investors, not communities

The first problem is structural. The securities regulator describes what the new regime requires as sustainability-related financial disclosures under IFRS S1 and S2. The standards ask how sustainability issues affect the company, meaning its risks, opportunities and enterprise value. They are less concerned with how the company affects people and communities.

That is the right focus for an investor. It is not the same as accountability to the public. As banks make these standards their primary framework, there is a risk that disclosure about real-world impact becomes an optional extra, written for the glossy pages and not for the data tables. I would describe this as a risk and not yet a finding, but the direction of travel is worth watching.

Where the detail thins

Four examples show the gap between more pages and more information.

Scope and assurance. Access says its report covers the holding company and its subsidiaries, but Access Bank accounts for a significant portion of the reported outcomes. The assurance is also partial: selected disclosures were assured under ISAE 3000 on a hybrid reasonable and limited basis. A reader cannot easily tell which numbers carry that comfort and which do not. For Zenith, the report is labelled assured, but CSR Reporters could not confirm the named assurance provider from the announcement. Assurance is only meaningful when the reader knows who gave it, what it covered and how deep it went.

Headline numbers without visible baselines. Access’s coverage carries the headline of an operational emissions cut of 28.47%. The figures in the same coverage show emissions of 49,352 tonnes in 2025, down from 57,176 tonnes in 2024. That is a fall of about 13.7% year on year. The larger percentage presumably measures against an earlier baseline, but the coverage does not say which. Both numbers may be correct. The problem is that a reader has to work out the difference, and the headline is the one that gets repeated.

Outputs without outcomes. The same report says the group extended access to finance to 2,528,117 low-income individuals. That is a large number, but “extended access” is not the same as someone using credit productively, staying out of default, or being better off. Reach is an output. Financial health is an outcome. Most reports lead with the former.

The biggest footprint is the least measured. A bank’s largest environmental impact is the activities it finances, not its branches. The review of Nigerian lenders found that Access had drawn the first line on financed emissions, while Zenith and GTCo were still aligning and UBA and First Bank relied heavily on qualitative reporting. Even Access says it plans to improve data quality for financed and Scope 3 emissions by adopting the PCAF methodology. The part of the footprint that matters most is the part still being worked on.

Following the money

Narrative is easy to produce. Money is harder to dress up. CSR Reporters’ own press-release scrutiny found that Access Holdings’ FY2025 audited financials show ₦2.86 billion in group donations and sponsorships, with about 71% concentrated in seven event-sponsorship line items and not in grassroots programmes. We sent right-of-reply questions at the time. We cite that finding here in the interest of transparency, and because it makes a point that applies well beyond one bank: a sustainability report describes community commitment, but the audited accounts show where the money went. The two should be reconcilable on the page, and rarely are.

What saying more would look like

If banks want credit for transparency and not just volume, five changes would make the difference:

1. State baselines and boundaries. Every percentage should name its starting year, and every figure should say which entities it covers.
2. Be precise about assurance. Name the provider, the standard, the level of comfort and exactly which disclosures were covered.
3. Disclose financed emissions and sector exposure. Show what the bank lends to, and how that is changing.
4. Report outcomes, not only reach. Track what happened to the people a programme served, including complaints and how they were resolved.
5. Reconcile giving. Show how donations in the audited accounts map to the programmes described in the report.

None of this requires a new standard. It requires the willingness to publish information that can be checked.

The answer

Are Nigerian banks saying less? In volume, no. They are publishing more than ever, in better frameworks, with growing assurance. But on the questions the public and communities care about, such as what was achieved against a clear baseline, for whom, at whose expense and who has verified it, the detail is often thinner than the page count suggests.

The 2028 deadline will force more disclosure. It will not force better disclosure unless banks choose it. The institutions that treat the deadline as a compliance exercise will produce thick reports. The ones that treat it as an invitation to be checked will produce something more valuable: reports that readers can trust.