Do listed companies in Zimbabwe already have to report on sustainability?
Yes. Listed companies must submit sustainability reports for financial years beginning on or after 1 January 2024, under section 399 of Statutory Instrument 134 of 2019, the Zimbabwe Stock Exchange listing rules, together with ZSE Practice Note 16 and VFEX Practice Note 2.
Most listed companies prepare those reports using the GRI Standards. That requirement continues, and from 2028 listed companies also move to IFRS S1 and S2 under PAAB's roadmap. Assurance of the current sustainability reports is not yet required.
Required today, from 1 January 2024
When does IFRS S1 and S2 reporting become mandatory in Zimbabwe?
It depends on the category of the entity. Category 1 entities can report voluntarily in 2026 and 2027 and must report from 2028, while Category 2 and Category 3 entities can report voluntarily until 2028 and must report from 2029.
| Category | Who is in it | Voluntary | Mandatory from |
|---|---|---|---|
| Category 1 | Listed companies, banking institutions and building societies, state-owned enterprises applying IFRS, and high environmental impact entities applying IFRS | 2026 and 2027 | 2028 |
| Category 2 | Insurance and reinsurance companies, life and funeral assurers, deposit-taking microfinance institutions, pension funds, and other public interest entities | 2026 to 2028 | 2029 |
| Category 3 | Non-deposit-taking microfinance institutions, micro-insurance entities, and entities without public interest | 2026 to 2028 | 2029 |
| Category 4 | Public sector entities applying IPSAS | A separate roadmap will be issued | — |
The first mandatory year is a transitional one: IFRS S1 and S2 apply, but entities can use the reliefs in the standards and PAAB's own exemptions. Category 1 entities must reach full compliance with IFRS S2 by 2030 and with both standards by 2031.
Which companies are high environmental impact entities?
High environmental impact entities are companies whose operations significantly affect the environment, or are significantly affected by environmental and climate-related matters. They include entities carrying out activities that require an Environmental Impact Assessment under the Environmental Management Act.
For other companies, PAAB asks management to use professional judgement, considering the nature of the business, its scale, its emissions and its exposure to climate risks. A company that falls in this group joins Category 1 and reports from 2028.
Management's judgement considers
What reliefs apply in Zimbabwe?
On top of the reliefs in IFRS S1 and S2, PAAB grants three exemptions of its own. Companies need not consider the SASB Standards, and need not disclose Scope 3 emissions, during the voluntary years and the first three mandatory years, and they are exempt from industry-based metrics in the first mandatory year.
No SASB Standards
During the voluntary years and the first three mandatory years.
No Scope 3
During the voluntary years and the first three mandatory years.
No industry-based metrics
In the first mandatory year.
Still required from the first mandatory year
Cross-industry metrics, such as Scope 1 and Scope 2 emissions, are still required from the first mandatory year. That makes measured energy and fuel data the first thing a Zimbabwean company needs to have in place.
When does assurance of sustainability reports start in Zimbabwe?
Assurance is phased in after reporting starts. For Category 1, the first two mandatory years need only management or internal audit attestation, limited assurance is required from 2030 and reasonable assurance from 2032.
Category 1
Category 2
Category 3
Category 2 entities move to limited assurance in 2031 and reasonable assurance in 2033, and Category 3 entities to limited assurance in 2032 and reasonable assurance in 2033. Assurance will follow the International Standard on Sustainability Assurance (ISSA) issued by the International Auditing and Assurance Standards Board, by providers accredited under criteria PAAB will develop, who must be independent under the IESBA Code of Ethics.
How ready are Zimbabwean companies?
PAAB found that most Category 1 companies already produce sustainability reports, some since 2019, but that the practice has not yet matured and knowledge of the ISSB standards remains limited among most preparers. Smaller companies may need more time to build their data systems and people.
That is why the roadmap phases the requirements, starts capacity building with Category 1, and gives two voluntary years before mandatory reporting. Companies are expected to use them to assess their gaps and build the systems that produce reliable data.