Beneath the iceberg: Why sustainability data will make or break 2027 sustainability reporting

Public interest entities in Kenya are required to publish sustainability disclosures under IFRS S1 and S2 from 1 January 2027, with independent limited assurance mandated from 1 January 2028.

As the sustainability landscape shifts from voluntary to mandatory disclosures, most organizations are preparing for the visible part of the iceberg, the assurance process, but are they missing the foundation? While assurance is what many see at the tip of the iceberg, what really sustains sustainability reporting is the quality, structure, and reliability of the underlying data. And despite its importance, data remains one of the most underdeveloped areas in corporate sustainability strategies.

• Fragmented or unstructured data scattered across departments. 
• Uncertainty on what to measure and how it links to material risks and opportunities. 
• Inconsistent definitions and methodologies, limiting comparability. 
• Limited internal capacity for sustainability data governance. 
• Sustainability reporting remains disconnected from core financial reporting systems.

High-quality sustainability reporting is not possible without a structured, auditable, and well-governed data ecosystem. Investing in data governance, clear data ownership, structured collection methods, audit trails, and centralized systems, ensures that sustainability information is:

• Reliable for assurance. 
• Comparable across periods or peers. 
• Useful for decision-making and stakeholder trust. 
• Resilient under regulatory and investor scrutiny.

To prepare for 2027/2028, forward-thinking organizations are:

• Conducting sustainability gap assessments, identifying where data sits, who owns it, and how it is reported. 
• Building governance over sustainability data, with internal controls like financial data. 
• Investing in sustainability reporting systems and training, enabling cross-functional collaboration. 
• Aligning with global standards, such as IFRS S1 and S2, GRI, SASB, CSRD.

So, if assurance is the iceberg tip, is your data iceberg strong enough to keep your sustainability report afloat? Because in sustainability, you can’t assure what you can’t measure.