In this second edition of Milliman’s “Climate-related risk and sustainability disclosures in Africa” report, we provide insights into the implementation of International Financial Reporting Standard (IFRS) sustainability standards S1 and S2, along with information on related disclosures and climate-related risk requirements. This second edition includes analysis of eight countries: Botswana, Ghana, Kenya, Mauritius, Namibia, Nigeria, South Africa, and Uganda—revealing various stages of implementation and adoption of the frameworks. There is some evidence that sustainability and climate-related risk management is starting to attract greater regulatory attention, although at the time of writing of this report there were no mandatory regulatory requirements for insurers in any of the markets considered. Our paper aims to highlight developments and trends in sustainability and climate-related regulations that could influence life insurers in each market.

Takeaways from each country:

• Botswana: Compliance with the standards is not a legal requirement under the Companies Act of 2003, but some enterprises are adopting the standards on a voluntary basis.
• Ghana: The Institute of Chartered Accountants Ghana has published a road map for the adoption of the standards, with compliance becoming mandatory in January 2027 for Significant Public Interest Entities, which include insurers.
• Kenya: The Institute of Certified Public Accountants of Kenya in 2024 published a “Roadmap for Adoption of IFRS Sustainability Disclosure Standards” for the adoption of IFRS S1 and IFRS S2.
• Mauritius: There are no mandatory requirements for Mauritian insurers for adoption of the standards, nor has the Mauritius Institute of Professional Accountants announced a roadmap.
• Namibia: The Institute of Chartered Accountants of Namibia has mandated the use of IFRS for financial reporting, but it is unclear whether S1 and S2 disclosures will become a regulatory requirement.
• Nigeria: The first country in Africa to adopt IFRS S1 and S2, Nigeria has adopted a phased approach to the implementation of the standards for non-government entities, with full mandatory implementation commencing in January 2028.
• South Africa: Compliance with the standards is not currently mandatory, though the Financial Sector Conduct Authority signalled its intent to mandate sustainability disclosures.
• Uganda: In September 2024, the Institute of Certified Public Accountants of Uganda announced the adoption of the S1 and S2, following a multi-year process led by the Uganda Integrated Reporting Committee.