By Innocent Okwuosa

The International Sustainability Standard Board (ISSB) is currently enhancing Sustainability Accounting Standards Board (SASB) priority Standards. The SASB Standards are an important source of guidance for Nigerian entities implementing International Financial Reporting Standards (IFRS S1) and (S2) in the absence of specific IFRS Sustainability Disclosure Standards.

One sustainability related topic, which first appeared in the 2025 amendment of the nine priority industries and now in the 2026 amendment of the remaining three industries is Genetically Modified Organisms (GMOs).  According to SASB standards, GMOs are defined as organisms, except for human beings, in which genetic material has been altered in a way that does not occur naturally by mating or natural recombination.

Africa Faith and Justice define GMO as an organism created in a Laboratory by taking genes from one species and forcing them into an entirely unrelated species – to achieve a new trait or characteristic that is not possible in nature. GMO is of much concern to Nigerian consumers and the public in general.

This concern may have triggered the House of Representatives Committee on Agricultural Production, to conduct a public hearing on GMO and food safety on November 18, 2024. Punch newspaper of November 19, 2024 reported that at the public hearing, anti-GMO campaigners under the aegis of GMO-Free Nigeria Alliance, made up of about 200 individuals and groups expressed concern over what they call the health and environmental impact of consuming genetically modified foods. The group urged the National Assembly to put a complete ban on GMOs, stressing that external bodies bent on introducing GMOs into the country are partly responsible for the challenges of insecurity in Nigeria. Here GMO is linked to insecurity in Nigeria.

The perception of the dangers of GMO is such that the National Cotton Association of Nigeria reported that: no other plant has been able to germinate on the farmlands where the GMO seeds were planted, even after four years. And to them, continuing this path holds serious implications on Nigeria’s food sovereignty, on our biodiversity/environmental sustainability, and our health.”

There is a perception among GMO-Free Nigeria Alliance that you can do to Nigerians whatever you want to do, and nothing will happen. According to them, that explains some of the institutional arrogance that we witness today to the point that someone was so audacious as to say it is better to eat and die than not to eat and die. This is a perception of GMO food causing death.

The fear of the safety of GMO food remains a topical issue given an article published on Thisday newspaper of 12/07/2026 titled: Separating Grains from Chaff: Truth About GMO Safety, Identity in Nigeria by Dr Bernard Ehirim, the Programme Officer for Product Stewardship at the African Agricultural Technology Foundation (AATF). He argues that the root of public discomfort with GMO often begins with the name itself, “Genetically Modified Organism”, which sounds clinical, and vaguely dystopian.

The perception that GMO has health and food safety implications may have prompted the Minister of Agriculture and Food Security, Abubakar Kyari, during that public hearing, to say that the Federal Government would do everything possible to safeguard the lives of Nigerians. No matter the assurance the Minister gives, perception is real and is what drives the demand for such agricultural products in Nigeria. As such this sustainability topic is of much concern to consumers and hence investors in Nigeria whose sustainability information needs IFRS S1 & S2 want to satisfy.

However, the ISSB has recommended the removal of all disclosures around GMO. In the July 2025 amendment the ISSB has proposed the discontinuance of disclosure of Revenue from products labelled as (1) containing genetically modified organisms (GMOs) and (2) non-GMO as one of the industry metrics under Product Labelling & Marketing for Food Processing Industry. The reason given for this recommendation can be found in BC 141 (b) where it stated that the removal of the metric is because both investors and preparers suggested that it does not lead to decision-useful information about how an entity manages a risk or opportunity that could affect its prospects. Wonderful, I will say!!

In the March 2026 Exposure Drafts, ISSB has proposed to remove the GMO Management disclosure topic and associated metric for Agricultural Products Industry SASB Standard. The reason given for this can be found in BC94-95 where it stated as follows:

During the 2010s, when the Agricultural Products SASB Standard was developed, GMOs were a major focus of public debate and regulatory activity worldwide, but research and initial stakeholder feedback suggest that user interest in GMO-related disclosures has declined since then. ….. In the ISSB’s view, potential effects on entities’ prospects from GMO-related risks and opportunities have decreased due to a more neutral attitude from consumers and regulatory stability.

This argument does not reflect the Nigerian situation described above. The Nigerian situation accords more with the original reasoning behind the demand for this disclosure by the SASB standard which was expressed as a concern in Topic Summary for Agricultural products Industry as follows:
GMO technology has enabled improvements in crop yield…, but consumer concerns persist regarding the perceived health, environmental or social impacts related to the cultivation and consumption of GMOs.

Some jurisdictions have banned the use or cultivation of GMOs.

Research suggests that only about eleven of the fifty-four African nations have approved the cultivation of GM crops, meaning it is still an issue in the remaining forty-three countries.

Consequently, I argue that disclosure of (1) revenue from products labelled as containing GMOs as a metric under Product Labelling & Marketing for Food Processing Industry and (2) GMO Management and associated metric for Agricultural Products Industry should not be discontinued.  This is because such disclosure can be used as effective communication to address misconception, reputational risks and revenue loss that may arise because of consumer perception in our jurisdiction and Africa as a whole.

There is no doubt that this disclosure will be of interest to investors given its potential to affect revenue and hence the prospect of entities in the Agricultural Products and Food Processing Industries.

In the context of the above, GMO disclosure is material information.

A clear guidance on identification and materiality assessment of SRRO under IFRS S1 & S2 is to focus on those SRRO that can affect the prospect of an entity (i.e., its financial performance, position, cash flows, access to capital and cost of capital).

IFRS S1 (para 18) states that in the context of sustainability-related financial disclosures, information is material if omitting, misstating or obscuring that information could reasonably be expected to influence decisions that primary users of general-purpose financial reports make on the basis of those reports.

Since IFRS S1 & S2 are global baseline sustainability information and local jurisdictions are given the opportunity to regulate local issues of concern, GMO may be included as a sustainability topic that local jurisdictions are allowed to dictate its disclosure.

One lesson to take away from the above is that there are always points of convergence between financial materiality and impact materiality in the implementation of IFRS standards.

Dr Okwuosa is the immediate past Chairman, Nigerian Integrated Reporting Committee (NIRC); the 59th President, Institute of Chartered Accountants of Nigeria; and an Adjunct Associate Professor at Pan Atlantic University, Lekki, Lagos.