SRG 1 Nigeria and the FRC readiness test

SRG 1 is the FRC's operational guideline for implementing sustainability reporting in Nigeria. It adds local requirements on readiness, annual-report placement, preparer registration, sign-off, controls and presentation.

The official SRG 1 document states that IFRS S1 and IFRS S2 are the adopted standards for the private sector. SRG 1 explains how that adoption works in Nigeria rather than replacing those standards.

Every entity adopting the IFRS Sustainability Disclosure Standards must complete the readiness test assessment, including voluntary adopters. Reporting early is not a route around readiness.

The mandate itself is phased: voluntary adoption covers periods ending on or before 31 December 2027, public interest entities report for periods beginning on or after 1 January 2028, and SMEs from 1 January 2030. The FRC's 2026 announcement describes the assessment as the mechanism for evaluating preparedness.

Stage one asks for a board resolution, a gap analysis and an implementation plan. Stage two asks for the policies, materiality work, governance structure and training evidence, and stage three asks for registration, risk frameworks, metrics and targets, and internal control evidence.

Always confirm the current list and submission instructions in SRG 1 and any later FRC directives.

Stage one is due three months before the reporting period begins, stage two no more than three months after it begins, and stage three no more than six months after it begins. The exact dates depend on the entity's financial year, not simply the calendar year.

A December year-end and a June year-end will therefore work to different readiness calendars. Use the reporting deadlines page to translate the rule into dates, or check where you stand with the readiness score.

Preparation may involve a cross-functional team, but the entity and the professionals engaged in the reporting must be registered with the FRC. The disclosure must be signed by the member of management who oversees sustainability reporting, with their FRC number.

SRG 1 lists the professional and sustainability-specialist routes to registration. A company engaging an external adviser should ask for evidence of the person's or firm's FRC registration rather than rely on a job title.

The sustainability disclosure must be a clearly identifiable section placed immediately after the Directors' Report and before the financial statements. Its beginning and end must sit within that space rather than being scattered across the annual report.

The disclosure begins with the required compliance and policy information, then follows the applicable standard. Unrelated material should not obscure it.

A first-time reporter can apply the transitional reliefs in the adopted standards, including relief from disclosing Scope 3 emissions in the first annual reporting period, which the FRC roadmap confirms and SRG 1 supplements with further guidance. Electing a relief is itself a stage-two readiness item, so record the decision and its reasons.

Relief postpones a disclosure; it does not remove it. Read Scope 3 emissions to plan the second-year work.

Assign an owner to every required document, data stream, control and approval, then track completion against the entity's reporting calendar. Preserve source evidence and decisions as the work happens, because a retrospective reconstruction is slower and harder to defend.

Emvert keeps the emissions record behind the metrics-and-targets work, with evidence and approvals attached. It does not submit the readiness test or file through the FRC platform. Company secretaries coordinating the stages should read company secretary sustainability reporting.