NSE ESG reporting: 17 mandatory disclosures and 6 steps

Updated 10 November 2026

NSE ESG reporting rules require companies listed on the Nairobi Securities Exchange to report publicly on their environmental, social and governance (ESG) performance at least once a year. The NSE’s ESG Disclosures Guidance Manual, issued in November 2021, gave listed companies a one-year grace period. After that, they were expected to include a sustainability or ESG report in their annual integrated report, or publish a separate one, covering at minimum a set of mandatory ESG topics. This guide lists those topics, the six reporting steps the manual sets out, what boards must do and how the rules fit with the newer IFRS sustainability standards.

Checked on 9 November 2026 against the NSE ESG Disclosures Guidance Manual (November 2021), published on the UN Sustainable Stock Exchanges initiative site. The manual is guidance. Check the NSE and Capital Markets Authority for any later rules that apply to your company.

Who NSE ESG reporting applies to

The manual applies to every company listed on the NSE. It says listed companies “are to report publicly on their ESG performance at least annually”. It is also offered as a public good for unlisted companies, SMEs supplying listed groups, and state corporations that want to report on ESG.

The manual recommends the Global Reporting Initiative (GRI) Standards as the reporting framework. It notes that NSE-listed companies already reporting on ESG had chosen GRI, and that GRI was the most widely used framework in a KPMG survey. It also proposes a common set of metrics, so investors can compare companies in the same sector.

The mandatory NSE ESG disclosures

Chapter 6 of the manual lists the topics “that must be disclosed by listed companies in Kenya”. They fall into four groups:

To define these topics in the Kenyan context, companies are pointed to the CMA Code of Corporate Governance (2015), the GRI Standards, IFC Performance Standards, the UN Guiding Principles on Business and Human Rights, NEMA’s environmental regulations, Kenya’s National Climate Change Action Plan, the Occupational Safety and Health Act, the Consumer Protection Act and the Data Protection Act.

The list is a minimum. Companies are expected to add sector-specific topics found through a materiality assessment. Annex 6 of the manual gives examples of the topics most reported by sector. Companies are also encouraged to show how their work contributes to the UN Sustainable Development Goals.

The six steps in the NSE ESG reporting process

1. Governance over ESG integration and reporting. Define the roles of the board, the CEO and a sustainability manager. The sustainability manager recruits ESG champions, sets up a management committee, trains the reporting team, raises awareness and runs a project plan.
2. Situational analysis and stakeholder engagement. Identify the laws and policies you must follow and the stakeholders affected by your business.
3. Materiality analysis. Rank ESG issues by their importance to stakeholders and their impact on the business. Annex 3 has a sample scoring model.
4. Value creation. Assess the opportunities and risks behind each material topic and decide how to measure performance.
5. Content development. Adopt a reporting standard, apply the reporting principles, list your disclosures (mandatory plus sector-specific), check your data systems, then gather and report the information.
6. Assurance and internal controls. Consider external assurance and strengthen the internal controls and management systems that produce ESG data.

The manual includes a responsibility matrix for these steps, a sample report outline (Annex 1) and a data collection template (Annex 2).

What boards must do

The manual says the board holds the CEO and senior management to account for sustainability performance as a fiduciary duty. It cites three policy anchors: the Companies Act’s requirement for directors to consider environmental, social and community issues, the CMA Code’s call for ESG frameworks and disclosure, and the Mwongozo Code for state corporations.

In practice, it says boards of listed companies will form a committee to oversee sustainability, including ESG reporting. If a separate committee is not feasible, the work can sit in the strategy committee with clear ESG terms of reference. The board should also have the CEO appoint and resource a sustainability focal point.

How NSE ESG reporting fits with IFRS S1 and S2

The NSE manual focuses on impact reporting under GRI: how a company affects the economy, the environment and people. The IFRS sustainability standards, S1 and S2, focus on sustainability and climate risks that affect the company’s own financial prospects. Kenya’s adoption timetable is set out in our guide to the IFRS S1 and S2 timeline in Kenya. Many listed companies will need both: GRI-style impact disclosures for the NSE, and IFRS-style financial disclosures for investors and auditors. Planning one data system for both saves time.

Practical checklist for listed companies and their suppliers

• Map each mandatory topic to an owner, a data source and a metric, such as tonnes of CO2, lost-time injuries, training hours or the number of data breaches.
• Start carbon footprinting early. Emissions data usually takes the longest to collect.
• Screen suppliers. Supply chain screening is a mandatory topic, so SMEs selling to listed companies should expect ESG questionnaires.
• Check compliance obligations such as NEMA’s rules. Our EPR regulations guide covers packaging and waste duties.
• Look at how large companies report. Safaricom’s latest report is summarised in our story on its 2026 sustainable business report.
• Get board approval for the report and consider external assurance.

Frequently asked questions

Is NSE ESG reporting mandatory?

The NSE manual says listed companies must report on ESG at least annually and, after a one-year grace period, include an ESG report with the mandatory disclosures in their annual report or a separate report.

Which standard does the NSE recommend for ESG reporting?

The manual recommends the Global Reporting Initiative (GRI) Standards and asks companies to apply the GRI reporting principles.

What are the environmental topics in NSE ESG reporting?

Environmental compliance and emissions, including a carbon footprint assessment, are the mandatory environmental topics.

Do unlisted companies have to follow the NSE ESG manual?

No. It applies to listed companies, but the NSE offers it as a public good that any organisation can use.