What's the difference between IFRS S1 and IFRS S2?
IFRS S1 sets the general rules for reporting any sustainability risk or opportunity that could affect your finances. IFRS S2 applies those rules to climate, and asks for specific climate figures such as your greenhouse gas emissions.
You use them together. S2 can't be applied on its own, because the basic rules on what to include and how to present it sit in S1, as the IFRS Foundation's preparer guide explains.
Both standards ask for the same four areas, which ICAG lists in its assurance roadmap:
- 01
Governance
Who oversees these risks, and how often they review them.
- 02
Strategy
How the risks and opportunities affect your business plan and finances.
- 03
Risk management
How you find, assess and track them.
- 04
Metrics and targets
The numbers you report, and any goals you've set.
The standards took effect for periods starting on or after 1 January 2024. Ghana let companies use them voluntarily from that date and made them compulsory later, as the next section shows.
Who must report under IFRS S1 and S2 in Ghana?
Listed companies, banks, insurers, pension schemes, public limited companies and six named sectors report first, from 2027. Most other companies registered under the Companies Act, 2019 (Act 992) follow in 2028.
ICAG's adoption roadmap sorts companies into groups. Find yours below.
Group 1 reports from 2027. ICAG calls these Significant Public Interest Entities (SPIEs). They are:
- Companies listed on any recognised exchange in Ghana
- Banks and insurance companies
- Corporate trustees and registered pension schemes
- Public limited companies
- Private companies that own a public or regulated company
These six sectors are in Group 1 whatever their size:
- Upstream oil and gas companies with petroleum agreements
- Mining exploration and production companies
- Oil and gas refineries
- Car and vehicle makers
- Cement makers
- Power generators, unless the power comes from renewable sources
Group 2 reports from 2028. ICAG calls these Other Mandatory Adopters. It covers every other company under Act 992, apart from government bodies and the small companies described next.
Small private companies don't have to report. You're in this group if no one trades your shares or debt, you have no plan to list, and you don't hold money in trust for the public. Your revenue must also be GHS 50 million or less in each of the last two years, or your total assets GHS 40 million or less in the prior year. ICAG still encourages you to report.
Government bodies and not-for-profits that use public sector accounting standards will get a date later. ICAG will set it once the public sector standard setter publishes its own sustainability standards.
Not in Group 1 or 2? Your bigger customers may still ask you for emissions data, because IFRS S2 asks them about emissions in their supply chain.
When do you have to start?
Group 1 reports for financial years starting on or after 1 January 2027, and Group 2 a year later. An outside check of the report starts in each group's second year.
The outside check comes in steps. Limited assurance is a lighter review. Reasonable assurance is a fuller check, closer to a financial audit. ICAG set these dates in its assurance roadmap of 17 August 2026.
| Your group | First report | Lighter review (limited assurance) | Fuller check, with a lighter review of Scope 3 | Fuller check on everything |
|---|---|---|---|---|
| Group 1 (SPIEs) | Years from 1 Jan 2027 | Years from 1 Jan 2028 | 1 Jan 2029 to 31 Dec 2030 | Years from 1 Jan 2031 |
| Group 2 (Other Mandatory Adopters) | Years from 1 Jan 2028 | Years from 1 Jan 2029 | 1 Jan 2030 to 31 Dec 2031 | Years from 1 Jan 2032 |
| Companies reporting by choice | Any year from 2024 | Years from 1 Jan 2028 | 1 Jan 2029 to 31 Dec 2030 | Years from 1 Jan 2031 |
In the lighter review year, the checker leaves out three things: Scope 3 emissions, climate scenario analysis, and transition plans.
What this means for a December year end in Group 1
You collect data from 1 January 2027 and publish your first report in 2028, inside your 2027 annual report. Your 2028 report is the first one an outside firm checks.
Where does the report go, and who signs it?
The report goes inside your annual report, after the directors' report and before the auditor's report on your accounts. Two directors and your Chief Sustainability Officer sign it.
The adoption roadmap adds these rules:
- If you have no Chief Sustainability Officer, the person who does that job signs.
- The directors' report includes a statement of the directors' responsibility for the sustainability section.
- The section and its page number appear in the table of contents.
- You publish it at the same time as your accounts, for the same period.
- You show last year's figures beside this year's, unless a first-year exemption applies.
You can only say your report complies with IFRS S1 and S2 if it meets every requirement in both. When it does, ICAG asks for a clear statement saying so.
Order in your annual report
Signed by
Who can check your report, and what rules do they follow?
Only a Certified Sustainability Assurance Practitioner (CSAP) working through a firm licensed by ICAG. They follow ISSA 5000, the global standard for checking sustainability reports, from periods starting on or after 15 December 2026.
ICAG set this out in its ISSA 5000 roadmap. The main points:
- The firm needs at least one partner, director or principal who holds the CSAP title.
- Accountants and other professionals can both qualify. Audit firms and non-audit firms are licensed on the same terms.
- ICAG will publish a list of certified people and licensed firms, with their numbers, so you can check who you hire.
- The checker's report sits right before your sustainability report in the annual report.
- The firm signs in its own name. The lead CSAP's name and ICAG number appear beneath, with the date and the firm's address.
If you're in Group 1 with a December year end, you need a licensed firm in place for your 2028 report. Talk to firms during 2027, so they can look at how you collect data before the first checked year.
ISSA 5000 applies from
15 December 2026
Checked by a Certified Sustainability Assurance Practitioner (CSAP), working through a firm licensed by ICAG
Which other regulators check your report?
ICAG sets the rules, and your sector regulator checks that your annual report follows them. ICAG's ISSA 5000 roadmap names the Bank of Ghana, the National Insurance Commission and the Securities and Exchange Commission.
ICAG sets the rulesBank of GhanaNational Insurance CommissionSecurities and Exchange CommissionBanks
The Bank of Ghana's Climate-Related Financial Risk Directive took effect for banks in 2026, the Ghana Stock Exchange said in August 2026. Read it alongside this page, as it has its own rules.
Insurers
The National Insurance Commission checks your annual report.
Listed companies
The Securities and Exchange Commission checks your annual report. The Ghana Stock Exchange also released an updated Sustainability Disclosure Guidance Manual on 19 August 2026, built with GRI.
What can you leave out in your first year?
In your first year, you can report on climate only, and you can leave out Scope 3 emissions. You also don't have to show last year's figures.
These exemptions are built into IFRS S1 and S2, and ICAG's roadmap lets Ghanaian companies use them. The IFRS Foundation's preparer guide lists them:
Climate only
Report on climate risks and opportunities in year one. Add your other sustainability topics from year two.
No Scope 3
Leave out emissions from your supply chain and customers in year one.
No comparatives
Skip last year's figures in year one.
Your current method
If you already measure emissions another way, you can keep that method for year one.
The exemptions last one year. Plan to report in full from your second year, which is also when the outside check starts.
What should you do now?
If you're in Group 1 with a December year end, your first reporting year starts on 1 January 2027. Every fuel receipt and electricity bill from that day feeds your first report.
- 1Confirm your group against the lists above. Write down the answer and who agreed it.
- 2Pick your signers: two directors and your Chief Sustainability Officer, or the person doing that job.
- 3Give the board, or a board committee, the job of overseeing climate risks. Set dates for it to review them.
- 4Start collecting fuel, generator and electricity records for every site, every month, from January.
- 5List your climate risks and opportunities, and how each could affect your costs, income or assets.
- 6Talk to a licensed checking firm during 2027.
- 7Draft a practice report from your first six months of data, and fix the gaps before year end.
In Group 2? Follow the same steps a year later. Collecting data during 2027 gives you a full practice year.