Sustainability Reporting Tanzania: What NBAA Requires in the Governance Report from 2027

This guide explains sustainability reporting in Tanzania after the August 2026 amendment: who is caught, what goes in the governance report, how assurance will arrive, what Zanzibar entities should assume, and a worked TZS budget for a Dar es Salaam manufacturer's first report.

What changed in August 2026?

The National Board of Accountants and Auditors (NBAA) has amended the rule it made in 2024 on sustainability reporting. Its Governing Board approved Technical Pronouncement No. 1 of 2026 at its 202nd ordinary meeting on 30 July 2026. NBAA published the text in August 2026 and announced it on 21 August 2026.

The revised pronouncement makes five changes that matter to a finance team:

• Fixed location. Sustainability disclosures stay in the report by those charged with governance (the TCWG report), placed after that report under the heading "Sustainability Disclosures".
• Optional extra report. An entity may also publish a stand-alone report under IFRS S1 and IFRS S2. The governance report disclosures must not be "omitted, diminished or replaced" because of it.
• Public sector clarified. Public sector entities keep applying IFRS S1, S2 and later ISSB standards until public sector sustainability standards are issued and in force.
• Readiness duty. Reporting entities and audit firms must each complete a readiness assessment and close the gaps it finds.
• Assurance date pending. NBAA will announce when ISSA 5000 applies in Tanzania. Until then auditors keep reporting under ISA 720.

The amendment applies to annual reporting periods beginning on 1 January 2027, and NBAA encourages early adoption. For a calendar-year company, the first report under the new rule covers the year ending 31 December 2027 and appears in 2028.

What the law says

NBAA's power comes from the Accountants and Auditors (Registration) Act, Cap. 286. Section 4 lists the Board's functions, including to "stipulate accountancy or auditing standards and guidelines as appropriate" and to "ensure the compliance of the standards and guidelines by the subjects". NBAA repeats this on its mandatory functions page. The pronouncement itself cites Cap. 286 [R.E. 2002] without a section number.

Four NBAA instruments now work together. The Companies Act supplies the company-law hooks.

Section 4 of the 2026 pronouncement keeps the 2024 pronouncement in force except where amended. Both must be read with the 2018 pronouncement. NBAA's own announcement links a second copy of the text, filed as Technical Pronouncement No. 1 of 2026. We read both. They carry the same sections, dates and requirements.

Who is affected

The 2024 pronouncement made IFRS S1 and S2 mandatory for PIEs and public sector entities, and encouraged everyone else. The 2026 amendment addresses "all reporting entities" in section 2, so any entity that reports under the pronouncement follows the new placement rule.

• Listed and listing companies on the Dar es Salaam Stock Exchange (DSE) or another public market.
• Banks, insurers, securities dealers and funds that hold assets in a fiduciary capacity.
• Large commercial entities with gross capital of at least TZS 50 billion in essential sectors.
• Public sector entities, which the 2026 text says must comply with section 2 as well.
• Audit firms registered with NBAA, which carry their own readiness duty.
• Foreign-owned subsidiaries that meet any PIE test. The IFRS Foundation profile says foreign publicly accountable entities report under the same framework.

Entities outside these groups may report voluntarily. A voluntary reporter that claims compliance with IFRS S1 and S2 must meet all of their requirements.

Is my company a public interest entity?

NBAA does not define a PIE in the 2024 or 2026 text. It points to Technical Pronouncement No. 1 of 2018. That pronouncement treats a commercial entity as a PIE if it has any one of three characteristics.

Test (c) needs both limbs. A TZS 60 billion property company outside the listed sectors is unlikely to qualify on size alone. A TZS 60 billion edible oil processor probably does. The 2018 text does not define "gross capital". Agree the measure with your auditor and record the reasoning in the board minutes.

If you were a PIE in 2025, the new rule does not create your duty. It changes where and how you report from 2027.

What must the Sustainability Disclosures section contain?

The content comes from the ISSB standards. IFRS S1 covers all sustainability-related risks and opportunities that could affect cash flows, access to finance or cost of capital. IFRS S2 applies the same structure to climate. Both were issued in June 2023.

Each standard asks for four core areas:

• Governance: the board's oversight of sustainability risks and how management carries it out.
• Strategy: the risks and opportunities, their effect on the business model and the plan to respond.
• Risk management: how risks are identified, assessed, prioritised and monitored.
• Metrics and targets: performance measures, including greenhouse gas emissions under IFRS S2.

The 2026 pronouncement adds three presentation rules. The section covers the same period as the financial statements. It sits after the governance report under its own heading. It cross-refers to other reports instead of repeating them.

TFRS 1 already asked for some of this. Paragraph 16 covers environmental, social and community matters. Paragraph 18.2 mentions climate change and resource shortages. Paragraph 25.3 says emissions and waste may need discussion if material. The 2024 amendment to TFRS 1 brought the ISSB disclosures into that report.

Emissions arrive in phases. The IFRS Foundation jurisdictional profile for Tanzania records Scope 3 reporting from 2026, Category 15 from 2028 and all categories by 2029. The profile says this gives up to three years more than the IFRS S2 reliefs.

A company may only state that it complies with IFRS S1 and S2 if it meets every requirement. IFRS S1 paragraph 72 calls this an "explicit and unreserved statement of compliance". The auditor will read that statement.

Can a company publish a stand-alone IFRS S1 and S2 report instead?

Not instead. Only in addition. Section 2.2 of the 2026 pronouncement allows a separate sustainability report on four conditions:

1. It follows IFRS S1, IFRS S2 and any other standard NBAA later adopts.
2. It cross-refers to and from the governance report.
3. Its period and publication timing match the financial statements.
4. The governance report disclosures stay complete.

The practical effect is that the stand-alone report becomes the long version. The governance report carries the required disclosures, and the separate report can add case studies, site data and a fuller transition plan.

Listed companies may add other frameworks. The IFRS Foundation profile notes that the DSE rules let listed entities report ESG information using ISO 26000 and the GRI Standards. Extra material must not obscure the ISSB disclosures.

When does assurance under ISSA 5000 start in Tanzania?

NBAA has not set a date. The International Auditing and Assurance Standards Board published ISSA 5000 on 12 November 2024. NBAA's first-quarter 2025 technical update and the 2026 pronouncement both give the IAASB effective date as periods beginning on or after 15 December 2026.

That IAASB date does not bind Tanzania by itself. Section 5 of the pronouncement says assurance timing in Tanzania awaits NBAA's announcement. Until then:

• The external auditor reads the Sustainability Disclosures as "other information" under ISA 720.
• The auditor reports material inconsistencies with the financial statements or with knowledge gained in the audit.
• The auditor considers whether any statement of compliance is adequate.

An ACCA technical article explains the two levels. Limited assurance gives a negative conclusion that nothing came to the practitioner's attention. Reasonable assurance gives a positive opinion and needs more testing. Build data trails now as if limited assurance will apply to the 2027 or 2028 report.

What does the readiness assessment involve?

Section 5(ii) requires every reporting entity, public sector included, to complete a comprehensive assessment of gaps and then address them. The pronouncement lists the areas:

Section 5(iii) gives audit firms a parallel duty. They must assess technical competence, quality management, methodologies, tools and manpower for ISSA 5000 work. Ask your auditor for their timetable. A firm that is not ready may need a specialist partner.

The pronouncement sets no filing date for the assessment and does not say NBAA will collect it. Keep it on file, approved by the board, as evidence for the auditor and for any NBAA enquiry.

How do banks, listed companies and public bodies fit in?

Banks and financial institutions have a second regulator. The Bank of Tanzania issued the Guidelines on Climate-Related Financial Risks Management and Disclosures, 2025 under section 71 of the Banking and Financial Institutions Act, 2006. They apply to all banks and financial institutions. Clause 6(2) aligns the disclosures with IFRS S2. Clause 23 asks for financed emissions across Scopes 1, 2 and 3. Clause 24(1) ties the period to the audited financial statements. The Citizen reported on 13 January 2025 that BoT had issued two sets of guidelines. The IFRS Foundation profile names the second as covering sustainability-related risks and opportunities. A bank must satisfy both NBAA and BoT. Our note on the BoT draft banking regulations 2026 covers a separate set of proposed rules.

Listed companies are PIEs under test (a). The governance report, with its Sustainability Disclosures, goes out with the annual report investors receive. TFRS 1 paragraph 56 requires PIEs to publish the report on their website with the audited financial statements within 30 days of approval. Investors new to the market can read our guide to buying shares on the DSE.

Public sector entities follow section 3. They apply IFRS S1 and S2 until the International Public Sector Accounting Standards Board issues sustainability standards, then move to those. The 2024 text had left a mandatory public sector date to a later decision. The 2026 text now requires compliance with section 2.

Does the pronouncement reach Zanzibar companies?

The position is unclear. The answer depends on where the entity is registered and who regulates it.

We read the Banking and Financial Institutions Act, 2006 on TanzLII for the bank row. Neither the IFRS Foundation profile nor the IFAC country profile mentions Zanzibar. A Zanzibar-registered company should ask NBAA and the Business and Property Registration Agency (BPRA) in writing. Adopting the Sustainability Disclosures voluntarily is the lower-risk course.

Worked example: a Dar es Salaam manufacturer's first report

Mfano Foods Limited is a hypothetical edible oil and flour processor in Dar es Salaam. It has total gross capital of TZS 62 billion, 640 staff and two plants. Its year ends on 31 December. It meets PIE test (c), so it has been in scope since 2025.

The board decides to rebuild its process for the 2026 rule. It approves a readiness budget. The figures below are internal planning assumptions for illustration, not market rates or Zatra fees.

The total is about 0.27% of gross capital. Government charges are separate and small. Filing the annual return with BRELA costs TZS 22,000 (F0007). Any separate document delivered to the Registrar costs TZS 22,000 (F0005). Late delivery costs TZS 2,500 per month or part of a month (F0006). The fee register holds no NBAA line for sustainability disclosures, and the pronouncement sets no fee.

The timeline runs like this:

For example, if the board approves the FY2027 accounts on 31 March 2028, the website deadline under TFRS 1 paragraph 56 falls on 30 April 2028. The tax return follows section 117 of the Income Tax Act, Cap. 332 R.E. 2023, due by 30 June 2028.

What it costs: government fees and adviser fees

Keep two cost buckets apart. Government charges are paid to the authority against its control number at the official rate. Adviser, auditor and Zatra fees are agreed separately and invoiced separately. Our explainer on professional fees versus government fees sets out the rule.

The figures are from the Zatra fee register, stated at 26 September 2026. The amount on the control number governs on the day of payment.

What to do now

1. Confirm your status. Test the entity against the three PIE tests and record the board's conclusion, including the gross capital measure used.
2. Name an owner. Give one board committee responsibility for sustainability reporting and write it into its terms of reference.
3. Run the readiness assessment. Cover the seven areas in section 5(ii), rate each gap and approve a closure plan with dates.
4. Start the data year on time. Capture fuel, power, water, waste and travel data from 1 January 2027 with source documents kept.
5. Talk to the auditor early. Agree the disclosure template, the ISA 720 reading and the firm's own ISSA 5000 readiness plan.
6. Restructure the governance report. Add the "Sustainability Disclosures" heading after the TCWG report and plan cross-references.
7. Decide on a stand-alone report. If you publish one, align its period and timing with the accounts and cross-refer both ways.
8. Watch for NBAA's assurance notice. Diarise a quarterly check of NBAA announcements for the ISSA 5000 date.

Key dates

Common mistakes to avoid

• Moving the disclosures out. Publishing a glossy sustainability report and leaving the governance report thin breaches section 2.2.
• Waiting for assurance. The reporting duty applies now. Only the assurance date is open.
• Claiming compliance too early. A partial set of disclosures cannot carry an unreserved statement of compliance.
• Mismatched periods. A June-year disclosure attached to December-year accounts fails the timing rule.
• Treating it as a tax matter. TRA does not receive the disclosures as a filing. The numbers should still reconcile with the fuel and energy costs claimed in the accounts.
• Confusing it with environmental audits. An environmental audit under the environment law is a separate duty. Our note on environmental audits after the EIA certificate explains it.

How Zatra helps

Zatra's finance desk helps boards prepare for the 2027 report. We run the PIE status test, design the governance and control structure through corporate governance advisory, and map the data controls through internal controls and risk advisory. We build the monthly data rhythm into management accounts and financial reporting, and coordinate the accounts, AGM and filings set out in our guides to audited financial statements, the AGM and the annual return. Ongoing support sits in the Business Continuity Desk.

Zatra is not an audit firm and does not give assurance. The external auditor reports on the accounts, and NBAA decides how the pronouncement is applied. Zatra prepares and coordinates the file; it does not decide or guarantee any authority's outcome. Our professional fee is scoped in writing and invoiced separately from government charges. A dispute with a regulator, a prosecution, a seizure, or a legal opinion a bank or investor will rely on goes to an advocate on our team.

Sources and status

Accurate as at 26 October 2026. We read the NBAA, BoT, IFRS Foundation and IAASB documents on 26 October 2026. Government fees are from the Zatra fee register at 26 September 2026.

• Revised Technical Pronouncement No. 1 of 2026: NBAA, approved 30 Jul 2026, issued Aug 2026. Accessed 26 Oct 2026.
• Technical Pronouncement No. 1 of 2026 (copy linked from the announcement): NBAA, Aug 2026. Accessed 26 Oct 2026.
• Taarifa ya Kiufundi Na. 1 ya 2026: NBAA announcement, 21 Aug 2026. Accessed 26 Oct 2026.
• Technical Pronouncement No. 1 of 2024: NBAA, issued 1 Jul 2024. Accessed 26 Oct 2026.
• Technical Pronouncement No. 1 of 2018: NBAA, approved 26 Sep 2018. Accessed 26 Oct 2026.
• TFRS 1, The Report by Those Charged with Governance: NBAA, approved 22 Jun 2020. Accessed 26 Oct 2026.
• Updates on Technical Issues, First Quarter 2025: NBAA, 2025. Accessed 26 Oct 2026.
• Accountants and Auditors (Registration) Act, Cap. 286: TanzLII, consolidation of 31 Jul 2002. Accessed 26 Oct 2026.
• NBAA mandatory functions: NBAA website, 2026. Accessed 26 Oct 2026.
• Companies Act, Cap. 212 R.E. 2023: BRELA, 2023. Accessed 26 Oct 2026.
• Income Tax Act, Cap. 332 R.E. 2023: TRA, 2023. Accessed 26 Oct 2026.
• Guidelines on Climate-Related Financial Risks Management and Disclosures, 2025: Bank of Tanzania, 2025. Accessed 26 Oct 2026.
• Banking and Financial Institutions Act, 2006: TanzLII, 8 Jun 2006. Accessed 26 Oct 2026.
• IFRS Sustainability Disclosure Standards: jurisdictional profile, Tanzania: IFRS Foundation, updated 12 Jun 2025. Accessed 26 Oct 2026.
• IFRS S1 General Requirements and IFRS S2 Climate-related Disclosures: IFRS Foundation, issued Jun 2023. Accessed 26 Oct 2026.
• ISSA 5000: IAASB, 12 Nov 2024. Accessed 26 Oct 2026.
• An introduction to ISSA 5000: ACCA, page updated 24 Jul 2026. Accessed 26 Oct 2026.
• Sustainability, climate risk reporting now mandatory for banks in Tanzania: The Citizen, 13 Jan 2025. Accessed 26 Oct 2026.
• Tanzania country profile: IFAC, updated Apr 2026. Accessed 26 Oct 2026.
• Tanzania Government Fees 2026 register: Zatra Handbook 06, fees at 26 Sep 2026; F0005, F0006, F0007. Accessed 26 Oct 2026.

Figures to confirm before you act

• The date NBAA sets for ISSA 5000 assurance in Tanzania, and whether limited or reasonable assurance applies first.
• The Scope 3 phasing, which we took from the IFRS Foundation profile because the 2024 roadmap appendix was not in the copy we read.
• Whether public sector entities face a fixed mandatory date, given the different wording of the 2024 and 2026 texts.
• How "total gross capital" is measured for PIE test (c).
• Whether the pronouncement binds companies registered with BPRA in Zanzibar.
• The implementation timetable in Annex 1 of the BoT guidelines, which was not in the copy we read.
• The amount on the authority's control number on the day of payment.

This article is general information based on official sources available at the date of publication. It is not legal, tax or financial advice. Laws and notices change. Verify with the issuing authority or consult Zatra before acting.