ARTICLE
7 May 2026

March Policy Trend Trail

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Tunde & Adisa

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Established in 2010, Tunde & Adisa Legal Practitioners (T & A Legal) has evolved into a dynamic and forward-thinking corporate and commercial law firm, recognised for its comprehensive legal expertise. We are committed to delivering innovative solutions and providing strategic counsel to clients navigating Nigeria's complex and evolving business landscape from our offices in Lagos, Abuja, and Ibadan.
This comprehensive review examines Nigeria's major policy developments introduced in March 2026, spanning tax reform, education verification, humanitarian protection, health regulation, climate risk management, security...
Nigeria Government, Public Sector
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INTRODUCTION

This Policy Trend Trail reviews key government policies introduced in March 2026, highlighting major developments across taxation, education, health, climate risk, humanitarian protection and financial regulation. Public policy remains a central tool through which government priorities are translated into enforceable actions that shape economic activity, institutional behaviour and citizen welfare. Collectively, the policies reflect a clear shift toward stronger standards regulation, digitised systems and enhanced accountability in major sectors.

POLICIES

NEW TAX ADMINISTRATION POLICY: BAN ON CASH TAX COLLECTION AND ROADBLOCK ENFORCEMENT AND THE INTRODUCTION OF THE PRESUMPTIVE TAX REGULATION

The Federal Government, through the Ministry of Finance and the Joint Revenue Board, enacted the Presumptive Tax Regulations and Guidelines, as part of the broader tax reform agenda currently being implemented across Nigeria.

The presumptive tax framework is aimed primarily at the informal sector, which accounts for a large share of Nigeria’s workforce but historically contributes little to structured tax revenue. Under the framework, nano and micro businesses with an annual turnover of N12,000,000.00 (Twelve Million Naira only) or below are exempt from tax payment, while other qualifying informal businesses are subject to a flat 1% tax on turnover, designed to simplify compliance and reduce the burden of complex accounting requirements.

The Federal Government also introduced an enforcement regime for tax collection that prohibits cash collection of taxes and the use of roadblocks for tax enforcement nationwide. The policy is in furtherance of the move toward a more transparent and technology-driven tax system, and it directly bans the long-criticised practices where tax officials mounted roadside checkpoints or demanded cash payments from traders, transport operators and small businesses. The old system of tax collection created an environment of informal, coercive and fragmented tax enforcement, particularly across sub-national jurisdictions. The new rules therefore require that all tax payments be made through traceable, technology-enabled platforms rather than cash transactions.

Ultimately, the reforms seek to balance two objectives: expanding Nigeria’s tax base without increasing tax rates and protecting small businesses from arbitrary or disruptive tax practices. By eliminating cash-based collections and roadside enforcement, the government aims to promote transparency, reduce leakages and create a more predictable tax environment for traders and transport operators who have historically faced inconsistent revenue demands.

ACADEMIC VERIFICATION POLICY FOR NATIONAL YOUTH SERVICE CORPS MOBILISATION

In March 2026, the Federal Government commenced the full enforcement of the “No NERD, No NYSC” policy. Originally introduced last year through the office of the Secretary to the Government of the Federation, this regulation makes compliance with the Nigeria Education Repository and Databank (NERD) a mandatory prerequisite for mobilisation into the National Youth Service Corps (NYSC). By this directive, every graduate whether trained in Nigeria or abroad, are required to obtain proof of NERD compliance before they can be mobilised for NYSC or granted exemption from the scheme.

NERD is a national digital repository created by the Federal Government to store and verify academic records, including final-year projects, thesis and research outputs produced by Nigerian graduates. The system is designed to strengthen education data management, curb certificate fraud and ensure that academic qualifications presented for public service or employment purposes can be verified.

Under the new framework, graduates seeking NYSC mobilisation must upload their academic project or thesis and supporting documents to the NERD platform, after which their institution verifies the submission before a NERD clearance slip is issued. The required documents include academic certificates or statements of results, project reports, identification details such as the National Identification Number (NIN).

The policy has multifaceted impacts for graduates as it promises a more credible verification system that protects the value of legitimate academic qualifications. It also establishes a reliable mechanism for validating educational records, thereby improving transparency in both public and private service recruitment and national youth mobilisation processes.

THE DOMESTICATION OF THE KAMPALA CONVENTION TO STRENGTHEN PROTECTION FOR INTERNALLY DISPLACED PERSONS

President Bola Tinubu signed into law the Kampala Convention (Domestication and Enforcement) Bill 2024, creating Nigeria’s first comprehensive legal framework for the protection and assistance of internally displaced persons (IDPs). The legislation formally incorporates the African Union’s Kampala Convention, adopted in 2009 into Nigeria’s legal system, making its provisions enforceable within the country.

Nigeria hosts millions of IDPs displaced from insurgency, communal conflict, banditry and natural disasters, many of whom live in overcrowded camps with limited access to healthcare, education and basic services. By domesticating the convention, the new law establishes clearer government obligations to protect displaced citizens, improve humanitarian coordination and provide structured support systems for their welfare and reintegration.

The law places the primary responsibility on the Nigerian state to prevent arbitrary displacement, provide humanitarian assistance and pursue durable solutions such as resettlement, local integration or voluntary return of displaced persons. It also strengthens institutional coordination among relevant agencies responsible for disaster management, humanitarian relief and social protection.

From a policy perspective, the legislation represents an important shift from ad-hoc humanitarian responses toward a rights-based legal framework for managing internal displacement. It shows Nigeria’s commitment to aligning domestic governance with regional and international standards on humanitarian protection while acknowledging the scale of displacement challenges across the country.

THE NATIONAL POLICY ON COSMETICS SAFETY AND HEALTH

In March 2026, the Federal Ministry of Health and Social Welfare began the state-level implementation of the National Policy on Cosmetics Safety and Health with a stakeholder engagement in Lagos state. This reflects a growing regulatory response to the rising health risks within Nigeria’s beauty and cosmetic industry. It serves both as a preventive and corrective framework aimed at strengthening oversight across cosmetic products and procedures.

At its core, the policy seeks to address a largely under-regulated space marked by the proliferation of adulterated, substandard and improperly formulated cosmetic products, as well as unsafe clinical practices. Over the years, there has been so many reports of the adverse health reactions and the discovery of large volumes of banned and fake cosmetics, all of which show a systemic gap in the quality control, professional standards and supply chain monitoring of the cosmetic industry in Nigeria.

The policy introduces a more structured value-chain approach to regulation, extending responsibility beyond regulators to manufacturers, suppliers, training institutions and healthcare facilities. It also provides a coordinated framework for states to develop tailored action plans to be implemented over a 5 (five) year period supported by federal oversight tools such as a national implementation dashboard, signalling a move toward data-driven regulation and accountability.

The implications of this policy are significant as it is designed to improve consumer safety by ensuring that cosmetic products meet minimum health standards and that cosmetic procedures are conducted within regulated environments. Furthermore, it elevates patient rights and safety in a sector that has increasingly blurred the line between healthcare, aesthetics and the safety of lives. By this policy, companies and individuals that violate cosmetics safety guidelines should expect tougher sanctioning regimes.

This policy signals a strategic shift from reactive enforcement to proactive governance in Nigeria’s cosmetics industry. Its long-term effectiveness will however depend on enforcement capacity, inter-agency coordination and sustained compliance by industry players operating in this fast-growing but high-risk sector.

PARAMETRIC FLOOD INSURANCE POLICY AIMED AT STRENGTHENING CLIMATE RISK

In March 2026, the Lagos State Government launched the parametric flood insurance policy, curated to protect Lagos State residents that are vulnerable to flooding and its associated casualties. The policy was developed in partnership with international development and insurance stakeholders reflecting the concerted effort to move from disaster response to a more proactive and risk-transfer approach that ensures rapid financial support when flood events occur.

Unlike conventional insurance models that require loss assessments before payouts, parametric insurance is triggered automatically once predefined conditions such as rainfall levels or flood intensity are met. This addresses one of the long-standing challenges in disaster management – delayed relief and recovery support.

Through this policy, the state aims to cushion the aftermath of flood particularly for those in high-risk areas. The policy offers financial protection that can help stabilise incomes and support quicker recovery after flood/climate incidents. It also shows the commitment to recognise climate risk as an economic issue requiring structured financial solutions rather than emergency interventions.

This initiative positions Lagos as a leader in sub-national climate innovation in Nigeria, aligning with global trends in disaster risk financing. Like every other policy, its long-term success will depend on sustained funding, accurate risk modelling and effective coordination to ensure that payouts reach the intended beneficiaries, thereby reducing vulnerability associated with the causalities of flood.

STATE POLICING – CONSTITUTIONAL AMENDMENT PROCESS

In March 2026, Nigeria’s long-standing debate on state policing moved from mere policy discussion to a more structured legislative and operational phase; a potential shift in the country’s security architecture. This followed the submission of a comprehensive framework by the Inspector-General of Police, Olatunji Disu, to the National Assembly as part of ongoing constitutional reform efforts.

The 75-page document, titled “A Comprehensive Framework for the Establishment, Governance and Coordination of Federal and State Police,” was presented to the Senate Committee on Constitutional Review chaired by Sen. Barau Jibrin. The report detailed the operational modalities for the proposed state police system and provided a roadmap for its seamless integration into Nigeria’s existing security architecture.

Specifically, it outlined the proposed structure, governance model and coordination mechanisms for a dual policing system, comprising both the federal and state police services and also outlined a two-tier policing structure comprising a proposed Federal Police Service (FPS) and 37 State Police Services (SPS) across the federation and the Federal Capital Territory. The FPS, which would replace the Nigeria Police Force subject to constitutional amendment, is designed to focus on national security, terrorism, cybercrime, interstate offences and other federal law enforcement responsibilities while the SPS would be responsible for local criminal offences, domestic violence, homicide, armed robbery and broader community policing functions as its primary mandate.

The framework proposes a managed redistribution of personnel, under which the FPS will retain approximately 40 per cent of officers for national duties, while the remaining 60 per cent will be redeployed to state police services. To facilitate this transition, the framework proposed the introduction of a Voluntary Transfer Programme (VTP), allowing officers to transfer to their home state or preferred State Police Service, supported by a three-month salary Transfer Facilitation Grant, structured transition training and guaranteed pension continuity to preserve retirement benefits.

A key innovation under the proposal is the establishment of a National Police Standards Board (NPSB), an independent federal body mandated to set minimum national standards for recruitment, training, conduct, accountability and funding across all police services. The Board will also monitor compliance, enforce standards and publish annual performance and compliance ratings for each State Police Service.

The framework further embeds community policing as the philosophical and operational core of the state policing model. It mandates every State Police Service to establish a dedicated Department of Community Policing, alongside Community Policing Forums in every Local Government Area comprising police officers, traditional rulers, women’s groups, youth organisations and religious leaders. Community Liaison Officers will be assigned to specific communities, required to speak local languages, and assessed partly based on community feedback and forum ratings.

The policy direction also incorporates institutional safeguards to address longstanding concerns about potential abuse of state-controlled police forces. It proposes a layered oversight and accountability framework. This includes independent State Police Service Commissions responsible for recruitment and discipline, State Police Ombudsmen for complaints handling, oversight inspections by the NPSB, legislative scrutiny by State Houses of Assembly, mandatory body-worn cameras with secure cloud storage, and public dashboards displaying use-of-force and community satisfaction metrics. It also recommends criminal sanctions for unlawful deployment of police forces and expedited Federal High Court review mechanisms for politically motivated actions.

The framework also prescribes a dedicated funding structure through a constitutionally backed State Police Fund (SPF). The fund is to be financed through a 3% statutory federal allocation from the Federation Account, distributed based on population, land mass, security needs and fiscal capacity, supplemented by a minimum 15% contribution from each state’s security budget. Additional proposals include conditional funding tied to human rights compliance and professional standards.

The reform is being advanced through proposed constitutional amendments; the “Sixth Alteration” Bill, particularly to Section 214 of the 1999 Constitution and the Second Schedule to remove policing from the Exclusive Legislative List and place it on the Concurrent List.

The reform introduces a 60-month phased implementation plan. The first 12 months are dedicated to constitutional and legal amendments. Months 13–24 will focus on establishing state police institutions and launching the Voluntary Transfer Programme. Months 25–42 will involve initial operations of State Police Services and gradual withdrawal of the FPS from local policing functions. Full consolidation, independent evaluation and legislative review are scheduled for Months 43–60.

In addition, the reform pathway recognises existing informal and regional security structures, with proposals to integrate vigilante groups and similar outfits into the formal policing architecture, subject to vetting, standardised training and regulatory oversight.

Although the Senate is considering the framework alongside other memoranda submitted during the constitutional review process, the establishment of state police remains subject to the approval of the National Assembly and ratification by at least two-thirds of State Houses of Assembly.

This marks a significant milestone in transitioning the debate into a structured legislative and operational roadmap, with indications that the Presidency and National Assembly are aligning efforts to conclude the amendment process ahead of the 2027 general elections.

Ultimately, the success of state policing will depend on sustained political consensus and robust institutional design. If implemented effectively, it has the potential to improve responsiveness, strengthen community trust and enhance overall security outcomes. However, careful attention must be paid to safeguards, funding architecture and institutional integrity to prevent political capture and ensure long-term sustainability.

CENTRAL BANK OF NIGERIA POLICIES

The Central Bank of Nigeria (CBN) issued a couple of circulars aimed at operationalising the financial ecosystem better. The details of these circulars are discussed below.

REVISION OF THE FRAMEWORK ON BANK VERIFICATION NUMBER (BVN) OPERATIONS

CBN issued an addendum to the Revised Regulatory Framework for Bank Verification Number (BVN) Operations and Watchlist for the Nigerian Banking Industry, other financial institutions and payment services providers, introducing new controls aimed at strengthening fraud monitoring and identity management in the banking system.

Under the revised framework, financial institutions are required to create and maintain a watchlist for BVNs linked to suspected fraudulent transactions reported by any financial institution. It provides that a BVN can remain on the temporary watch-list for up to 24 (twenty-four) hours, during which the BVN holder must be contacted to provide clarification on the flagged transaction.

It also introduced additional operational rules such as the restriction of BVN enrolment to persons who are aged 18 (eighteen) years and above and on changes to phone numbers linked to a BVN which will only be permitted once. In addition, access to BVN database records is now limited to CBN-licensed financial institutions, although the CBN retains discretion to grant access in exceptional circumstances.

The new provisions are scheduled to take effect from 1st May, 2026. All persons covered and governed by this regulation are required to comply. It also signals a better structure to the existing BVN verification system in compliance with best practices.

CENTRAL BANK OF NIGERIA’S GUIDELINES ON MANAGEMENT OF DORMANT ACCOUNTS AND UNCLAIMED BALANCES

The CBN updated its guidelines on the management of dormant accounts, unclaimed balances and other financial assets held by banks and other financial institutions, thereby introducing clarifications on account reactivation, disclosure obligations and regulatory compliance.

Banks and other financial institutions are required to adopt alternative channels to receive requests to reactivate dormant accounts, in addition to in-person submissions, provided that adequate identification, verification and risk management measures are established.

Also, the mandatory requirement for affidavits when reactivating dormant accounts that have not been transferred to the Unclaimed Balances Trust Fund (UBTF) Pool Account have been removed. However, affidavits will still be required where funds have already been transferred to the UBTF Pool Account.

In addition, financial institutions are mandated to publish information relating to dormant accounts and unclaimed balances on their websites or on their industry association’s websites. The information to be disclosed is limited to the name of the authorised account holder, account type, name of the financial institution and the branch where the account is domiciled.

Banks must also publish the mandated information annually in at least two national daily newspapers, while state and unit microfinance banks are compelled to display the information within their business locations.

The CBN further clarified that these disclosure requirements are consistent with the provisions of the Nigeria Data Protection Act 2023 and the Banks and Other Financial Institutions Act 2020, which permit the processing of personal data where necessary to comply with legal obligations.

Banks, fintechs and other financial institutions are advised to review their dormant account management processes, disclosure practices and customer verification procedures to ensure alignment with the updated requirements to avoid any penalties that are associated with non-compliance. The issuance of these guidelines shows the CBN’s commitment to foster confidence in the banking sector by entrenching transparency.

THE INTRODUCTION OF ADDITIONAL SECURITY AND OPERATIONAL REQUIREMENTS FOR INSTANT PAYMENTS

CBN issued new guidelines introducing additional functionalities and security requirements for Instant Payment (IP) services across Nigeria’s financial system.

Under the new framework, banks and other financial institutions offering instant payment services must introduce stronger customer controls and enhanced fraud monitoring mechanisms. Customers now have the option to opt in or opt out of instant payment services, with any changes subject to a Multi-Factor Authentication (MFA).

In the event that a customer opts out, instant online transfers will be disabled until the service is reactivated. The guidelines also allow customers to adjust their personal transaction limits within the existing regulatory ceilings of N25,000,000.00 (Twenty-Five Million Naira only) for individuals and N250,000,000.00 (Two Hundred and Fifty Million Naira only) for corporate entities. This is however subject to enhanced due diligence and additional authentication by the financial institution.

To strengthen fraud prevention, all financial institutions are required to implement enterprise-level fraud monitoring systems capable of detecting and restricting suspicious inflows and outflows in real time. Online account openings and reactivations must also undergo liveness checks and validation against BVN or NIN databases.

For mobile banking applications, the CBN has introduced additional safeguards through the restriction of mobile financial service apps to one device at a time and the requirement of a fresh authentication where there has been a switch or change to a new device. In addition, newly activated mobile apps for new accounts are made subject to temporary transaction limits of N 20,000.00 (Twenty Thousand Naira only) in their inflows and outflows within the first 24 (twenty-four) hours, while existing accounts with newly activated mobile apps have the same transaction limits specifically for outflows.

These provisions are set to take effect from 1st July, 2026, giving operators in the banking sector adequate time to regularise their existing operational frameworks.

THE CENTRAL BANK OF NIGERIA BASELINE STANDARDS FOR AUTOMATED AML MONITORING SYSTEMS FRAMEWORK

Following the exit of Nigeria from the FAFT grey list, it has become imperative to further tighten the regulatory landscape to maintain the status quo by staying off the grey list. Consequently, the CBN introduced new Baseline Standards for Automated Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT) and Counter-Proliferation Financing (CPF) solutions for financial institutions in Nigeria.

This framework mandates all banks, mobile money operators, international money transfer operators and other financial service providers to deploy and use automated systems capable of detecting and reporting suspicious financial transactions in real time. The goal is to strengthen the financial sector’s ability to prevent money laundering, terrorism financing and other financial crimes whilst improving the risk management system in the financial sector.

The implementation of the standards took effect from 10th March, 2026 and all financial institutions are required to submit implementation roadmaps to the CBN within 3 (three) months from the same date.

It is worthy of note that the full compliance timelines are within 18 (eighteen) months for Deposit Money Banks and 24 (twenty-four) months for other financial institutions. All businesses operating in the financial services ecosystem are encouraged to review their AML monitoring infrastructure, compliance frameworks and reporting systems to ensure alignment with the new regulatory expectations.

This is an applauded proactive step taken in the right direction, it shows Nigeria’s unwavering commitment to combat and prevent Money Laundering, Terrorism Financing and Proliferation Financing.

CONCLUSION

The policies introduced in March 2026 point to a clear and consistent direction; a move toward more structured systems, stronger oversight and greater accountability. Across tax administration, education verification, public health regulation and humanitarian protection, the focus is on replacing informal and weak practices with clearer rules that can be monitored and enforced. By setting clearer rules and enforcement expectations, they seek to close existing gaps that have allowed inconsistency, informal practices and weak accountability in critical public systems.

The reforms signal a deliberate shift toward embedding standardisation, documentation and proper verification as core requirements for public and private sector actors. It also sends a clear message to businesses and institutions that compliance and transparency are an integral part of their operations.

However, the real impact of these policies will depend on how well they are implemented because they have the potential to improve trust in public systems, support fairer economic participation and strengthen Nigeria’s overall development path.

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.

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