As January 2026 begins, Kenya’s corporate sector finds itself at a critical juncture in its journey toward enhanced sustainability reporting. In exactly one year (on January 1, 2027) the Institute of Certified Public Accountants of Kenya will implement mandatory adoption of IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures) for all Public Interest Entities. The voluntary adoption phase, which began in January 2024 and continues through this period, has seen limited but encouraging uptake. What was intended as a steady 24-month rollout now transitions into a focused 12-month preparation window, with many institutions building momentum toward readiness.
Source: ICPAK’S Roadmap for Adoption of IFRS Sustainability Disclosure Standards in Kenya, September 2023
The progress, while modest, highlights early leaders who can inspire broader participation. Among Kenya’s Public Interest Entities (banks regulated by the Central Bank of Kenya, companies listed on the Nairobi Securities Exchange, insurance companies, and pension schemes), a small number have begun voluntary adoption. KCB Group, for instance, has published its 2024 sustainability report prepared in reference to the IFRS S1 and S2 Standards, showcasing the Group’s proactive approach ahead of the mandatory deadline. This report, the only one by a Kenyan financial institution to undergo limited assurance by Deloitte, serves as a valuable model for others.
To grasp the scope of this transition, it’s essential to understand the entities involved. ICPAK’s roadmap defines Public Interest Entities as companies whose failure or misconduct could disrupt the financial system or affect large groups of stakeholders, including the public. This definition encompasses financial institutions, listed companies across all sectors, and other entities with significant public impact. The comprehensive nature of this requirement means that Kenya’s adoption will affect not only banks and insurers but also telecommunications companies, manufacturing firms, consumer goods producers and other major corporations.
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The banking sector forms the largest and most systemically important group. Kenya’s licensed commercial banks, including major players like KCB Group (assets exceeding KSh 1.98 trillion), Equity Group Holdings, and Co-operative Bank of Kenya (each with substantial assets) underpin the financial system. These institutions collectively manage significant assets. KCB Group has emerged as a prominent early adopter with comprehensive compliance efforts, including a readiness assessment as a prerequisite stipulated by ICPAK ahead of mandatory IFRS S1/S2 adoption that covers its subsidiaries including the Kenyan branch. Co-operative Bank has engaged in sustainable finance initiatives and shared sustainability information, which may align with aspects of IFRS S1 and S2. While many banks have yet to publicly detail their voluntary adoption, these examples demonstrate feasible paths forward.
Insurance and pensions constitute another vital segment. Kenya’s insurance sector, overseen by the Insurance Regulatory Authority, features key players like Britam Holdings, CIC Insurance Group, Jubilee Holdings, and Liberty Kenya Holdings (all NSE-listed with public exposure). The Retirement Benefits Authority manages numerous pension schemes with considerable assets. Evidence of voluntary IFRS S1 and S2 adoption in these areas is emerging, offering opportunities for collaboration and knowledge sharing.
The capital markets add another critical dimension. The Nairobi Securities Exchange hosts actively trading listed companies spanning diverse sectors: telecommunications (Safaricom PLC), consumer goods (East African Breweries, British American Tobacco Kenya), financial services, manufacturing, real estate, and more. ICPAK’s mandate applies to all NSE-listed entities, regardless of sector. Some companies, such as Safaricom PLC, East African Breweries PLC, and Stanbic Bank PLC, have issued sustainability reports, though alignment with full IFRS S1 and S2 versus prior frameworks like GRI or TCFD varies. These efforts indicate growing awareness and potential for wider adoption across sectors.
Kenya’s corporate sector faces not a lack of guidance or expertise, but challenges in building the necessary data infrastructure for IFRS S1 and S2 disclosures. The WWF Sustainable Banking Assessment for Africa Report 2025 notes that many African banks, including those in Kenya, have room for improvement in disclosing portfolio greenhouse gas emissions and acknowledging nature-related risks. Kenyan banks demonstrate relative strength in ESG integration compared to regional peers, trailing only South Africa (a foundation that can support further advancements).
Specific data needs are evident. The Kenya Bankers Association’s assessment from the September 2024 IFRS S1/S2 template development workshop, involving representatives from multiple banks and ICPAK, highlighted the value of standardized tools for comparing sustainability performance and the current variability in reporting practices. Participating institutions often relied on manual processes and had opportunities to enhance integrated data systems, API connectivity, and validation protocols.
IFRS S2’s requirements underscore these areas for growth, calling for disclosures on greenhouse gas emissions, risk metrics, targets, and (for financial institutions) financed emissions across portfolios. KCB Group’s 2024 report, which included financed emissions calculations for key sectors (Motor Vehicle, Commercial Real Estate, and Business Loans) and screened substantial loans for environmental and social risks, illustrates achievable outcomes. For non-financial companies, the focus shifts to operational emissions, supply chain impacts, and sector-specific climate risks.
Related: Comparative analysis of global sustainability reporting frameworks
Kenya’s sustainability reporting landscape has evolved amid various frameworks issued by regulatory bodies over the past five years, leading to a mix of guidelines sometimes referred to as “ESG alphabet soup” (including GRI, TCFD, SASB, UNGC, and CDP) which can result in inconsistencies. The Central Bank of Kenya’s Guidance on Climate-Related Risk Management (2022) requires licensed commercial banks to report climate risks using TCFD-aligned frameworks, with mandatory reporting starting in September 2022. The Nairobi Securities Exchange’s ESG Disclosures Guidance Manual (2021) mandates annual ESG disclosures for listed companies following GRI Standards. The Capital Markets Authority’s Code of Corporate Governance includes ESG considerations for public issuers.
Data Sourced from: IFRS Foundation publishes jurisdictional profiles providing transparency and evidencing progress towards adoption of ISSB Standards, June 2025
Kenya’s path to IFRS S1 and S2 adoption, while challenging, aligns with global trends and offers lessons from other emerging markets. Nigeria’s Financial Reporting Council committed to early adoption at COP27 in 2022 and released a detailed roadmap in March 2024. Nigeria’s phased timeline sets mandatory adoption for PIEs in fiscal year 2028, providing additional preparation time. It includes readiness assessments requiring documentation on governance, data frameworks, and training, along with sector-specific programs and transitional guidance. This structured approach highlights how assessments can build capacity, a strategy Kenya is also adapting to strengthen its implementation.
To the other side of the Atlantic, Brazil provides a model of coordinated regulation. The country mandated IFRS S1 and S2 for publicly accountable entities starting January 1, 2026. Alignment among the Securities and Exchange Commission (CVM), Central Bank (BCB), and National Monetary Council (CMN) ensured consistent application across sectors. The Brazilian Committee on Accounting Pronouncements translated the standards into Portuguese, reducing barriers. For Kenya, where guidance from ICPAK, CBK, CMA, and IRA overlaps, Brazil’s inter-regulatory collaboration suggests pathways to more unified support.
Similarly, Singapore’s thematic phasing offers another insight. It prioritized IFRS S2 for climate disclosures, making it mandatory for listed issuers from fiscal years beginning on or after January 1, 2025, while consulting on IFRS S1. This sequencing builds infrastructure for complex elements like Scope 3 emissions first, integrating requirements into Singapore Exchange listing rules for effective enforcement. While Kenya boldly pursued simultaneous adoption of both standards, this choice underscores its strong commitment to comprehensive, integrated sustainability reporting from the outset
South Africa, Africa’s most developed financial market, adopts a largely voluntary approach. The Johannesburg Stock Exchange provides guidance aligned with TCFD and ISSB, without firm deadlines like Kenya’s. South African banks and corporations lead in ESG integration, bolstered by the King Code on Corporate Governance’s emphasis on integrated reporting since the early 2000s. This cultural foundation supports strong performance, yet voluntary systems can lead to uneven progress. Kenya’s mandatory framework, combined with its growing ESG baseline, positions it to achieve consistent, high-quality disclosures across all sectors.
These jurisdictions illustrate that successful adoption often involves extended timelines, coordination, phasing or established governance (elements Kenya has drawn upon to enhance its efforts). With its ambitious 2027 deadline and emerging strengths, Kenya has the potential to emerge as a regional leader in sustainability reporting.
Given the current landscape, preparing for January 2027 compliance offers a chance for collaborative advancement across Kenya’s entire corporate ecosystem, not just financial institutions. The start of 2026 presents a key moment for all Public Interest Entities to affirm their commitment. Organizations could consider declaring implementation priorities in January board meetings, assigning executive-level oversight and allocating resources for data system enhancements. Those that establish clear plans early will be well-positioned for success.
Looking ahead to January 2027, Kenya’s Public Interest Entities have the tools and examples to achieve meaningful compliance. With coordinated action from ICPAK, CBK, CMA, and IRA (such as enhanced support, assessments, and guidance) a positive outcome is within reach. Leading institutions like KCB and others can guide peers, fostering industry-wide progress across all sectors.
Kenya’s commitment to mandatory IFRS S1 and S2 by January 2027 reflects forward-thinking ambition to align with global standards ahead of many peers. As of January 2026, with early adopters paving the way, data capabilities evolving and regulatory frameworks in place, the sector is poised to turn challenges into strengths. This transition meets Kenya’s reporting needs while rigorously testing the corporate sector’s adaptability to sustainability demands across industries. Success in meeting the 2027 deadline, now just one year away as 2026 unfolds, positions Kenya as an ESG disclosure frontrunner and attracts global investment that prioritizes transparency and resilience. Strategic early action by leaders like KCB Group proves progress is achievable. Ultimately, Kenya’s potential as an ESG disclosure frontrunner depends on banks and PIEs taking affirmative direction to prioritize readiness assessments and capacity building today, seizing this opportunity to lead rather than follow.
