Climate-Related Financial Disclosure and Greenwashing Control in African Capital Markets: A Comparative Analysis of Regulatory Readiness

Abstract

This study examined regulatory readiness for climate-related financial disclosure and greenwashing control in Nigeria, South Africa, Kenya, Morocco and Ghana. It adopted comparative doctrinal and institutional research designs and reviewed securities legislation, listing requirements, sustainability guidelines, green-bond rules, corporate-governance codes, IFRS S1 and IFRS S2 adoption roadmaps, enforcement arrangements and investor-redress mechanisms available up to 31 July 2026. Regulatory readiness was assessed through a 12-criterion index covering disclosure status, entity coverage, greenhouse-gas reporting, materiality, transition plans, scenario analysis, value-chain emissions, assurance, green-product labelling, supervision, penalties and investor redress. The findings showed considerable regulatory development but uneven legal force, coverage and implementation. Nigeria, Kenya and Ghana had adopted pathways towards full ISSB alignment, although mandatory application largely fell beyond the study period. South Africa combined voluntary corporate climate guidance with stronger requirements for labelled debt securities, while Morocco required ESG reporting but had not achieved full IFRS S2-equivalent climate coverage. Green-bond regulation was generally more developed than controls over corporate sustainability claims, ESG fund names and net-zero commitments. All five jurisdictions were classified as developing, with readiness scores ranging from 50.0% to 62.5%. The study concluded that formal standard adoption alone was insufficient to control greenwashing. Effective regulation required mandatory proportionate disclosure, credible taxonomies, substantiated environmental claims, independent assurance, active supervision, enforceable sanctions and accessible investor remedies.