ESG Global Vision

Environment, corporate governance

Varies between participating states 

CORSIA applies to airline operators who fulfil the following criteria:

• their annual CO2 emissions from international flights using aeroplanes with a take-off mass greater than 5,700kg exceed 10,000 tonnes (all major carriers meet this relatively low threshold);
• they are responsible for international flights (flights by state aircraft and humanitarian, medical, and firefighting flights, as well as flights before or after such flights which are carried out by the same aeroplane and are needed for these activities, are not included); and
• they are registered in one of the participating states (see the list as of 1 January 2026 here; notable omissions include India and China).

In 2010, the International Civil Aviation Organisation (ICAO), a United Nations Agency that sets global standards and regulations for international civil aviation, adopted a sectoral aspirational goal for carbon neutral growth from 2020 onwards. Whilst operational and technological improvements are seen as a key part of achieving this goal, the ICAO took the view that a market based scheme was required to fill the remaining emissions gap and to achieve carbon neutral growth. Accordingly, the International Standards and Recommended Practices for the implementation of CORSIA were adopted as an Annex to the Chicago Convention in 2016, to apply to all of ICAO’s 193 member states from 1 January 2019.

CORSIA is being implemented in three phases:

• The Pilot Phase (2021-2023) and the First Phase (2024-2026). During these phases participation by ICAO member states was voluntary. 126 member states participated, with flights between participating states subject to reporting and offsetting requirements.
• The Second Phase (2027-2035). During this phase, with some exemptions, such as for Least Developed Countries and Small Island Developing States, participation will become mandatory for all ICAO member states and all international flights will be subject to offsetting requirements. The Second Phase will be split into three-year compliance periods.

In scope airline operators are under the following obligations:

• To monitor and report emissions from international flights on an annual basis.
  • At the beginning of each 3-year compliance period, an operator is required to submit an Emissions Monitoring Plan to its administering state which, once approved, the operator will use for the entire compliance period.
  • Under the plan, the operator is required to monitor and record its fuel use for international flights over the course of each calendar year. The operator must then estimate their annual CO2 emissions and report them to the national authority of their administering state by 30 April the following year. To guarantee the accuracy of the data reported, operators will need their annual emissions report to be verified by an impartial third-party verification body prior to submission.
  • Aggregated emissions are required to be reported by each administering state to ICAO, which will publish the total emissions from individual operators.
• To offset their emissions.
  • Under the scheme, the administering state calculates the annual offsetting requirements for each operator by multiplying the operator’s CO2 emissions by a ‘Growth Factor’, which is calculated by the ICAO and represents the percentage growth of the aviation sector’s international CO2 emissions covered by CORSIA’s offsetting requirements in a given year compared to the sector’s baseline emissions (being 85% of 2019 emissions levels).
  • Upon completion of each 3-year compliance period, the operator will have to show they have met their offsetting requirements by purchasing and cancelling the appropriate number of certified CORSIA Eligible Emissions Units (“CEEUs”) (each representing a tonne of CO2). The price of these units varies considerably depending on the type of project ($0.50 to $45/tCO2e during 2020-2021 with a weighted average of $3.08/tCO2eq in 2021).
  • Operators can also reduce their offsetting requirements by using CORSIA Eligible Fuels (“CEFs”) that meet the CORSIA sustainability criteria, which includes fuels with at least 10% lower CO2e emissions on a life-cycle basis compared to a reference fossil fuel value of 89.1 gCO2e/MJ. It is worth noting that as the baseline for calculating emissions reduction targets is 85% of 2019 emissions levels, offsetting requirements will only cover the growth in emissions since 2019 and therefore it is anticipated that the percentage of their total emissions that operators will have to offset will remain modest for the first few years of implementation of the scheme.

For more information, please follow the link here.

Penalties and enforcement:

National aviation authorities of participating states determine the sanctions for non-compliance, so these vary between countries. In the UK, for example, typical civil penalties can include a £20,000 penalty with a further daily penalty of £500 for failing to: (i) apply or revise an emissions monitoring plan; (ii) monitor emissions properly; or (iii) submit emissions reports. In recent consultations, the UK government has indicated that the penalties for failing to cancel CEEUs on time in line with an airline’s offsetting requirements would be £100 for each uncancelled unit.

Mandatory regulation

In force

All public companies; private companies that are holding companies of public companies or other regulated entities; 'concessioned' or privatised companies and regulated private companies.

The NCCG sets out 28 broad areas of focus and sets out corporate governance requirements in relation to each category. Risk management, sustainability, and ethical culture are all examples of the NCCG's areas of focus. The NCCG demands, for example, that a company's annual company report contains a board statement on the company's ESG activities from the year.

Mandatory guidelines

in force

Public Companies

The SCGG creates additional mandatory requirements for public companies. The requirements (e.g. in relation to board structure and composition, audit committees,  disclosure requirements, and the  requirement for internal anti-corruption policies) seek to improve the standards of transparency, accountability and good corporate governance of public companies, without unduly inhibiting enterprise and innovation.

Disclosure guidelines

In force

Entities listed on the Nigerian Stock Exchange.

Under the Nigerian Stock Exchange Sustainability Disclosure Guidelines, it is a mandatory requirement for Premium Board (the high-end listing segment of the Nigerian Stock Exchange reserved for issuers with a minimum market capitalisation of NGN200 billion and the highest corporate governance standards) listed companies to undertake sustainability reporting. However, all issuers are encouraged to apply them. The report should cover specified items such as (i) the company's operating standards for purchasing and selecting suppliers, (ii) the impact of the company's products and services on stakeholders and (iii) the company's diversity and employee make-up.

Federal law

In force

Employers with three employees or more

The PRA requires employers to maintain a group life insurance policy on behalf of each of their employees. The employer has to contribute a minimum of three-times the employee’s annual total emolument (i.e. the employee's basic salary, housing allowance and transport allowance) by no later than the commencement of the cover, for the provision of cover to the employee against death.

The PRA also created a contributory pension scheme (“CPS”) applicable to all employers with three or more employees. Under the CPS, employers are required to deduct at least 8% of the sum of each employee’s basic salary, housing allowance and transport allowance monthly (“Monthly Emoluments”) and pay the same into the employee’s retirement savings account (“RSA”) on a monthly basis. Employers are also required to contribute at least 10%  of the employee’s Monthly Emoluments into the employee’s RSA monthly.

Federal law

In force

Employers from all sectors

The ECA provides employees who suffer death, injury, disease, or disability in the course of employment with a statutory right to claim for compensation.

Federal law

In force

Factory employers

The FA implements measures to protect the health and safety of factory employees. For example, the FA sets minimum standards with regard to factory safety equipment and sanitation.

Environment, corporate governance

Varies between participating states 

CORSIA applies to airline operators who fulfil the following criteria:

• their annual CO2 emissions from international flights using aeroplanes with a take-off mass greater than 5,700kg exceed 10,000 tonnes (all major carriers meet this relatively low threshold);
• they are responsible for international flights (flights by state aircraft and humanitarian, medical, and firefighting flights, as well as flights before or after such flights which are carried out by the same aeroplane and are needed for these activities, are not included); and
• they are registered in one of the participating states (see the list as of 1 January 2026 here; notable omissions include India and China).

In 2010, the International Civil Aviation Organisation (ICAO), a United Nations Agency that sets global standards and regulations for international civil aviation, adopted a sectoral aspirational goal for carbon neutral growth from 2020 onwards. Whilst operational and technological improvements are seen as a key part of achieving this goal, the ICAO took the view that a market based scheme was required to fill the remaining emissions gap and to achieve carbon neutral growth. Accordingly, the International Standards and Recommended Practices for the implementation of CORSIA were adopted as an Annex to the Chicago Convention in 2016, to apply to all of ICAO’s 193 member states from 1 January 2019.

CORSIA is being implemented in three phases:

• The Pilot Phase (2021-2023) and the First Phase (2024-2026). During these phases participation by ICAO member states was voluntary. 126 member states participated, with flights between participating states subject to reporting and offsetting requirements.
• The Second Phase (2027-2035). During this phase, with some exemptions, such as for Least Developed Countries and Small Island Developing States, participation will become mandatory for all ICAO member states and all international flights will be subject to offsetting requirements. The Second Phase will be split into three-year compliance periods.

In scope airline operators are under the following obligations:

• To monitor and report emissions from international flights on an annual basis.
  • At the beginning of each 3-year compliance period, an operator is required to submit an Emissions Monitoring Plan to its administering state which, once approved, the operator will use for the entire compliance period.
  • Under the plan, the operator is required to monitor and record its fuel use for international flights over the course of each calendar year. The operator must then estimate their annual CO2 emissions and report them to the national authority of their administering state by 30 April the following year. To guarantee the accuracy of the data reported, operators will need their annual emissions report to be verified by an impartial third-party verification body prior to submission.
  • Aggregated emissions are required to be reported by each administering state to ICAO, which will publish the total emissions from individual operators.
• To offset their emissions.
  • Under the scheme, the administering state calculates the annual offsetting requirements for each operator by multiplying the operator’s CO2 emissions by a ‘Growth Factor’, which is calculated by the ICAO and represents the percentage growth of the aviation sector’s international CO2 emissions covered by CORSIA’s offsetting requirements in a given year compared to the sector’s baseline emissions (being 85% of 2019 emissions levels).
  • Upon completion of each 3-year compliance period, the operator will have to show they have met their offsetting requirements by purchasing and cancelling the appropriate number of certified CORSIA Eligible Emissions Units (“CEEUs”) (each representing a tonne of CO2). The price of these units varies considerably depending on the type of project ($0.50 to $45/tCO2e during 2020-2021 with a weighted average of $3.08/tCO2eq in 2021).
  • Operators can also reduce their offsetting requirements by using CORSIA Eligible Fuels (“CEFs”) that meet the CORSIA sustainability criteria, which includes fuels with at least 10% lower CO2e emissions on a life-cycle basis compared to a reference fossil fuel value of 89.1 gCO2e/MJ. It is worth noting that as the baseline for calculating emissions reduction targets is 85% of 2019 emissions levels, offsetting requirements will only cover the growth in emissions since 2019 and therefore it is anticipated that the percentage of their total emissions that operators will have to offset will remain modest for the first few years of implementation of the scheme.

For more information, please follow the link here.

Penalties and enforcement:

National aviation authorities of participating states determine the sanctions for non-compliance, so these vary between countries. In the UK, for example, typical civil penalties can include a £20,000 penalty with a further daily penalty of £500 for failing to: (i) apply or revise an emissions monitoring plan; (ii) monitor emissions properly; or (iii) submit emissions reports. In recent consultations, the UK government has indicated that the penalties for failing to cancel CEEUs on time in line with an airline’s offsetting requirements would be £100 for each uncancelled unit.

Federal law

In force

Any entity operating within Nigerian territory

NOSDRA created an agency whose responsibility is to prepare for, detect and respond to all oil spillages in Nigeria. Where an oil spill occurs, NOSDRA creates a requirement for the responsible party to report, and immediately seek to remedy, the spill.

Federal law

In force

The National Park Service (the "NPS") are a quasi-governmental organisation with the power to enforce against any entity

The NPS, as created by NPSA, are responsible for the preservation, enhancement and protection of wild animals and plants and other vegetation in Nigerian National Parks. Their duties and objectives relate to items such as the conservation of select endangered species. The NPSA affords the NPS the power to "do anything which in its opinion is calculated to facilitate the performance of its functions.

Federal law

In force

Issues relating to the exploration and exploitation of solid minerals in Nigeria.

The Nigerian Minerals and Mining Act  regulates the exploration of solid minerals in Nigeria. It prohibits unauthorised exploration or exploitation of minerals. Authorisation is granted through a series of different types of license, depending on the nature of the exploration intended.

With a view to protecting the natural environment and local communities, the Nigerian Minerals and Mining Act  takes measures such as (i) the prohibition of mining in certain areas, (ii) reserving certain rights of owner or occupier and (iii) obliging the preparation and submission of an environmental impact assessment statement before a mining project.

Federal law

In force

Every company producing oil and gas in Nigeria.

The Associated Gas Re-injection Act is focused on the efficient use of resources. Any company producing oil and gas in Nigeria is required to submit a plan to show that they will either a) utilise all associated gas contained within their project site or b) re-inject any associated gas not utilised in the industrial project. The Associated Gas Re-injection Act  also prohibits the flaring of associated gas without the permission in writing of the Minister of Petroleum.

Federal law

In force

Issues relating to the use of radioactive substances, material, equipment, emitting and generating ionising radiation.

The Nuclear Safety and Radiation Protection Act  establishes the Nigerian Nuclear Regulatory Authority (the "Authority"). The Authority oversee the use of radioactive substances, material and equipment. The Nuclear Safety and Radiation Protection Act also provides for the Authority to create regulation to protect the environment from the harmful effects of ionising radiation.

Federal law

In force

Any vessel operating within Nigerian waterways. Nigerian naval ships are exempted.

This Oil In Navigable Waters Act  makes provisions to prevent the discharge of oil into the waters of Nigeria, such as by mandating ships to be equipped in a certain manner. It came into force as part of the implementation of the terms of the International Convention for the Prevention of Pollution of the Sea by Oil 1954 (as amended in 1962 and 1969).

Federal law

In force

All relevant government authorities(Chapter II, section 13).

The State shall protect and improve the environment and safeguard the water, air and land, forest and wildlife of Nigeria.

Non-binding guidance

in force

Banks, discount houses and development finance institutions in Nigeria.

The Sustainable Banking Principles recommend a management approach that balances a consideration of Nigeria's environmental and social risks with the business opportunities available in the country.

The Principles, for example, demand a commitment to integrate environmental and social considerations into business activity decision-making processes in order to avoid, minimise or offset negative impacts.

Federal law

In force

Employers with five or more employees, or fewer than five employees but an annual turnover of 50,000,000 NGN (fifty million Naira).

The Industrial Training Fund (the "ITF") is a fund dedicated to the training of indigenous manpower.  Employers who meet the ITFA’s  conditions are required to contribute 1% of their total annual payroll to the ITF. To encourage employer-initiated training programmes focused on indigenous staff and students, employers may be entitled to a 50% refund of their total contributions if they evidence their training courses in accordance with the ITF’s reimbursement schemes.

Federal law

In force

Nigerian workers earning a basic salary of at least N3,000 (three thousand Naira); indirectly applicable to employers, who should make the deductions.

The National Housing Fund (Establishment) Act establishes the National Housing Fund and provides that 2.5% of the monthly income of an employee earning the national minimum wage and above, either in public or private sector, shall be contributed to the National Housing Fund , and any contributor who does not have an outstanding loan with the Federal Mortgage Bank of Nigeria and has attained 60 years of age and 35 years of service or such other retirement age or years of service as may be provided in any law in force in Nigeria is entitled to a refund of contribution at an interest rate of 2% per annum, within 3 months of application.