Towards a Legal Framework for Regulating Artificial Intelligence (AI) in Nigeria
Keywords:
Artificial Intelligence, cybercrimes, cybersecurity, data protectionAbstract
This article addresses Nigeria's current legal approach to Artificial Intelligence (AI), highlighting both its reliance on overlapping frameworks and the lack of a comprehensive, dedicated law. It compares this context with the EU's Artificial Intelligence Act and relevant international soft law, drawing out lessons for Nigeria. As AI is already integrated into key sectors such as telecommunications, health care, security, public administration, and financial services, the article advocates for a Nigerian AI Act anchored in local constitutional values, economic realities, and institutional strengths.
References
The National Artificial Intelligence Strategy from the Federal Ministry of Communications, Innovation, and Digital Economy was published on August 28, 2023. You can read it here: https://fmcide.gov.ng/initiative/nais/ accessed 3 November 2025. fmcide.gov.ng
See the following: the Nigeria Data Protection Act 2023, the Cybercrimes (Prohibition, Prevention, etc.) Act 2015 (as amended 2024), the Federal Competition and Consumer Protection Act 2018, the SEC Rules on Robo-Advisory Services 2021, the NCC Consumer Code of Practice Regulations 2024, and the CBN Risk-Based Cybersecurity Framework 2024. Central Bank of Nigeria+5PlacNG+5PlacNG+5.
The Federal Republic of Nigeria's Constitution, 1999 (as amended), s 37 (Right to private and family life). faolex.fao.org
See the NDPC enforcement communications and press reports on fines for privacy violations for more information on the Nigeria Data Protection Act 2023. Placing+1
The Nigeria Data Protection Commission (NDPC) has put out the General Application and Implementation Directive (GAID) 2025 (NDPC/NDP ACT-GAID/01/2025). ndpc.gov.ng
Reuters: "Nigeria's data privacy agency fines Fidelity Bank..." (22 August 2024). Reuters
The National Health Act of 2014 and the Nigerian Communications Commission's Consumer Code of Practice Regulations of 2024. admin.theiguides.org+1
The Cybercrimes (Prohibition, Prevention, etc.) Act 2015 and the Cybercrimes (Amendment) Act 2024. nfiu.gov.ng+1
The Nigerian Communications Commission's Lawful Interception of Communications Regulations 2019 and the Central Bank of Nigeria's Risk-Based Cybersecurity Framework and Guidelines for DMBs and PSBs (May 2024) are both important. PolicyVault.Africa+1
The Federal Competition and Consumer Protection Act of 2018. fccpc.gov.ng
Reuters: "Nigeria fines Meta $220 million for breaking consumer and data laws" (19 July 2024) (noting that the FCCPC and NDPC worked together). Reuters
FCCPC, Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending 2022; FCCPC, Digital Consumer Lending Guidelines (2025 update). +1 fccpc.gov.ng
Securities and Exchange Commission, Rules on Robo-Advisory Services (30 August 2021). sec.gov.ng
The Nigerian Communications Commission's Consumer Code of Practice Regulations 2024. ncc.gov.ng
The Central Bank of Nigeria's Risk-Based Cybersecurity Framework and Guidelines for DMBs and PSBs (May 2024). The Central Bank of Nigeria
Evidence Act 2011, s 84; see, for example, studies on s 84 and important court cases. broderickbozimo.com+1
UNESCO's 2021 Recommendation on the Ethics of Artificial Intelligence and the OECD's 2019 AI Principles. unesco.org+1
Regulation (EU) 2024/1689, also known as the Artificial Intelligence Act, was published in the Official Journal on July 12, 2024. EUR-Lex
The Constitution of the Federal Republic of Nigeria, 1999 (as amended). faolex.fao.org
The Data Protection Act of Nigeria 2023. Placing
The NDPC, NDP Act General Application and Implementation Directive (GAID) 2025. ndpc.gov.ng
The Cybercrimes (Prohibition, Prevention, etc.) Act 2015 and the Cybercrimes (Amendment) Act 2024. nfiu.gov.ng+1
The National Health Act of 2014. admin.theiguides.org
The 2018 Federal Competition and Consumer Protection Act. fccpc.gov.ng
Nigerian Communications Commission, 2019 Rules on the Lawful Interception of Communications. Policy Vault Africa
Nigerian Communications Commission's 2024 Consumer Code of Practice Regulations. ncc.gov.ng
The Central Bank of Nigeria's Risk-Based Cybersecurity Framework and Guidelines for DMBs and PSBs (2024). The Central Bank of Nigeria
Rules on Robo-Advisory Services from the Securities and Exchange Commission (2021). sec.gov.ng
Regulation (EU) 2024/1689 (the Artificial Intelligence Act). EUR-Lex
UNESCO's 2021 Recommendation on the Ethics of Artificial Intelligence. unesco.org
AI Principles from the OECD (2019). oecd.ai
National AI Strategy from the Federal Ministry of Communications, Innovation, and Digital Economy (28 August 2023). fmcide.gov.ng
FCCPC: Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending (2022); Digital Consumer Lending Guidelines (2025). +1 fccpc.gov.ng
Reuters: "Nigeria's data privacy agency fines Fidelity Bank..." (22 August 2024). Reuters
Reuters: "Nigeria fines Meta $220 million..."
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