NG

Nigeria

West Africa

16Instruments
6Cases
3Regulators
85%Coverage
Overview

Nigeria operates one of Africa's most developed and closely watched data protection regimes, and its trajectory is the clearest example of legislative evolution on the continent. The current primary instrument is the Nigeria Data Protection Act, 2023 (NDPA), signed into law on 12 June 2023 and in force from that date, which placed data protection on a primary-legislation footing for the first time. The NDPA applies to controllers and processors domiciled, resident, or operating in Nigeria, and extends extraterritorially to anyone processing the personal data of individuals in Nigeria, so foreign companies with Nigerian users must comply. It recognises six lawful bases, imposes heightened conditions on sensitive data, requires registration and annual audits (through licensed Data Protection Compliance Organisations) for controllers "of major importance," mandates DPIAs for high-risk processing, grants the full suite of data-subject rights, requires breach notification to the regulator within 72 hours, and provides administrative fines of up to 2% of annual global gross revenue. The NDPA superseded the Nigeria Data Protection Regulation, 2019 (NDPR), a subsidiary regulation issued by NITDA under the NITDA Act that had been Nigeria's first substantive data protection instrument, notable for its DPCO-led annual-audit mechanism. The NDPA absorbed and elevated that model into statute, and ATLPF holds both instruments, giving a clear before-and-after legislative history that few jurisdictions on the continent can match. Enforcement rests with the Nigeria Data Protection Commission (NDPC), an independent statutory authority that replaced the former Nigeria Data Protection Bureau and is empowered to register controllers and processors, issue regulations, investigate complaints, conduct audits, and impose sanctions. With two documented instruments (a superseded predecessor and an in-force Act) and an active named regulator, Nigeria is among the best-documented and most mature regimes in West Africa and on the continent.

Topic coverage
TopicInstrumentsCasesCoverage
Data Protection63
AI Governance10
Fintech102
Cybercrime11
Digital Rights43
Platform Liability02
Telecoms10

● Covered  ◐ Partially covered  ○ Not yet covered

Instruments
ng-const-privacy·Act

Constitution of the Federal Republic of Nigeria, 1999, Section 37 (Right to Privacy, including correspondence and communications)

NigeriaDigital RightsData ProtectionIn Force
Verified

Enacted 5 May 1999

ng-foia-2011·Act

Freedom of Information Act, 2011

NigeriaDigital RightsIn Force
Verified

Enacted 28 May 2011

ng-lic-2019·Regulation

Lawful Interception of Communications Regulations, 2019

NigeriaDigital RightsTelecomsIn Force
Verified

Enacted 23 Jan 2019

ng-cyber-2015·Act

Cybercrimes (Prohibition, Prevention, Etc.) Act, 2015

NigeriaCybercrimeData ProtectionFintechDigital RightsIn Force
Verified

Enacted 15 May 2015

ng-openbanking-2023·Guidance

Operational Guidelines for Open Banking in Nigeria

NigeriaFintechData ProtectionIn Force
Verified

Enacted 7 Mar 2023

ng-sandbox-2021·Guidance

Framework for Regulatory Sandbox Operations

NigeriaFintechIn Force
Verified

Enacted 12 Jan 2021

ng-mobilemoney-2021·Guidance

Framework and Guidelines on Mobile Money Services in Nigeria

NigeriaFintechIn Force
Verified

Enacted 9 Jul 2021

ng-pspcategorisation-2020·Guidance

Guidelines on New License Categorization for the Nigerian Payment System

NigeriaFintechIn Force
Verified

Enacted 9 Dec 2020

ng-openbankingframework-2021·Guidance

Regulatory Framework for Open Banking in Nigeria

NigeriaFintechData ProtectionIn Force
Verified

Enacted 17 Feb 2021

ng-enaira-2021·Guidance

Regulatory Guidelines on the eNaira

NigeriaFintechIn Force
Verified

Enacted 25 Oct 2021

ng-psb-2020·Guidance

Guidelines for Licensing and Regulation of Payment Service Banks in Nigeria

NigeriaFintechIn Force
Verified

Enacted 27 Aug 2020

ng-vasp-2023·Guidance

Guidelines on the Operations of Bank Accounts for Virtual Assets Service Providers

NigeriaFintechIn Force
Verified

Enacted 22 Dec 2023

ng-agentbanking-2025·Guidance

Guidelines for the Operations of Agent Banking in Nigeria

NigeriaFintechIn Force
Verified

Enacted 6 Oct 2025

ng-ai-2024·Guidance

National Artificial Intelligence Strategy (NAIS)

NigeriaAI GovernanceProposed
Verified

Enacted 2 Aug 2024

ng-ndpr-2019·Regulation

Nigeria Data Protection Regulation, 2019

NigeriaData ProtectionSuperseded
Verified

Enacted 25 Jan 2019

ng-ndpa-2023·Act

Nigeria Data Protection Act, 2023

NigeriaData ProtectionIn Force
Verified

Enacted 12 Jun 2023

Cases
ng-cbn-2024-fintech-kyc-fines

Central Bank of Nigeria

NigeriaFintechTribunal / Regulatory Body
Verified

"Following routine audits of the fintech sector, the Central Bank of Nigeria imposed administrative penalties reported at ₦1 billion each on OPay and Moniepoint (with further unnamed operators also penalised) for deficiencies in know-your-customer and anti-money-laundering controls, in a wider 2024 tightening that included a temporary suspension of new-customer onboarding across several fintech operators."

ng-ecowas-2022-serap-cybercrimes-s24

ECOWAS Community Court of Justice

NigeriaCybercrimeDigital RightsOther
Verified

Decided 25 Mar 2022

"The Court held that section 24 of the Cybercrimes (Prohibition, Prevention, Etc.) Act 2015, which criminalises the sending of messages deemed grossly offensive, indecent, obscene or annoying via a computer network, is vague, arbitrary and incompatible with the right to freedom of expression under Article 9 of the African Charter on Human and Peoples' Rights and Article 19 of the ICCPR, and ordered Nigeria to amend the provision."

ng-ecowas-2022-serap-twitter-ban

ECOWAS Community Court of Justice

NigeriaDigital RightsPlatform LiabilityOther
Verified

Decided 14 Jul 2022

"The Court held that the Federal Government's June 2021 suspension of access to Twitter was unlawful and inconsistent with the rights to freedom of expression, access to information and the media under Article 9 of the African Charter and Article 19 of the ICCPR; it ordered the suspension lifted and directed the government to guarantee non-repetition and to align its measures with those guarantees."

ng-ndpc-2024-fidelity-bank

Nigeria Data Protection Commission

NigeriaData ProtectionFintechTribunal / Regulatory Body
Verified

Decided 21 Aug 2024

"The NDPC imposed a penalty of approximately ₦555.8 million on Fidelity Bank Plc after finding that the bank processed the personal data of over one million users of its banking application without valid consent and engaged non-compliant third-party data processors, in breach of the Nigeria Data Protection Act 2023."

ng-ca-2021-drli-v-nimc

Court of Appeal of Nigeria

NigeriaData ProtectionDigital RightsSupreme Court / Court of Appeal
Verified

Decided 24 Sept 2021

"The Court of Appeal held that the fundamental right to privacy guaranteed by section 37 of the 1999 Constitution encompasses data protection rights, so that breaches of the Nigeria Data Protection Regulation 2019 are enforceable as fundamental-rights violations, and found NIMC's imposition of a fee for the rectification of personal data incompatible with the data subject's rights."

ng-ccpt-2025-meta-v-fccpc

Competition and Consumer Protection Tribunal

NigeriaData ProtectionPlatform LiabilityTribunal / Regulatory Body
Verified

Decided 25 Apr 2025

"The Competition and Consumer Protection Tribunal dismissed Meta and WhatsApp's appeal and upheld the FCCPC's USD 220 million administrative penalty (plus USD 35,000 in investigation costs), affirming the Commission's finding that the companies engaged in discriminatory and exploitative data-privacy practices against Nigerian consumers, including denying Nigerian users control over their personal data and sharing data without consent, contrary to the Federal Competition and Consumer Protection Act and applicable data-protection standards."

Notable gaps

Subsidiary regulations and guidance issued under the NDPA continue to develop; ATLPF holds the Act and its NDPR predecessor but not the full body of NDPC subsidiary instruments. The DPCO-led audit model also concentrates compliance infrastructure in licensed intermediaries.