INTRODUCTION
The September Policy Trend Trail considers the key policy and regulatory developments that reflect Nigeria’s efforts to strengthen economic growth, financial protection, digital transformation, public service delivery and education. Although these policies cut across different areas such as the financial sector, procurement, commercial, social and welfare consideration amongst others, the policies share a common focus on improving the existing systems and creating better conditions for citizens. This policy trend trail therefore considers not only what the policies seek to achieve, but also the practical issues they address and what their implementation could mean for Nigeria.
POLICIES
THE PROPOSED NATIONAL FINANCIAL INTELLIGENCE FRAMEWORK
In September, 2026, the Nigerian Financial Intelligence Unit (NFIU) commenced the design of a proposed Joint Financial Intelligence Collaboration Framework (the “Framework”). The Framework seeks to bring together public and private-sector stakeholders, including regulators, banks, insurance companies, fintechs, Virtual Asset Service Providers (VASPs) and technology companies, to establish a trusted platform for sharing financial intelligence. The objective is to enable the early detection of emerging financial threats, disrupt illicit financial networks and strengthen the overall resilience of Nigeria’s financial system.
The significance of the proposal is that it aims to replace the existing system of institution-based reporting with an improved system that enables public-private intelligence collaboration. Given that financial crimes extend beyond traditional regulatory boundaries to fintechs, digital payments, crypto and other virtual assets and other technology-enabled channels, the Framework is intended to enhance the ability of regulators and private-sector entities to share and consolidate information that might otherwise remain fragmented across different institutions. This is also consistent with Nigeria’s preparation for its 2027 Financial Action Task Force (“FATF”) evaluation.
This proposal signals impending regulatory obligations and compliance expectations for all businesses within the financial system as well as businesses whose activities generate financial crime risks. It also re-emphasises the need for all reporting entities to ensure that their KYC records, beneficial ownership information, transaction-monitoring systems, suspicious transaction reporting processes, and internal escalation mechanisms are sufficiently robust to withstand the increased information-sharing and supervisory scrutiny that may be introduced under the Framework.
BANK SCRUTINY OVER TERRORISM FINANCING RISKS
The Central Bank of Nigeria (“CBN”) has heightened its supervision over terrorism-financing risk management using both on-site and off-site supervisory engagements to assess Anti-Money Laundering (AML), Counter-Financing of Terrorism (CFT) and Counter-Proliferation Financing (CPF) controls.
The CBN’s effort to improve scrutiny is built on its existing framework on AML/CFT obligations imposed on financial institutions. It is therefore necessary that banks and other financial institutions scrutinise their AML/CFT monitoring systems to assess whether:
i. their risk assessments actually identify terrorism-financing exposure;
ii. their transaction-monitoring systems can detect relevant patterns;
iii. sanctions screening is effective; and
iv. suspicious transaction reports are being identified and filed appropriately.
The aim of conducting this assessment is to determine how effective their AML/CFT controls are and not merely whether they have an AML/CFT policy in place.
The import of the heightened regulatory oversight of CBN over AML/CFT obligations is that AML/CFT compliance is moving from being a simple submission of documentation exercise to an operational and active supervisory focus. As such, institutions will need to be able to demonstrate how they identify terrorism-financing risks, how those risks inform their customer risk-rating and monitoring systems, how sanctions lists are incorporated into screening and how alerts are escalated and documented. This is particularly relevant given the CBN’s existing 2026 standards for automated AML/CFT/CPF solutions, which require regulated institutions to deploy systems capable of real-time detection, analysis and reporting of suspicious financial activity.
PROPOSED HARMONISATION OF BENEFICIAL OWNERSHIP DATABASE
The Corporate Affairs Commission (“CAC”) proposed the harmonisation and centralisation of beneficial ownership information across Nigeria, with the CAC corporate registry as the central repository for beneficial ownership data. A beneficial owner refers to a natural person who ultimately owns or controls a company, whether directly or indirectly, including a person who meets the statutory criteria for a Person with Significant Control (PSC) under the Companies and Allied Matters Act 2020 (CAMA 2020).
The CAC introduced this proposal to address the existing fragmented approach of collating and storing beneficial ownership data in Nigeria with each sector having its own definitions, thresholds and filing requirements. For example, for the corporate sector, the beneficial ownership data is maintained by the CAC as PSC under Sections 119 and 120 of CAMA 2020; while for the extractive sector, the data is stored with Nigeria Extractive Industries Transparency Initiative (NEITI) through the beneficial ownership portal and for the free trade zones, the data is collected by the Nigeria Export Processing Zones Authority (NEPZA).
This fragmented structure makes it challenging to identify the ultimate individuals benefitting from and controlling corporate entities in Nigeria, thereby undermining financial monitoring efforts.
The proposed harmonisation is not intended to displace the statutory obligations of NEPZA and NEITI, but rather to ensure that the information of beneficial owners across various sectors is consolidated under a single repository for transparency and easy oversight access by all regulators. Another benefit of this proposal is that it would strengthen financial monitoring, improve the effectiveness of anti-money laundering oversight and bring Nigeria closer to alignment with the Financial Action Task Force (FATF) recommendations on beneficial ownership transparency. The likely implication of this proposed harmonisation is that there will be heightened compliance demands on companies across all sectors to ensure that their PSC (beneficial owners according to the Companies and Allied Matters Act, 2020) information is updated at every phase of a change in shareholding or control structure of the company.
While the policy rationale behind this proposal is sound, its implementation carries records conflict risk. To curb this, it is important that there is stakeholder consultation with all necessary regulatory offices, after which a cross-sector harmonisation framework can be developed and adopted. The framework must provide definitions, thresholds, reporting structures, filing obligations etc., to drive uniform compliance and implementation. Failure to do so could leave the successful implementation of the proposal at the mercy of the institutional goodwill of the sectors.
PROHIBITION OF STREET BEGGING BILL, 2026
In response to the growing prevalence of street begging activities and recurring ills associated with the same, the Lagos State Government has proposed the Street Begging and Street Urchins (Prohibition, Prevention and Rehabilitation) Bill, 2026 (the “Bill”). Following the second reading of the Bill by the Lagos State House of Assembly, a public hearing on the same was held.
The Bill pursues a dual approach of prohibition and rehabilitation. On the prohibitive side, it proposes the criminalisation of street begging and street urchin activities by proposing a 2-year term of imprisonment or a fine of up to N200,000.00 for second-time offenders. It further prohibits the exploitation of children for the purpose of begging, and vests enforcement powers including powers of arrest and prosecution in the Environmental Sanitation Corps Agency (the “Agency”). Also, jurisdiction over related offences is conferred on both the Magistrate Court and the High Court of Lagos State.
A more consequential feature of the bill is its rehabilitative approach. The Bill establishes Rehabilitation and Welfare Centres (the “Centres”) which are tasked with the reintegration of street urchins and first-time offenders involved in activities associated with street begging, into society through vocational training, literacy programmes, psychological counselling, life skills education and social welfare assistance. The legislative design is double-edged in that the criminal sanction deters recidivism whilst the rehabilitative infrastructure addresses the underlying conditions that produce street urchins and begging in the first instance.
Although the policy direction of the Bill is forward-thinking, there are however some policy concerns as it relates to the adequacy of safeguards against possible abuse by the Agency during enforcement. Furthermore, the risk of enforcement overreach, particularly against vulnerable persons, should be properly considered and possibly cured through enlarged provisions to protect the vulnerable whilst ensuring that the Agency is functioning under commensurate regulatory oversight. Another key consideration is whether protections exist to ensure that the centres are adequately funded and equipped prior to the commencement of enforcement of the law. Overall, the policy represents a model that balances punitive deterrence with social investment to manage the identified societal challenge.
IMPLEMENTATION OF THE NATIONAL GUIDELINES ON DEBARMENT OF CONTRACTORS
Nigeria’s public procurement system has long grappled with a credibility deficit, owing to the recurrence of non-performing contractors, abandoned projects and fraudulent procurement practices which have eroded public confidence and drained public resources. Although the Public Procurement Act, 2007 (PPA) provides a legal foundation for accountability and transparency, its debarment provision has not been maximised over the years.
In view of the foregoing, the National Guideline on Debarment of Contractors (the “Guideline”), made pursuant to Sections 6 and 58 of the PPA, was approved in 2025, and in September 2026, the Federal Government issued a directive on the implementation of the Guideline to promote integrity, transparency and accountability in public procurement; value for money in public expenditure and to protect government from bad and non-performing contractors.
Building on this foundation, the Guideline extends and operationalises the debarment mechanism, establishing clear grounds, procedures and consequences. Thus, a consultant, service provider or contractor (collectively referred to as “entities”) may face debarment where they are found to have:
i. violated the PPA;
ii. given or promised to give money, gifts or any tangible item to a current or former employer of a procuring entity or the Bureau of Public Procurement (BPP) with the aim of influencing a procurement action or decision;
iii. engaged in wrongdoing relating to contract delivery;
iv. wilfully failed to perform in accordance with the terms of a contract;
v. a history of failure to perform or of unsatisfactory performance of a contract;
vi. been convicted for fraud or other offence connected with obtaining, attempt to obtain or performing a public contract or subcontract;
vii. falsified documents; and
viii. been debarred by a multilateral organisation.
Prior to the debarment, the BPP is required, through a dedicated committee established for that purpose, to investigate the matter and notify the entity concerned, providing an opportunity to respond before a final determination is made. Upon confirmation of guilt, entities may be debarred for a minimum period of 3 (three) years and a maximum period of 5 (five) years. Also, the scope of debarment is comprehensive, as debarred entities are prohibited from acting in any capacity, whether as contractors, sub-contractors, agents, representatives, consultants or service providers in relation to any government procurement activity.
The implementation of the Guideline indicates a shift in the outlook of public procurement in Nigeria, from a system that passively tolerated non-performance as an administrative inconvenience to one that treats it as a sanctionable breach. In addition, it levels the playing field for compliant entities, making it considerably harder for non-performing or debarred contractors to return under different arrangements.
Overall, the strength of this Guideline, like any other policy, will not be measured by its promises but by the consistency of its application. The BPP must therefore ensure that the implementation of this Guideline is closely monitored. Failure to do so risks the Guideline being another well-drafted policy instrument that falls short of its reform potential in practice.
BALANCING INTERNET ACCESS WITH DIGITAL EDUCATION FOR NIGERIAN STUDENTS
Prior to the commencement of the 2025 academic session, the Ministry of Education reviewed the educational curriculum of schools in Nigeria to include a broader focus on digital education. In the continued monitoring of the revised curriculum, the Ministry has decided that starting from 1st October, 2026, Nigerian students will receive a daily data allocation of 100 megabytes with the aim of promoting access to approved educational and digital learning platforms.
This free data policy is intended to address the cost barrier to digital education, particularly for students from underserved communities and low-income households. This policy would initially apply to students in public senior secondary schools and tertiary institutions, before being rolled out to broader categories of learners. Through this policy, students will be able to access platforms such as learning management systems, digital libraries, educational repositories, and technical and vocational training platforms.
This data initiative is not being rolled out in isolation. The Ministry has also communicated proposed measures to regulate internet access for children under the age of 16 (sixteen), although it has not disclosed the specific form of restriction or how it will be enforced.
The foresight displayed by the Ministry in creating a balance and not taking a reactive position is highly commendable. By this dual approach, the government is able to reduce the cost of educational data and expand learning opportunities, particularly for children who may otherwise be excluded from access to the internet whilst at the same time workshopping answers to the questions around parental responsibility, privacy, age verification, cybersecurity and the extent of government control over children’s online activities.
There are, however, concerns about the effectiveness of the free data policy, especially concerning the volume of data afforded to students under the scheme. Modern websites and educational platforms incorporate multimedia elements, creating an apprehension that simply loading these sites would deplete the allocated 100 megabytes before any substantial learning takes place, therefore it does seem that increasing the data allocation available to students might serve to better achieve the aims of the policy
CRACKING DOWN ON DECEPTIVE AI-ASSISTED MARKETING
The Federal Competition and Consumer Protection Commission (FCCPC) has proposed provisions in the Draft Sales Promotion Regulations, 2026, released on 30th September, 2026, to regulate the use of Artificial Intelligence (AI), machine learning and automated technologies in promotions, marketing communications and consumer engagement directed at Nigerian consumers. The proposed framework would require businesses using AI or automated technologies for marketing purposes to register such use with the FCCPC, require AI-generated or automated promotional content to be identifiable, and make businesses responsible for representations and claims generated through technologies they deploy. Corporate defaulters may face penalties of up to ₦100 million or 1% of previous-year turnover, whichever is greater.
The proposal addresses a legitimate consumer-protection concern. Generative AI has significantly reduced the cost of producing highly realistic but potentially misleading commercial content. AI-generated hotel rooms, food, clothing, product demonstrations, or synthetic testimonials can create expectations that differ materially from the actual product or service. AI-generated influencers and automated systems can similarly give consumers a false impression that a real person has used or endorsed a product. Businesses should therefore not be able to avoid responsibility for misleading representations simply because they were generated by an automated system.
However, there is a legitimate question concerning potential regulatory overlap between the FCCPC and the Advertising Regulatory Council of Nigeria (ARCON). While ARCON regulates advertising, the FCCPC has a broader consumer-protection mandate, so some overlap is not inherently objectionable, however, the primary concern is whether businesses will face multiple layers of registration, approval or compliance requirements for the same commercial communication. This is particularly relevant because the FCCPC’s April 2026 exposure drafts already contemplated AI-generated consumer communications, including synthetic testimonials, deepfakes, chatbots and AI-generated product imagery. The Commission should therefore clarify what specific regulatory gap an AI registration regime is intended to address beyond the application of existing consumer-protection and advertising rules.
The proposal should also be considered within Nigeria’s broader AI policy environment. NITDA and other government institutions are simultaneously promoting responsible AI adoption and domestic AI development. Consumer protection and innovation are not inherently contradictory objectives. The regulatory mistake would be to assume that every new AI-related risk requires a new registration, approval or licensing requirement. The objective should instead be to make responsible AI use easier, safer and more predictable. Regulation should target genuinely new or amplified risks while allowing businesses and creators to benefit from legitimate productivity gains.
Finally, the proposed penalties require proportionality. A ₦100 million or 1% of turnover penalty may be justified for serious consumer harm, but the framework should distinguish deliberate deception from unwitting miscommunication and consider the conduct, culpability and impact of the offending business.
Overall, the FCCPC’s objective is legitimate, but there is a need to ensure that its regulations address AI risks without creating a regulatory environment in which avoiding AI usage becomes the easiest route to compliance.
CONCLUSION
The policy developments in September 2026 demonstrate a broader shift towards strengthening regulatory oversight, improving institutional coordination and addressing practical barriers affecting citizens and businesses. Across financial intelligence, beneficial ownership, public procurement, social welfare and digital education and advertising, the policies seek to move beyond formal frameworks towards more effective implementation and accountability. However, their success will ultimately depend on clear regulatory structures, adequate safeguards, inter-agency coordination and consistent enforcement.
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