Regulatory Pulse - June 2026

1.  FEDERAL GOVERNMENT ISSUES GENERAL TAX TRANSITION GUIDELINES

On 18 June 2026, the Federal Government recently issued the General Guidelines for the implementation of the 2025 Tax Acts, providing a transitional framework for the application of the new tax legislation and expressly precluding the retroactive application of the Acts. The Guidelines are intended to provide the much-needed clarity on compliance obligations as the new tax regime takes effect.

Health facilities, health startups, and employers of labour in the health sector are directly affected by the new tax framework, and should note that the Guidelines provide the applicable compliance roadmap for the transition period. Entities operating in the health space are advised to conduct a review of their tax positions under the 2025 Tax Acts in light of the Guidelines, identify exposures arising from the transition and seek legal and regulatory counsel to ensure a seamless transition and full compliance.

2.  NCDC ISSUES PUBLIC HEALTH DIRECTIVE ON EBOLA OUTBREAK 

The Nigeria Centre for Disease Control and Prevention (NCDC) has issued a public health directive following the ongoing Ebola outbreak in the DRC and Uganda. Effective 9 June 2026, all passengers arriving in Nigeria on international flights must complete the NCDC Health Declaration Form before arrival. Enhanced screening measures are now in force, including thermal screening and 21-day travel history assessment.

This directive carries direct compliance obligations for airports, airlines, port health authorities, and healthcare facilities handling incoming international patients. It also marks a significant development in Nigeria’s digital public health surveillance infrastructure through the mandatory pre-arrival digital declaration platform at healthapp.ncdc.gov.ng. Stakeholders are encouraged to seek regulatory advice to ensure institutional compliance.

3.   NATIONAL HIV PREVENTION PLAN 2026-2030

The National Agency for the Control of AIDS (NACA) launched the National HIV Prevention Plan 2026–2030 in a bid to make a deliberate shift from a reactive, risk-based HIV response to a proactive, development-based one. The Plan targets a 90% reduction in new HIV infections by 2030 through a dual-track approach: a school-based values curriculum led by the Federal Ministry of Education, and continued clinical prevention services led by the Federal Ministry of Health and Social Welfare, delivered through a wide multi-sectoral and private sector partnership structure.

This Plan carries direct implications for HMOs, insurers, employers, digital health platforms, and civil society organisations operating in the HIV prevention space, particularly around anticipated shifts in alignment expectations. Stakeholders are encouraged to seek regulatory advice ahead of implementation.

4.  NATIONAL HEALTH TECHNOLOGY AND DATA ANALYTICS OFFICE (NHTDAO)

 In June 2026, President Tinubu approved the establishment of the NHTDAO, an office domiciled in the Office of the Coordinating Minister of Health and Social Welfare. Its mandate is to serve as a coordinating platform for Nigeria’s digital health agenda, operationalising the National Digital Health Architecture approved by the National Council on Health in November 2025. The NHTDAO will be the country’s central platform to coordinate data standards across the health system.

Public and private digital health operators, electronic health records platforms, telemedicine providers, and digital health companies should note that this office creates new expectations around alignment with health data standards and should monitor NHTDAO guidance closely as implementation standards are developed.

5.  NATIONAL IDENTITY MANAGEMENT COMMISSION (NIMC) ACT 2026

 The NIMC Act was signed into law, repealing and replacing the 2007 Act and expanding the NIMC’s powers across digital identity, cybersecurity and data protection. The NIMC is now designated as the Root Certification Authority for Nigeria’s National Public Key Infrastructure and Digital Public Infrastructure.

Health facilities, HMOs, and digital health platforms that use National Identification Number (NIN) for patient verification are now operating within this new legal framework. Stakeholders are encouraged to seek legal and regulatory advice to ensure institutional compliance with the new NIN-based data flows.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.