When does ESG reporting become mandatory in Uganda?
For accounting periods beginning on or after 1 January 2028 for the first group of entities, with further groups following in 2029 and 2030. Any entity may report voluntarily from 1 January 2026, as long as it first completes ICPAU's readiness test.
| Phase | Who | Accounting periods beginning on or after |
|---|---|---|
| Voluntary | All entities | 1 January 2026 |
| Mandatory | Listed entities, financial institutions including deposit-taking microfinance institutions, insurers and reinsurers, and government business entities using IFRS | 1 January 2028 |
| Mandatory | Retirement benefit schemes, large companies, SACCOs and all other public interest entities | 1 January 2029 |
| Mandatory | Small and medium enterprises | 1 January 2030 |
| Public sector | Government and other government organisations | To be set by ICPAU |
ICPAU chose this staggered approach to start with the entities that are best resourced and of most interest to investors.
Which entities report first in Uganda?
From 1 January 2028, four groups must report: entities whose debt or equity is traded on a public market, financial institutions, insurers and reinsurers, and government business entities that apply IFRS Accounting Standards.
Listed and issuing entities
Entities whose shares or debt trade on a domestic or foreign stock exchange or an over-the-counter market, or that are in the process of issuing such instruments.
Financial institutions
Commercial banks, merchant banks, mortgage banks, credit institutions, building societies and any institution the Bank of Uganda classifies as a financial institution, together with deposit-taking microfinance institutions.
Insurers and reinsurers
Any entity carrying on insurance business, as an insurer or reinsurer.
Government business entities
State-owned businesses that report under IFRS Accounting Standards.
Who reports from 2029 and 2030?
From 1 January 2029, retirement benefit schemes, large companies, savings and credit cooperative organisations (SACCOs) and all other public interest entities must report. From 1 January 2030, small and medium enterprises follow.
Which companies count as large or as SMEs is set by ICPAU's implementation guidelines for the IFRS for SMEs Accounting Standard, so check your classification there. Government and other public sector organisations will follow once the public sector sustainability standards being developed by the IPSASB are available, with a readiness programme in the meantime.
From 1 January 2029
From 1 January 2030
What is ICPAU's readiness test?
A compulsory assessment of how prepared an entity is to report under IFRS S1 and S2, carried out before it publishes its first sustainability report. It applies to every entity that reports, including those that choose to report voluntarily before their mandatory date.
ICPAU sets out the areas the test should cover, starting with governance and leadership: whether the board and senior management understand their oversight role, whether policies and frameworks support sustainability reporting, and whether a committee or person is responsible for the disclosures. It also covers stakeholder engagement and the areas of greatest judgement, such as Scope 3 emissions, scenario analysis and cross-industry metrics.
The test covers
Areas of greatest judgement
What reliefs apply in Uganda?
Uganda adopts the ISSB's five transition reliefs for the first year of reporting: climate-first reporting, an existing emissions method instead of the GHG Protocol, publication up to nine months after the year end, no comparative figures, and no Scope 3 emissions. ICPAU extends the Scope 3 relief by one extra year.
Climate first
Report on climate before other sustainability topics.
Your existing method
An existing emissions method instead of the GHG Protocol.
Up to nine months
Publication up to nine months after the year end.
No comparatives
No comparative figures.
No Scope 3
Extended by ICPAU for one extra year.
Abuse of the reliefs is prohibited
ICPAU also prohibits abusing the reliefs. Deliberately misapplying, manipulating or evading the reporting requirements under cover of a relief counts as abuse, so record which reliefs you elect and why.
When does assurance of sustainability reports start in Uganda?
Assurance begins after the first year of mandatory reporting and moves through four steps. For the 2028 group, limited assurance applies from 2029, reasonable assurance from 2030, reasonable assurance with limited assurance over Scope 3 from 2031, and full reasonable assurance from 2032.
| Group | Limited assurance | Reasonable assurance | Reasonable, limited over Scope 3 | Full reasonable assurance |
|---|---|---|---|---|
| 2028 group | 2029 | 2030 | 2031 | 2032 |
| 2029 group | 2030 | 2031 | 2032 | 2033 |
| SMEs | 2031 | 2032 | 2033 | 2034 |
The first two steps exclude Scope 3 emissions, scenario analysis and transition plans. The 2029 group follows one year later, moving to full reasonable assurance in 2033, and SMEs two years later, in 2034. In the first phase, assurance concentrates on Scope 1 and Scope 2 emissions, energy use and efficiency, governance and risk management.
Who can provide sustainability assurance in Uganda?
A qualified, experienced and independent assurance provider who holds an ICPAU practising certificate and the sustainability accreditation ICPAU will set. Assurance follows the International Standard on Sustainability Assurance, ISSA 5000.
Because some elements need specialist skills, an assurance provider may bring in third-party experts under ISSA 5000. Responsibility for the assurance opinion stays with the accredited provider.
The provider must hold