What is a public interest entity in Nigeria?
A public interest entity, or PIE, is an organisation included in the category defined by the FRC Act and applied in the sustainability-reporting roadmap. The definition covers several legal and regulatory routes, so size alone is not the test.
The FRC amended roadmap reproduces the categories used for adoption. A company should check each route rather than stop after asking whether it is listed.
Which organisations are public interest entities under the FRC Act?
The category includes government bodies, listed and regulated entities, public companies, certain holding companies, concession and privatised entities, government licensees and other large entities. One applicable category is enough to require further compliance analysis.
| PIE route | Examples described in the roadmap |
|---|---|
| Public sector | Governments and government organisations |
| Capital markets | Entities listed on a recognised Nigerian exchange |
| Regulation | Non-listed regulated entities |
| Company form | Public limited companies |
| Group structure | Private holding companies of public or regulated entities |
| Government relationship | Concession entities, privatised entities in which government retains an interest, and licensees of government |
| Public works | Entities engaged by any tier of government in public works with an annual contract sum of ₦1 billion and above, settled from public funds |
| Turnover | All other entities with an annual turnover of ₦30 billion and above |
Does a public company have to be listed to be a PIE?
No. The roadmap lists public limited companies separately from entities listed on a recognised exchange.
This distinction prevents an unlisted public company from treating listing status as its only test. Confirm the company's legal form as well as its market status.
Can a private company be a public interest entity?
Yes. A private company may fall within the definition because it is regulated, holds a government licence, has a qualifying group relationship or meets another listed route.
The roadmap also includes other entities with annual turnover of ₦30 billion and above. Use the current legal text and professional advice when applying a monetary threshold to a particular reporting period.
When do public interest entities begin mandatory sustainability reporting?
PIEs begin mandatory IFRS S1 and IFRS S2 reporting for accounting periods beginning on or after 1 January 2028. A period that started before that date does not become mandatory merely because it ends during 2028.
The timetable comes from the FRC adoption roadmap. The work must begin earlier because the first report depends on records created throughout the reporting period. For context, voluntary adoption covers periods ending on or before 31 December 2027, PIEs report for periods beginning on or after 1 January 2028, and SMEs follow from 1 January 2030.
What should a company check before treating itself as an SME?
Check every PIE category before relying on the SME timetable. A company that meets a PIE route cannot use a small headcount or informal description to postpone reporting.
If the entity is a PIE, continue with the SRG 1 readiness test and reporting deadlines. Listed PIEs should also read SEC sustainability reporting.
Where this fits
About this guide: Prepared for Nigerian reporting teams by Emvert.