From Boardroom Talk to Personal Signature: Who Will Put Their Names to Nigeria’s Sustainability Disclosures?

For years, a sustainability report in Nigeria has been a curious kind of document. It carries a chairman’s letter, glossy photographs and impressive numbers, yet very few people could say who, exactly, stands behind the claims. If a figure proved wrong, the company would apologise. No individual would.

That is about to change. According to a legal alert by Olajide Oyewole LLP, a member of DLA Piper Africa, the Financial Reporting Council of Nigeria’s (FRC) new framework requires a named, FRC-registered manager to personally sign sustainability disclosures, with their registration number attached. The same alert describes it as personal accountability, not a formality.

This is a significant shift, and it divides opinion. Here is every side of it.

What the rule says, and what we have not verified

In February 2026, the FRC released its amended Sustainability Reporting Guideline roadmap together with Sustainability Reporting Guideline 1 (SRG 1), which sets out how entities should adopt IFRS S1 and S2. DLA Piper Africa’s reading is that the two together are binding and that FRC enforcement powers apply. The FRC says the documents also clarify which categories of professionals are eligible to undertake sustainability reporting.

A caution is in order. The personal sign-off detail comes to us through a law firm’s summary. Before any company builds its governance around it, the exact wording of SRG 1 should be read in full. Where we describe the rule below, we are describing that firm’s reading of it.

The scope is wide. Mandatory reporting from 1 January 2028 reaches listed companies, CBN-regulated financial institutions, public limited companies, private companies with turnover of ₦30bn or more, and government-linked entities. SMEs follow in 2030.

The case for personal accountability

Supporters of the signature requirement make a simple argument: accountability only bites when it has a face.

Financial reporting already works this way. Directors and officers sign off on financial statements, and that personal exposure shapes behaviour. Sustainability claims, which now influence capital allocation, pricing and access to markets, deserve the same discipline.

It also addresses a long-standing weakness. Greenwashing thrives where nobody owns the claim. A named signatory has an incentive to ask hard questions of the people supplying the data, to challenge optimistic numbers and to refuse to sign what cannot be supported. In a market where trust is fragile, a signature is a form of public commitment.

Finally, it raises the standing of the sustainability function. When a manager’s name and registration number are on the line, the sustainability team stops being an afterthought in the communications department and starts commanding board attention and budget.

The case against

The objections are serious, and they come from people who support sustainability reporting itself.

There may not be enough qualified people. A registration requirement creates a pool of eligible signatories. If that pool is small, companies will compete for a handful of professionals, costs will rise, and smaller regulated entities will struggle. This is a real risk in a market where sustainability expertise is still being built. A Nairametrics report earlier this year noted that some industry leaders still lacked a basic understanding of sustainability concepts.

It may encourage defensive reporting. Faced with personal exposure, a signatory has every reason to disclose less, hedge more and fill pages with boilerplate. The result could be reports that are legally safe and informationally useless.

It may punish the wrong person. In many organisations, strategy is set by executives and data is produced by operations teams. A mid-level registered manager who signs may carry liability for decisions made above them. Critics fear scapegoating, with accountability flowing downward rather than upward.

It may shift the burden without fixing the system. A signature does not make the underlying data better. If a company lacks reliable internal systems, the signatory simply inherits the risk.

What a signature cannot do

This is the part of the debate that deserves the most attention, because the signature is being asked to do a great deal of work.

First, assurance arrives slowly. DLA Piper Africa notes that external assurance phases in over several years, with limited assurance first and reasonable assurance by year seven. For a long stretch, a registered manager’s signature will be the main internal check on the numbers, with independent verification coming later.

Second, the framework itself has a defined focus. IFRS S1 and S2 concern sustainability-related financial information: the risks and opportunities that affect a company’s prospects. They do not, by design, verify whether a school was built, a clinic equipped or a community compensated. A signed IFRS report and a verified community outcome are different things. A company can sign one honestly while the other goes unchecked.

Third, a signature binds one person, not the institution. It does not replace board oversight, and it does not replace the independent scrutiny that journalists, civil society and affected communities provide.

How companies are likely to respond

We would expect four reactions. Companies will hire or train registered professionals early to secure a signatory. They will build sub-certification chains, in which each data owner signs off to the person who ultimately signs. Many will seek legal advice on director and officer exposure. And some will do the minimum, treating the signature as a compliance box.

The first three are healthy. The last is the one regulators and the public should watch.

What good looks like

A well-run company would, in our view, do the following:

• Make the signatory senior enough to challenge, with direct access to the board and audit committee.
• Build separate internal controls for sustainability data. DLA Piper Africa notes these are distinct from financial controls.
• Use sub-certification so that responsibility is traceable to those who produce the data.
• Disclose limitations honestly rather than burying uncertainty.
• Treat the signature as the end of a process, not a substitute for one.

Our verdict

Personal sign-off is a sound principle with real design risks. It will improve discipline where companies already want to get things right, and it will expose those that do not. But it is a floor, not a ceiling.

A name on a report tells us who is answerable. It does not tell us whether the claim is true. That requires evidence: independent assurance, field verification and the voices of the people a company says it is helping.

Nigerian executives are right to be uneasy about putting their names on sustainability claims. The discomfort is the point. The test will be whether the signature produces more honest reporting, or merely more careful wording.