NIGERIA Law and Practice Contributed by: Yeye Nwidaa, Mariam Olayinka Akinyemi and Toluwalase Oliver-Jude, Jackson, Etti & Edu
and ensures regular updates in response to emerging risks. Operational responsibility for managing geopolitical and other enterprise risks is delegated to manage - ment, particularly the Risk and Compliance functions, which report periodically to the board. Sanctions compliance is also subject to board over - sight, usually through the Audit or Risk Committee. Management is responsible for implementing sanc - tions screening and compliance controls to prevent dealings with sanctioned individuals, entities or juris - dictions, while the board ensures appropriate systems are in place and receives regular compliance updates.
and ESG reporting. The federal government has for - mally endorsed the IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Infor - mation) and IFRS S2 (Climate-related Disclosures) standards, aligning Nigeria with globally recognised sustainability reporting frameworks. In support of this transition, key regulators including the FRCN, SEC, NGX and CBN have developed a co- ordinated roadmap to progressively transition com - panies from voluntary to mandatory ESG disclosure. The current phase is a voluntary adoption period, dur - ing which companies are expected to begin building internal capacity, strengthening data collection sys - tems and integrating ESG considerations into gov - ernance, risk management and financial reporting processes. This transition period is intended to allow organisations to align their reporting frameworks with IFRS S1 and S2 requirements ahead of full implemen - tation. This voluntary phase runs until 31 December 2027, after which mandatory compliance will be phased in. From 1 January 2028, ESG reporting will become mandatory for all public interest entities in Nigeria. At that stage, affected entities will be required to provide structured, consistent and auditable sustainability dis - closures, including climate-related risks and opportu - nities, governance oversight and impact on financial performance. This regulatory shift represents a major evolution in Nigeria’s corporate reporting environment, moving from fragmented sustainability disclosures toward a standardised, globally aligned ESG reporting regime.
7. Environmental, Social and Governance 7.1 ESG Requirements
ESG reporting in Nigeria is currently governed by a combination of corporate governance codes, capital market regulations, financial reporting standards and sector-specific requirements, with a gradual transition
toward IFRS S1 and S2 adoption. Companies are generally required to:
• disclose annual compliance with the NCCG 2018, including clear information on governance struc - tures, policies and practices, and environmental and social risks and opportunities; • file corporate governance and material ESG risk disclosures with the SEC, particularly for public companies; • provide ESG-related disclosures under NGX listing rules, including material ESG risks; • include governance and risk disclosures in finan - cial reporting in line with FRCN requirements and applicable IFRS standards; and • comply with sector-specific ESG requirements issued by regulators such as the CBN, NAICOM and others, depending on industry. 7.2 ESG Developments Nigeria’s corporate landscape is currently undergoing a significant transformation in relation to sustainability
8. Artificial Intelligence 8.1 Board Oversight of AI
In Nigeria, board oversight of AI is currently governed by a combination of general corporate governance duties, data protection law, sector-specific regulation and emerging national AI policy, rather than a dedi - cated AI statute. Boards are not required to establish AI-specific committees nor appoint AI specialists, but are expected to actively oversee AI-related risks,
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