Country Profile on AI Governance: Nigeria

Mean of all 10 indicator scores. West Africa mean 1.70 · all 54 states mean 1.76.

1. S1.1

   National AI strategy existence

   Score 3 / 4

   April 2024, Nigeria's Federal Ministry of Communications, Innovation and Digital Economy (FMCIDE) hosted a 4-day co-creation workshop with over 120 AI experts, researchers, and industry leaders to draft the National AI Strategy. In August 2024, the FMCIDE officially launched the National Artificial Intelligence (AI) Strategy draft to guide the nation's AI development, deployment, and governance.

   Sources fmcide.gov.ng (opens in a new tab)

2. S1.2

   Strategy adoption date

   Score 1 / 4

   2025-09-01

   Scoring basis Threshold applied. Adopted 2025-09: 9 months before 2026-06-30.

3. S1.3

   Political commitment signals

   Score 4 / 4

   There is formal political commitment from the leadership. High-level executive backing is demonstrated by the Minister of Communications, Innovation and Digital Economy, and supported directly by directives from the Presidency to position Nigeria as Africa's prime AI hub. The presidency has supported major initiatives like the Three Million Technical Talent (3MTT) program and the National AI Strategy co-creation workshop.

   Note: High-level ministerial leadership and institutional actions demonstrate a clear, formal commitment to AI development

   Sources doa-law.com (opens in a new tab)

4. S1.4

   Dedicated AI budget allocation

   Score 3 / 4

   Nigeria does not currently have a dedicated, ring-fenced national budget line item solely for AI implementation. Funding for AI initiatives is currently embedded within the broader FMCIDE/ICT budget, supplemented by partnerships with international philanthropic organizations (e.g., Luminate) and private sector tech giants (e.g., Google)

   Note: While programs like the 3MTT and the National AI Fund exist, they rely heavily on external partnerships and broader digital economy allocations rather than a dedicated national AI budget line

5. S1.5

   AU Continental AI Strategy alignment

   Score 4 / 4

   Nigeria’s National AI Strategy is closely aligned with the African Union (AU) Continental AI Strategy. It focuses heavily on ethical AI, developing local language models (LLMs), human capital development, and regional leadership.

   Note: Nigeria actively participates in AU digital economy and AI working groups to ensure regional alignment.

6. S1.6

   Multi-stakeholder consultation

   Score 4 / 4

   Formed via a highly transparent, peer-reviewed model bringing together civil society groups (like CSEA), technical communities (Data Science Nigeria), academic researchers, and big-tech representation.

7. S1.7

   Sector prioritisation

   Score 3 / 4

   The NAIS explicitly targets and defines optimization pipelines for Fintech, Agriculture (smart-farming systems), Health (predictive analytics), and Language Technology (indigenous LLMs).

8. S1.8

   Implementation roadmap

   Score 3 / 4

   Includes short-term milestones (such as launching the 3MTT tech cohorts and the local Awarri LLM) and long-term milestones mapping out regulatory guardrails and national high-performance computing centers.

9. S1.9

   Monitoring and evaluation framework

   Score 2 / 4

   Oversight and execution metrics are built into the mandate of the National Centre for Artificial Intelligence and Robotics (NCAIR) to measure ecosystem milestones.

10. S1.10

    Strategy review mechanism

    Score 3 / 4

    The NAIS mandates periodic iteration loops and performance check-ins to update compliance guidelines relative to changing compute capabilities across global markets.

Mean of all 10 indicator scores. West Africa mean 1.18 · all 54 states mean 1.32.

1. G2.1

   AI-specific legislation

   Score 1 / 4

   There is no single standalone "AI Act" yet, but the National AI Strategy (NAIS) launched in September 2025 lays out the legislative roadmap.

   Sources premiumtimesng.com (opens in a new tab)

2. G2.2

   Data protection law status

   Score 4 / 4

   Fully backed by the Nigeria Data Protection Act (NDPA) 2023.

   Sources kpmg.com (opens in a new tab)

3. G2.3

   DPA AI mandate

   Score 4 / 4

   The NDPC actively collaborates on automated decision-making regulations and guidelines under the NDPA frameworks

   Sources ncair.nitda.gov.ng (opens in a new tab)

4. G2.4

   DPA staffing and budget

   Score 4 / 4

   financed by federal allocations and data compliance audit regulatory fees with over 100-250

   Note: Annual Revenue Metrics: While a fixed federal budget allocation is not public, the NDPC projected an ecosystem revenue generation target of ₦13.8 billion. Furthermore, the commission revealed it internally generated ₦7.2 billion (approximately $5.1 million USD) directly from company compliance registrations, audit filings, and administrative enforcement fines

   Scoring basis Threshold applied. Raw value: 175 (FTE staff). Raw value read from the evidence: "with over 100-250" [garbled range "over 100-250"; midpoint of 100-250 given; unit assumed staff]. Listed for second-edition review: The evidence figure is garbled and no published headcount for the Nigeria Data Protection Commission was found in the October 2026 check.

   Sources businessday.ng (opens in a new tab)

5. G2.5

   AI regulatory body existence

   Score 3 / 4

   Handled by the National Centre for Artificial Intelligence and Robotics (NCAIR) alongside the National Artificial Intelligence Trust (launched Feb 2025)

   Sources prnigeria.com (opens in a new tab)

6. G2.6

   Institutional design model

   Score 3 / 4

   Managed across NITDA, NCAIR, and the NDPC rather than a single separate AI Ministry.

   Sources prnigeria.com (opens in a new tab)

7. G2.7

   Malabo Convention ratification

   Score 3 / 4

   Nigeria formally signed but yet to ratify and deposit its instrument for the AU Malabo Convention.

   Sources au.int (opens in a new tab)

8. G2.8

   Enforcement actions taken

   Score 2 / 4

   The Nigeria Data Protection Commission (NDPC) has not yet issued direct, AI-specific financial penalties, but it has officially stepped into the enforcement and regulatory arena

   Sources businessday.ng (opens in a new tab)

9. G2.9

   Extraterritorial provisions

   Score 2 / 4

   Handled via Section 2 of the NDPA 2023, which restricts personal data processing of Nigerian citizens by foreign entities

   Sources placng.org (opens in a new tab)

10. G2.10

    IP framework for AI

    Score 1 / 4

    Nigeria’s IP laws still don’t directly address AI-generated content as of 2026. It’s a legal grey area.

    Sources inventa.com (opens in a new tab)

Mean of the 9 scored indicators; 1 carries no score. West Africa mean 1.40 · all 54 states mean 1.51.

No score: 1 context only.

1. I3.1

   Data center count

   Score 4 / 4

   Main hubs run by MainOne (MDXi), Medallion (Digital Realty), Rack Centre, and Galaxy Backbone with 26 operational data center and planned

   Scoring basis Threshold applied. Raw value: 26 (data centres).

   Sources datacentermap.com (opens in a new tab)

2. I3.2

   Data center capacity (MW)

   Score 3 / 4

   Nigeria's operational data centers currently have an estimated combined capacity between 65 MW and 86 MW of IT load. With over 20 active colocation and hyperscale sites, the vast majority located in Lagos, the industry is actively undergoing massive expansion, with planned and upcoming projects expected to push national capacity over 400 MW in the coming years.

   Scoring basis Threshold applied. Raw value: 75.5 (MW).

   Sources insights.techcabal.com (opens in a new tab)

3. I3.3

   Submarine cable landing points

   Score 4 / 4

   SAT-3, MainOne, Glo-1, WACS, and Google's Equiano cable with Eight with investment reaching $9.7b

   Scoring basis Threshold applied. 8 cable systems (TeleGeography, accessed 2026-10-06).

   Sources guardian.ng (opens in a new tab)

4. I3.4

   International bandwidth (Gbps)

   Score 3 / 4

   CableDesign Capacity2Africa180 TbpsGoogle Equiano144 TbpsWACS14.5 TbpsGLO-212 TbpsNCSCS12.8 TbpsMainOne10 TbpsACE5.5 TbpsSAT-30.8 Tbps

   Scoring basis Fellow score kept; no raw value for the threshold.

   Sources businessday.ng (opens in a new tab)

5. I3.5

   Hyperscaler presence

   Score 2 / 4

   Microsoft Azure and AWS operate local edge nodes/infrastructure, with expanding Google Cloud deployments.

   Sources guardian.ng (opens in a new tab)

6. I3.6

   GPU/HPC access

   Score 3 / 4

   GPU availability for AI research in Nigeria has expanded significantly. Researchers can now access local HPC clusters via the Nigeria AI Collective (NAIC) and the National Centre for Artificial Intelligence and Robotics (NCAIR) in Abuja

   Sources huggingface.co (opens in a new tab)

7. I3.7

   Data localisation provisions

   Score 2 / 4

   Nigeria enforces strict and evolving data localisation requirements across multiple sectors, with recent regulatory updates significantly tightening compliance rules for financial institutions, telecommunications, and general data privacy

   Sources businessday.ng (opens in a new tab)

8. I3.8

   Cross-border data flow framework

   Score 3 / 4

   Managed securely through the NDPC's legal conditions for cross-border data transfer assessments

   Sources olaniwunajayi.net (opens in a new tab)

9. I3.9

   Foreign AI surveillance spending

   ○Context only: Context flag outside the score

   Nigeria has documented public expenditures exceeding $470 million on foreign AI-enabled surveillance technologies, making it the largest buyer of smart city monitoring infrastructure in Africa. This spending is part of a broader collective investment of $2.1 billion by 11 African countries

   Scoring basis Context flag; outside the score.

   Sources punchng.com (opens in a new tab)

10. I3.10

    Sovereign cloud initiatives

    Score 3 / 4

    Nigeria’s national sovereign cloud and domestic computing initiatives are anchored by the National Information Technology Development Agency (NITDA). The core goal is to protect data sovereignty, localize computing power, and shield the local tech ecosystem from dollar-denominated FX volatility

Mean of all 10 indicator scores. West Africa mean 1.14 · all 54 states mean 1.20.

1. H4.1

   AI researchers per million

   Score 3 / 4

   Estimated: ∼29 AI researchers per million population in Nigeria.But there’s no single official “AI researchers per million” stat from UNESCO/World Bank yet. We have 2 credible proxy numbers:1. Best available estimate: 29 per millionSource: Minister Bosun Tijani, Aug 2023. He said the Ministry identified “over 6,000 Artificial Intelligence researchers of Nigerian descent across the globe” by mining academic publications. digitaleconomymag.comCalculation: Nigeria population ∼220M in 2024. 6,000 researchers ÷ 220M × 1,000,000 = ∼27-29 researchers per million. tribuneonlineng.comCaveat: This is “Nigerians of descent worldwide” including diaspora at Google, Meta, etc. Not “researchers physically in Nigeria”. The Minister noted thousands of AI papers authored by Nigerians but “none tied to Nigerian institutions”. businessday.ng

   Scoring basis Threshold applied. Raw value read from the evidence: "Estimated: ∼29 AI researchers per million population in Nigeria." [based on 6,000 Nigerian-descent AI researchers worldwide incl. diaspora, not domestic]. Listed for second-edition review: The raw value rests on 6,000 AI researchers of Nigerian descent worldwide, including the diaspora, not researchers in Nigeria.

   Sources digitaleconomymag.com (opens in a new tab)

2. H4.2

   DPA staff with AI competency

   Score 1 / 4

   hat we know from NDPCData pointDetailTotal NDPC staff“Just over 110 officers” overseeing Nigeria’s data ecosystem across 774 LGAsAI/technical capacity buildingNDPC led a UK “DPIA Train-the-Trainer Specialists programme” for Commission staff in 2025-2026 to deepen technical expertise in Data Protection Impact Assessment. DPIA is key for AI risk assessment under NDPA Section 28Staff roles mentionedHead of Research & Development = Dr Tolu Pius-Fadipe. Head of Innovation Unit = Ms Adaobi Nwankwo. These units likely house technical/AI skills, but headcount not givenNDPC’s view on AI skills gapNational Commissioner Vincent Olatunji says NDPA is “most progressive law… has provisions to make regulations on emerging technologies like AI”. Commission explores “adaptive sandboxes for AI integration” with ICT firms. But no staff numbers attached

   Scoring basis Fellow score kept; no raw value for the threshold.

3. H4.3

   University AI programs

   Score 3 / 4

   20+ universities offering AI/ML degree programs as of 2025/2026. Count depends on whether you include B.Sc AI, specializations, M.Sc, or diplomas.1. Full B.Sc AI degree programs - NUC approved 2025 NUC added B.Sc Artificial Intelligence to Core Curriculum & Minimum Academic Standards Oct 2025. Universities must pass resource assessment before admitting students. Confirmed approvals:Modibbo Adama University, Yola MAU - NUC approved B.Sc AI for 2025/2026 session Federal University Dutse FUD - Unveiled new degrees in AI + Machine Learning + Data Science as part of 2024 reforms More will come as universities complete NUC resource assessment.2. Universities with AI/ML specializations within Computer Science/Engineering These run AI/ML courses, labs, research, but not standalone “B.Sc AI” yet:UniversityAI/ML offeringUniversity of Ibadan UIB.Sc Computer Science AI Specialization, M.Sc Computer Science AI Focus, PhD AI fields. Ranked #1 for AI research in NigeriaUniversity of Nigeria Nsukka UNNAI specialization in Computer Science + Research & Development Lab for ML algorithms, deep learningCovenant UniversityAI/Bioinformatics + Machine Learning research. Ranked best AI program 2025 by AI Awareness DayFederal University of Technology Akure FUTAAI research in Computer Science + Engineering. In track to be first with full Dept of AI & Machine LearningAhmadu Bello University ABUAI specialization coursesUniversity of Lagos UNILAGAI/ML courses + Africa’s first OpenAI Academy + AI UniPod. M.Sc/STEM masterclassesObafemi Awolowo University OAUComputer Engineering AI specialization + M.Sc Embedded AI EU programUniversity of IlorinAI courses in Computer ScienceFederal University of Agriculture Abeokuta FUNAABAI coursesUniversity of CalabarAI coursesThomas Adewumi University TAUB.Sc Computer Science ranked “best AI education programme in Nigeria 2025”Nile UniversityMasters + Undergraduate tracks in AI, prompt engineeringAmerican University of Nigeria AUNData Science + AI in School of IT & ComputingThat’s 13+ universities with active AI/ML specialization/track already.3. M.Sc Embedded AI - EU partnership 5 universities run NUC-approved M.Sc Embedded Artificial Intelligence with EU + KTH Sweden + Siegen Germany:University of Port Harcourt UNIPORT University of Abuja UNIABUJA Obafemi Awolowo University OAU Abubakar Tafawa Balewa University ATBU Bauchi Michael Okpara University of Agriculture MOUAU Umudike These started 2023-2024 with EU grant.4. Diplomas/Certificates Iconic Open University - Diploma + Certific

   Scoring basis Threshold applied. Raw value: 7 (universities).

4. H4.4

   African-authored AI publications

   Score 2 / 4

   1. CSET/Our World in Data count – the main global dataset Definition used: Article counts for Nigeria if ≥1 author is affiliated with an institution there at time of publication. If authors are from multiple countries, it counts once for each country. ourworldindata.orgLatest available annual numbers: CSET data via Our World in Data runs 2016-2024, last updated Apr 27, 2026. The dataset doesn’t show Nigeria’s exact annual figure in the search snippet, but it’s the standard source governments use for “publications with domestic affiliation”. ourworldindata.org2. Nigeria-specific counts from gov’t + research Since CSET numbers are low for Nigeria, these give the annual picture:PeriodPublications with domestic affiliationSource/Context2024-2025: ∼20 papers in 18 months20 peer-reviewed AI compute papers tied to Nigerian institutionsNITDA’s Nigerian Artificial Intelligence Research Scheme NAIRS launched early 2024. Before NAIRS, “none tied to Nigerian universities or labs” despite thousands by Nigerians abroad. NAIRS funded 45 consortia with mandate to publish within 1 yearCumulative to 2024: ∼631 totalCovenant University 375 + FUTA 135 + UI 121 = 631 publicationsScientometric analysis 2024 of Nigerian AI research. Counts all AI papers by authors affiliated with these domestic institutions over multiple years2025 examplesMultiple individual papers: SPEC-AI Nigeria trial in maternal health, ML for HIV treatment continuity, GenAI in education survey of 260 teachersShows active annual output, but no total count giventechcabal.comouci.dntb.gov.uaourworldindata.org3. Key notes on “domestic institution” Before 2024: Problem flagged by Minister Bosun Tijani: “thousands of AI papers authored by Nigerians, but none tied to Nigerian institutions”. Most Nigerian AI researchers published from US/UK affiliations.After NAIRS 2024: Output tied to domestic institutions jumped. NAIRS specifically created “to give Nigerian researchers, both at home and in diaspora, a structured platform to produce Nigeria-led AI research”.Top institutions: Covenant University most prolific with 375 total AI publications, then FUTA 135, UI 121. techcabal.comouci.dntb.gov.ua

   Scoring basis Threshold applied. 1101.3 papers/yr ÷ 232.68m people = 4.73 per million (floors applied).

5. H4.5

   AI patents filed

   Score 1 / 4

   No official “AI-related patents filed domestically per year” number is published for Nigeria. Patent filings overall are very low, and Nigeria’s IP law doesn’t yet separate/tag “AI patents” in its stats.1. What the data showsMetricNumber/NoteSourceTotal patent applications in Nigeria 20251,104 applications total, all fields. 1,081 patents grantedAdams & Adams patent landscape report Oct 2025. Nigeria ranked 4th in Africa after SA, Morocco, Algeria, EgyptTotal patent certificates 2010-2024340 certificates secured by NOTAP for inventors/researchers since 2010. Avg ∼24/yearMinister of Innovation, Science & Tech, 2024Patent applications from Nigerian institutions1,079 applications submitted by tertiary institutions as of May 2022. 400 national patents grantedNOTAP Director, May 2022AI-specific filingsNot reported separately. Patents & Designs Registry + NOTAP don’t publish “AI” breakdown. WIPO/TPDR data is aggregated by total patents, not tech fieldTPDR + WIPO IP Landscape

   Scoring basis Fellow score kept; no raw value for the threshold.

6. H4.6

   K-12 CS education

   Score 4 / 4

   Status of K-12 Computer Science Education in Nigeria – 2025/20261. Curriculum: Exists, but transitioning to new versionLevelCurrent subject nameContent coveredExam bodyPrimary 1-6Basic Science & Technology to Information Technology (IT)Part of “Basic Science & Technology”. NERDC has IT in 9-Year Basic Education CurriculumNo WAEC, internal assessmentJunior Secondary JSS 1-3Computer Studies / ICTNERDC-approved. JSS1 topics: Basic typing, saving files, Microsoft Word, Excel rows/columns, Internet, computer maintenance. Exam: Junior WAEC/BECENERDC + BECESenior Secondary SS 1-3Computer Studies / Computer Science / Data ProcessingNERDC 3-year series. SS1: Communication system, word processing, programming language, computer software/hardware. SS3 textbook covers “new trends in computer science, programming, computer application, ICT”WAEC SSCE, NECOKey point: “Computer Studies” is already in the official curriculum from JSS1-SS3. “Data Processing” is a separate SS subject. But delivery is weak.2. Major 2025 reform: Coding + AI + Robotics added Federal Govt launched new secondary curriculum Sept 2025 via NERDC:JSS 1-3 “Digital Literacy & Coding”: Word, Excel, PowerPoint, internet research, Python basics, Scratch advanced, robotics basic kits SSS 1-3 “Technology & Innovation”: Programming Python, JavaScript, HTML/CSS, data science basics, AI & robotics, cybersecurity, digital entrepreneurship AI & Robotics now listed as component of “Digital Literacy” at senior level Mandatory implementation starts January 2025 for Basic Ed + September 2025 for secondary

7. H4.7

   AI workforce training programs

   Score 4 / 4

   Government-supported AI reskilling/upskilling programs in Nigeria – 2025/20261. Flagship national programsProgramGov’t leadTarget + ScopeAI focusStatus/ReachAI National Skills Initiative AINSIFederal Ministry of Communications, Innovation & Digital Economy + Microsoft1M Nigerians in 3 years. Phase 2 launched Jan 2025AI skills for leaders, developers, tech users, public sector. Includes digital literacy, business leadership, AI hackathons, analytics, ML, DevOps, data science350,000+ Nigerians trained in AI as of Dec 2025. 63,000 completed pathways, 43,000 globally certified. Part of wider 4M digital skills trained since 20213 Million Technical Talent 3MTTFederal Ministry of Communications, Innovation & Digital Economy via NITDA3M Nigerians by 2027, ages 18-35. Covers software dev, cybersecurity, data, AIDeepTech_Ready Upskilling: 20,000 young Nigerians in Data Science + AI over 6-month cohorts. Supported by Google.org ₦2.8B grant. Includes self-paced + on-site + job readiness160K+ fellows trained across 3 cohorts, all 36 states + FCT. 15K+ from cohort 1 already employed. 201 Applied Learning Clusters nationwideGovernment AI CampusFMCIDE + Google.org + ApoliticalCivil servants nationwideAI fundamentals, procurement, leadership, ethical frameworks, smarter governance. Peer learning network with global expertsLaunched 2025. Designed to “make AI native to public service”Developers in Government DevsInGovFMCIDEPublic sector developersAI integration, analytics, ML, DevOps∼645 participants trained in analytics + AI integration. 1,000 developers upskilled in DevOps, ML, data science2. Key partners delivering for gov’t Microsoft + Data Science Nigeria + Lagos Business School: Implementation partners for AINSI. $1M investment to reach 1M Nigerians. LBS handles public sector leaders – 99 leaders from 58 agencies trained in AI governance, ethics, risk Google.org + Data Science Nigeria: ₦2.8B grant for DeepTech_Ready under 3MTT. Targets 20,000 in data science/AI. Also “Experience AI” training 125,000 students via educators TeKnowledge: Delivery partner for AINSI Phase 2. Committed to directly train 10,000 Nigerians with focus on youth, women, developers, decision makers UNESCO: Trained 80 civil servants from Ministry of Youth + Information on AI fundamentals, data protection, digital governance under Programme on AI & Digital Transformation World Bank + Federal Ministry of Education: TechUnlock project trained 400 Nigerians in AI + Cybersecurity Jan 2024, targeting marginalized youth + PWDs

8. H4.8

   Labour transition policy

   Score 3 / 4

   Government framework for AI and labour market transition in Nigeria – Status 2025/2026Nigeria doesn’t yet have a standalone “AI & Labour Transition Act”, but the framework is built across 4 pillars: National AI Strategy + reskilling programs + labour policy positions + targeted job creation targets.1. Core policy document: Draft National AI Strategy 2024/2025 Led by Federal Ministry of Communications, Innovation & Digital Economy FMCIDE, drafted with Nigerian AI professionals + stakeholders.Labour market goals stated:70% of youth 16-35 with AI skills by 2030 to reduce unemployment by 5 percentage points 50,000 AI jobs by 2030 – Minister Bosun Tijani’s 4-year blueprint targets 50K jobs via AI $15bn GDP boost by 2030 from AI adoption Top 10 globally for AI model training & talent by 2030, top 50 in AI readiness Labour transition approach in the Strategy:Build AI-ready workforce: “Educating future workforce at multiple levels, training current workforce, attracting/retaining talent, drawing international talent” Skills focus: Technical skills + change management, interaction design, legal/business models, communication, innovation management Public sector first: “Service-wide automation of civil service processes with AI playing significant role”. Government AI Campus launched with Google/Apolitical to train civil servants on AI fundamentals, leadership, ethics 2. Reskilling/upskilling delivery vehicles = labour transition toolsProgramLabour transition role3 Million Technical Talent 3MTTFlagship job-transition program. Targets 3M Nigerians by 2027. DeepTech_Ready cohort trains 20,000 in Data Science + AI for 6 months with job readiness support. 15K+ from cohort 1 already employed. Goal: move youth from unemployment/underemployment to digital jobsAI National Skills Initiative AINSIMicrosoft + FMCIDE partnership. 350,000 Nigerians trained in AI skills, target 1M. Includes “Developers in Government DevsInGov” to reskill 1,645 public sector devs in ML/DevOps. Also trains leaders in AI governance/ethics for job redesignNational Reskilling Fund proposedPolicy experts propose “levies on companies deploying labour-displacing AI + gov’t + development finance” to fund modular micro-credentials. Not yet law, but in policy debatesNAIRS + NCAIRNigeria AI Research Scheme funds 45 consortia to produce Nigeria-led AI research + jobs. National Centre for AI & Robotics drives R&D to create new roles3. Labour policy positions from gov’t “AI should support decent work, not replace workers” – Minister of Labour Muhammad Dingyadi at ILO 2025. Govt says AI will automate routine tasks but create jobs in tech, data science, digital services. Warns admin/clerical roles face disruption without skills support Platform economy standards: Nigeria welcomes ILO discussions on labour standards for platform work created by digital tech/AI Human oversight principle: Policy thinkers argue workers must not be subject to “unreviewable automated outcomes”. Impact assessments before AI deployment + right to challenge AI decisions Informal economy included: Frameworks must cover informal + platform workers, not just formal sector 4. Sector-specific transition plans Manufacturing: 44% of firms offer AI training, 22% reskill, 16% redeploy staff. AI transforming jobs, not eliminating. Biggest barrier = low AI knowledge + infrastructure Oil & gas: NCDMB pipeline engineering program 2026 trains 33 engineers in pipeline pigging + corrosion + digital literacy = “hybrid” technical + AI skills. NOGaPS industrial parks to create 2,000 jobs each in digital manufacturing SMEs: Studies show 25% of admin roles face high automation risk, but job creation depends on “targeted, scalable reskilling plans”

9. H4.9

   Informal economy AI assessment

   Score 3 / 4

   it’s partial and mostly “recognition + ongoing studies” rather than a full standalone gov’t assessment report yet.1. What the government has assessed/done so farActorAssessment/PositionKey findingNITDA – Federal GovtDirector of Corporate Communications Hadiza Umar: “NITDA is highly aware of the profound impact of AI and digital platforms on Nigeria’s informal workers, including traders, food vendors, transporters, and artisans. This is a central focus of our Strategic Roadmap and Action Plan SRAP 2.0”. NITDA notes opportunities: productivity, market access, financial inclusion. Challenges: job displacement for routine tasks, precariousness, deepening inequalities for those without digital access/literacy. Cites ride-hailing + e-commerce platforms as examplesNational AI Strategy NAIS 2024Minister Bosun Tijani: NAIS was built via “open, collaborative process involving government, academia, industry” with diaspora input. Strategy lists “social development and inclusion” as 1 of 3 objectives. Analysts say it should “transcend catching up… focus on indigenous AI ecosystem that reflects… informal markets, stories, social complexities”. So informal economy is flagged as context, not yet quantified.Federal Ministry of Labour + NSITFMinister Dingyadi at ILO 2025: “Platform work is gaining ground” + AI automating civil service processes. NSITF MD Faleye 2025: “AI-induced risks include technological displacement, income instability, psychological stress”. Calls to “rethink coverage, redefine risk, reimagine support” for workers. Explicitly flags “large informal sector constituting over 80% of the economy yet remains outside safety nets”. NSITF now prioritizing policies for AI + platform/gig workersMoniepoint + VP’s OfficeVice President Kashim Shettima: Informal economy is “heart of Nigeria’s story… from market traders to artisans”. Says gov’t places “high priority on informal sector” for evidence-based policymaking. Moniepoint launched “M” AI chatbot to make informal economy data actionable for policymakers.Academic/Gov’t-linked studies citedResearch on “AI-Driven VAT Gap Closure for Nigeria’s Digital & Informal Economy” notes AI can detect evasion patterns + informal businesses’ willingness to register jumps 24.6% to 56.3% with AI-enabled simplified systems. HAL study 2025 proposes AI-enhanced occupational health surveillance for informal workers in Lagos/Enugu/Kano.technext24.comtechcabal.com

10. H4.10

    African language NLP coverage

    Score 4 / 4

    3–7, depending on “meaningful”Nigeria has 500+ languages. But NLP/LLM support is still low-resource. Here’s the breakdown as of Sept 2025:1. Languages with “meaningful” LLM/NLP support – production-ready These have trained LLMs, datasets, ASR, and real applications:LanguageSupport levelEvidenceHausaHighIn N-ATLAS v1 LLM + ASR. NaijaNLP survey: most research done here. Datasets, MT, sentiment, NER exist. Spoken by 63M+YorùbáHighIn N-ATLAS v1 LLM + ASR. NaijaNLP: 2nd most studied. Diacritics, MT, ASR datasets exist. 47M+ speakersIgboHighIn N-ATLAS v1 LLM + ASR. NaijaNLP: 3rd most studied. Datasets for summarization, sentiment, NER exist. 33M+ speakersNigerian PidginMedium-HighIn Awarri’s LLM. NaijaNLP counts it as one of 4 main studied languages. NaijaSenti, NaijaNER datasets exist. 60M+ speakersGov’t model N-ATLAS v1: Officially supports Yoruba, Hausa, Igbo + Nigerian-accented English with ASR + LLM. Launched Sept 2025 by FMCIDE/NITDA/Awarri.2. Languages with emerging/early support – research stage These have datasets + benchmarks but LLMs still perform poorly:LanguageSupport levelEvidenceIbibioEmergingIn Awarri LLM + “Ibom NLP” dataset 2025. 10M+ speakers. But LLMs perform poorly in zero/few-shot MTEfik, Anaang, OroEmerging“Ibom NLP” dataset 2025 for MT + topic classification. First parallel data for Anaang/Oro. Not in Google Translate/Flores-200 yetTivTargetedListed by Minister Tijani as one of 5 languages targeted for Nigeria’s LLM. Data collection ongoing3. The reality check “Meaningful” = 3 major languages + Pidgin: NaijaNLP survey 2025: 500+ languages, but Hausa/Yorùbá/Igbo account for 60% of speakers and >75% of NLP research. Only 25.1% of studies create new resources; most repurpose data.<1% of 500+ languages have datasets: Research says NLP has focused on Hausa, Igbo, Pidgin, Yoruba = <1% of languages spoken.Gov’t target: Minister Bosun Tijani said Nigeria’s LLM “covering about five of our languages” starting with Yoruba, Hausa, Igbo, Tiv + others. N-ATLAS v1 shipped with 3 + Pidgin + accented English.

    Scoring basis Threshold applied. Raw value: 4 of 4 (languages supported / major languages), normalised 100. 100% of major domestic languages.

Mean of the 9 scored indicators; 1 carries no score. West Africa mean 1.04 · all 54 states mean 1.05.

No score: 1 not scored (excluded from the mean).

1. N5.1

   AI companies count

   Score 3 / 4

   Number of AI companies operating in Nigeria: ∼120–300+ depending on how you countThere’s no single CAC “AI company register”, so estimates vary by source and definition:1. Most cited counts for 2025/2026SourceCountScope/NotesAI Outlook 2026 by AI CoLab Africa + AI in Nigeria122 operational AI startupsSurveyed 504 professionals. “Active startups” across healthtech, fintech, agritech, language tech. Heavily Lagos-based, with clusters in Abuja + other statesPM News / Leadership.ng120+ AI startupsSame AI Outlook 2026 report. Says ecosystem “grown to over 120 active startups”BusinessDay NG300 AI startups“Over 300 Nigerian AI startups train models abroad due to infrastructure gap”. This likely includes early-stage + solo builders, not just incorporated startups.TechCabal Africa AI Landscape 202550 AI startups trackedHarvard Dataverse dataset. Nigeria leads Africa with 50 tracked AI startups, up +24 since 2022. This is a curated list of visible/funded companies, not total.ReadyContacts database111 AI companiesCommercial database updated March 2026. Includes registered firms using AI/ML.leadership.ngleadership.ngpmnewsnigeria.combusinessday.nginsights.techcabal.comreadycontacts.com2. “Registered vs Operating” distinction Registered: CAC doesn’t tag “AI” as a sector. ReadyContacts lists 111 companies self-describing as AI/ML. TechCabal tracks 50 visible startups. These are incorporated entities.Operating/active: AI Outlook 2026 counts 122 active startups building AI products, many unincorporated or very early. BusinessDay’s 300+ includes solo devs/teams training models abroad.3. Sector breakdown of Nigerian AI companies TechCabal 2025 shows Nigeria leads Africa in: Healthcare 7, Software Development 10, Finance 6, Legal AI 3. AI Outlook 2026 lists leading ones: Awarri, CDIAL AI, Ubenwa Health, BetaLife Health, Terra Industries. techcabal.compmnewsnigeria.com

   Scoring basis Threshold applied. Raw value: 122 (companies).

2. N5.2

   Private AI investment (USD)

   Score 3 / 4

   Private VC to Nigerian AI startups: ∼$30M-$50M/year average 2019-2024, with 2025 likely $80M-$120M based on deal flow. Broader private AI investment including corporate adoption, surveillance procurement, cloud/credits: $400M-$500M/year projection.

   Scoring basis Threshold applied. Raw value: 40000000 (USD/year).

3. N5.3

   AI incubators/accelerators

   Score 3 / 4

   Dedicated AI accelerators/incubators: 8–10 running active cohorts as of 2025/2026: Google Africa, Meta Llama, AI Ventures, AI Scaling Hub, DSN AI Hub, AI Hub Ogba, plus Google AI First. Broader ecosystem: 20+ hubs like CcHUB, Wennovation, AIF that run AI tracks but aren’t AI-only.Most activity is Lagos/Abuja-based. Google’s accelerator alone has supported 106 startups across 17 African countries since 2018, with Nigeria getting the most slots.

   Scoring basis Threshold applied. Raw value: 9 (incubators/accelerators).

4. N5.4

   Regulatory sandbox (AI)

   Score 2 / 4

   The National Regulatory Sandbox TWG was inaugurated May 21, 2026. AI startups can already apply to NITDA/ONDI for supervised testing. Full legal backing will come when the National AI Act/Digital Economy Bill passes – expected 2026.

5. N5.5

   Government AI procurement

   Score 3 / 4

   Yes, but mostly via grants, pilot projects, and “Nigerian Content” rules, not large-scale commercial procurement yet.1. Policy framework: Local content is mandatory for gov’t IT/AI procurement NITDA Guidelines: NITDA’s “Guidelines for Registration of ICT Service Providers” + Executive Orders 003 & 005 mandate that MDAs must give preference to indigenous IT companies and “made-in-Nigeria” products/services in procurement. Cloud/data procurement must prioritize local content and indigenous CSPs Cloud policy: NITDA National Cloud Technical Document says “Procurement must prioritize local content and indigenous CSPs in line with Guidelines for Nigerian Content Development in ICT” Rationale: Govt says this is to deepen professionalism, ensure quality IT projects, and avoid N13bn+ spent on foreign software. 2018 recorded highest purchase of indigenously-assembled hardware/software.2. Actual procurement/examples of gov’t using domestic AIExampleWhat happenedDomestic developer roleN-ATLAS LLMFG launched Nigeria’s first gov’t-backed multilingual LLM Sept 2025Built by Awarri, a Nigerian startup, in partnership with NITDA/NCAIR. 500 fellows from gov’t 3MTT program used as data collectorsUniccon “Omeife” robotNITDA signed MoU with Uniccon GroupGovt plans to integrate Omeife humanoid robot into NITDA LMS for digital literacy in Pidgin, Hausa, Igbo, Yoruba. Explicit MoU to “commercialise Omeife”NCAIR AI Research Scheme NAIRSUp to ₦5M grants to 45 research teams/startupsFocus: agriculture, healthcare, education, finance. Designed to turn ideas into “market-ready solutions” for gov’t useNITDA-Google AI Fund ₦100M10 Nigerian AI startups got ₦10M each + $3.5M Google Cloud creditsStartups like BetaLife Health, CDIAL AI, Farmspeak selected to build gov’t-relevant AI for health, agriculture, language techGovGuideNigeria AI platformAI chatbot to simplify access to gov’t servicesLaunched 2026, processed locally to comply with Nigeria Data Protection Act. Uses local dev talent from 3MTT pipelinePublica AI + cBrainF2 digital gov’t platform rollout across MDAsPublica AI is Nigerian partner handling implementation + adapting platform to Nigeria’s regulatory requirements. Data hosted in Nigeria3. Large contracts still go foreign AI surveillance $470M: Nigeria’s AI-powered facial recognition + ANPR systems are mostly supplied by Chinese firms via soft loans. Report notes “most surveillance infrastructure deployed was supplied by Chinese firms” F2 platform: Core F2 case management/AI platform is Danish cBrain, with Publica AI as local implementer. Gov’t target: digitize 75% of public services by 2027.

6. N5.6

   AI safety evaluation capacity

   Score 2 / 4

   Nigeria has 1 dedicated AI safety evaluation lab – CBR Trustworthy AI Lab in Ibadan using Z-Inspection® for ethics/trustworthiness. NCAIR Abuja provides infrastructure for startups to test prototypes, but not formal safety certification. No: No national AI red-teaming lab, no model safety benchmark facility, no “AI Safety Institute” equivalent yet. TETFund plans 6 new AI/Robotics CoEs which could fill gap, but they’re still in selection phase.

7. N5.7

   ISO/IEC 42001 adoption

   Score 2 / 4

   Adoption level: “Emerging, strategic”. Nigeria isn’t mandating ISO/IEC 42001 yet, but:Available: SGS Nigeria and other certifiers can audit/certify orgs now.Used: At least some Nigerian fintechs/startups are implementing it voluntarily for investor trust + export readiness.Supported: Training for lead auditors exists in Lagos. Not nationalized: SON hasn’t adopted it as NIS yet, and gov’t procurement doesn’t require it.

8. N5.8

   Standards body AI competency

   Score 3 / 4

   No standalone SON Technical Committee for AI exists yet. Nigeria contributes to AI standardization through SON’s participation in ISO/IEC JTC 1, and specifically SC 42 on Artificial Intelligence. If/when SON sets up a domestic mirror of SC 42, that would become Nigeria’s AI-specific technical committee.SON mirrors 23 IEC technical committees and participates in JTC 1 SCs. For AI, the work is currently routed through JTC 1 and its subcommittees rather than a standalone SON/TC.If SON creates a “SON/TC 1XX: Artificial Intelligence” mirroring ISO/IEC JTC 1/SC 42, that would be the formal AI committee. As of May 2026, that hasn’t been announced.

9. N5.9

   AI risk assessment frameworks

   ○Not scored: Excluded from the pillar mean

   SectorFramework in useStatusHealthcareSPEC-AI trial risk review + Independent audit EHI + CBR Trustworthy AI Lab Z-InspectionResearch/audit tools, not regulator-mandatedFinance/FintechCBN AML AI standards: model validation + explainability + annual auditsRegulatory requirement since 2026All sectorsNAIS draft to NIST AI RMF; NEAIF ethical layer; UNESCO RAM bias auditsPolicy guidance, voluntaryGov’t procurementNo formal AI risk assessment mandate yetDraft bill proposes impact assessments for high-risk AISo: Fintech has the only mandatory sectoral AI risk rules now via CBN. Healthcare has research audits but no regulator framework. Most sectors rely on NAIS/NIST RMF + NEAIF as voluntary guidance until the AI Act passes.

   Scoring basis Not determined; excluded from the pillar mean.

10. N5.10

    University-industry AI partnerships

    Score 4 / 4

    Partnerships are moving from MoUs to labs to deployable systems. UNILAG, UI, OAU, Wigwe Uni are the most active nodes. Industry brings funding/cloud/tools, universities bring talent/data, NITDA/UNDP provide infrastructure.

Mean of all 10 indicator scores. West Africa mean 1.21 · all 54 states mean 1.26.

1. E6.1

   Algorithmic impact assessment

   Score 3 / 4

   While a comprehensive, stand-alone Artificial Intelligence (AI) Act with mandatory Algorithmic Impact Assessments (AIAs) is in the legislative pipeline, it is not yet fully enacted law.

   Sources globallawexperts.com (opens in a new tab)

2. E6.2

   Bias audit requirements

   Score 4 / 4

   While a dedicated, overarching AI law is still pending legislative passage in Nigeria, AI bias audits for high-risk systems are not universally legally mandated but are rapidly becoming enforced best practices. However, three basic rukes make it mandatory(1) Nigeria Data Protection Act NDPA 2023 requires bia audit (2) NITDA Nigeria AI Ethic Code 2024 requires AI Audit (3)Sectoral specific such as CBN credit scoring of AI and NCC.

3. E6.3

   Transparency obligations

   Score 4 / 4

   There is no single transparency Act , yet three framewrok makes it mandatory including NDPA 2023 Nigeria Data Protection ACT,NITDA Nigeria AI Ethics Code 2024 and sectoral regulators.

4. E6.4

   Citizen redress mechanism

   Score 4 / 4

   Two laws give power to challenge AI driven decision includes;91) Nigeria Data Protection Act NDPA 2023 which include right to object, right to explanation, right to human review, and right to redress. How to challenge: file complaint with NDPC within 6 months. NDPC investigate and order correction. While CBN handles banking related AI complaint for sector specific situation, and NAFDAC for healthcare,and FOI, Public Complaint Commission for attend to government service related AI complaint

5. E6.5

   Judicial AI remedy

   Score 3 / 4

   No AI court yet but extant court have jurisdiction such as NDPA 2023 section 69 gives federal high court exclusive jurisdiction over NDPC cases.Which court handles itType of AI disputeCourt with jurisdictionData privacy/breach by AIFederal High Court. NDPA 2023 Section 69 gives it exclusive jurisdiction over NDPC casesConsumer harm, fraud, biasFederal High Court + State High Courts. FCCPC Act + Consumer Protection Act applyContract, IP, liabilityFederal/State High Court, depending on parties + amountHuman rights violation by AIFederal High Court. Fundamental Rights Enforcement Procedure Rules 2009Labour/employment AINational Industrial Court. If AI is used for hiring/firingSo yes, courts can hear it. Judges apply existing law to AI facts.2. What laws judges use today Nigeria has no “AI Liability Act” yet. But courts use these:NDPA 2023: Section 34-35 gives citizens right to challenge automated decisions. Section 69 lets court award damages for unlawful AI processing.Cybercrimes Act 2015: Covers AI used for fraud, deepfakes, cyberstalking.Constitution 1999: Section 37 right to privacy, Section 33-34 right to life/dignity. Can be used if AI causes harm.Common law negligence: If an AI system causes physical/financial damage, court can hold developer/user liable like any faulty product.NITDA Nigeria AI Ethics Code 2024 isn’t law, but courts can use it as “best practice” to decide if conduct was negligent.3. Real cases & signals NDPC enforcement 2024-2025: Nigeria Data Protection Commission has fined companies for unlawful AI profiling. Appeals go to Federal High Court, so judges are already interpreting NDPA on AI.FCCPC vs Meta/WhatsApp 2024: ₦220B fine involved algorithmic data sharing. FCCPC used existing competition/consumer law to challenge AI-driven data practices.Judicial training: National Judicial Institute NJI has been training judges on “tech law + AI” since 2023. Courts are preparing for more AI cases.4. Challenges courts face now Technical evidence: Judges rely on expert witnesses to explain how the AI worked, bias, training data.Liability question: Is it the developer, deployer, or user who’s liable? Court applies NDPA + negligence tests case-by-case.No AI Act yet: Draft National AI Commission Bill 2025 will give clearer rules. Until then, judges use NDPA + general law.

6. E6.6

   AI advisory body diversity

   Score 4 / 4

   NAIS 2024 strategy: NITDA says inclusivity is “core”. The roadmap mandates that at least 40% of programmes directly benefit women and underserved groups. That same Gender Inclusion Strategy guides training + capacity building.AI Ethics Expert Group AIEEG: NAIS plans a “well-respected and diverse AI Ethics Expert Group” to advise on ethics. “Diverse” is stated, but the exact male/female split hasn’t been published.Push from civil society: Groups like CITAD are actively calling for more gender justice in AI policy. NITDA DG Kashifu Inuwa also highlights women-in-AI programs as proof of intent.

7. E6.7

   Global AI governance participation

   Score 2 / 4

   Forum: GPAI Nigeria’s role: Observer/ParticipantWhat they push African data: language diversity, capacity building. FORUM: UN/UNESCO/ITUActive participantHuman rights, ethics, multilingual AI, digital divide.Forum: OECD: Non-member, but references principlesAdapts OECD AI Principles to Nigeria context

8. E6.8

   Civil society AI engagement

   Score 4 / 4

   1. Formal mechanisms written into policyMechanismHow CSOs participateLegal/Policy basisNAIS 2024 co-creation workshops120 stakeholders from civil society helped draft the National AI Strategy. NITDA used “human-centred design” + public consultations.National AI Strategy 2024 documentAI Ethics Expert Group AIEEGNAIS mandates a “diverse AI Ethics Expert Group” to give independent advice on AI ethics. Civil society/academia are expected seats. Not fully constituted/published yet.NAIS 2024 Objective 4.1NITDA Governing BoardBoard includes reps from civil society via: 1) Standards Org of Nigeria 2) Computer Professionals Council affiliates 3) 6 IT experts from geo-political zones appointed by President. CSOs can be nominated as “experts”.NITDA Act Section 2(2)(e)Public consultations by NITDA/NDPCNITDA runs stakeholder workshops for draft guidelines, Ethics Code, AI Act. NDPC does public calls for input on NDPA regulations. CSOs submit memos.Standard NITDA/NDPC regulatory practice2. Semi-formal / ongoing channels Multi-stakeholder committees: Example: Nigeria Startup Act Labelling Committee has 2 “Civil Society” reps out of 9 members. Same model is being copied for AI governance bodies.Partnerships with NITDA: NITDA DG Kashifu Inuwa publicly invites CSOs like NIWIT, CITAD to “tap into open-door policy” + sign MoUs for training/mentorship programs.Sector forums: NCAIR + NITDA host events like “Innovate Her”, “AI for Women” where health, media, development CSOs participate

9. E6.9

   African ethical framework reference

   Score 3 / 4

   Nigeria’s AI governance documents explicitly reference African ethical principles, including Ubuntu and decoloniality.It’s one of the ways NAIS 2024 tries to avoid just copy-pasting EU/US rules. Here’s where:1. National AI Strategy NAIS 2024 The strategy has a whole section on ethics. 2 African principles are named directly:PrincipleWhat NAIS saysWhy it mattersDecolonialityListed as a core ethical principle. Goal: Build AI that reflects Nigeria/Africa’s realities, not just “imported datasets + models”.Pushes for indigenous datasets, Hausa/Yoruba/Igbo LLMs, and avoiding bias from Western training data.HumanityListed alongside fairness, safety, transparency. “Humanity” in NAIS is interpreted to include African values of community + dignity.Contrasts with pure “individual rights” focus. Emphasizes collective wellbeing.InclusionMandates 40% of initiatives support women + underserved groups. Also calls for AI that works for Nigeria’s 500+ languages.Direct response to African context: rural/urban divide, gender gap, language diversity.NITDA DG Kashifu Inuwa stressed “developing indigenous datasets and LLMs that reflect Nigeria’s diverse realities” as an ethical priority.2. Nigeria AI Ethics Code 2024 The 7 principles mirror UNESCO’s but are adapted:Humanity - includes respect for African communal values, not just Western individualismNon-discrimination - specifically mentions ethnicity, language, religion, region in Nigeria Inclusion & diversity - tied to Africa’s demographics + Global South needsThe Code was drafted to align with UNESCO Recommendation on Ethics of AI, but NITDA added “decoloniality” language to make it Afro-centric.3. Ubuntu specifically? “Ubuntu” isn’t named word-for-word in the public NAIS 2024 PDF. But:“Humanity” principle in NAIS is interpreted by NITDA officials as capturing Ubuntu values - “I am because we are”. Minister Bosun Tijani talks about “AI for collective prosperity” not just individual gain.AU Continental AI Strategy: Nigeria was a lead drafter. The AU strategy explicitly cites Ubuntu + other African philosophies. Since NAIS aligns with the AU strategy, Ubuntu is indirectly referenced.Civil society push: Groups like CITAD are lobbying to make Ubuntu, communal ethics, and religious perspectives more explicit in the final AI Act.

10. E6.10

    Youth participation

    Score 4 / 4

    Yes - Nigeria has several formal mechanisms for youth participation in AI governance, and youth are actually a core pillar of NAIS 2024.NAIS literally sets a target: 70% of Nigerian youth AI-skilled by 2030. So youth participation isn’t just “consultation” - it’s built into the strategy.1. Formal mechanisms written into policyMechanismHow youth participateBasisNAIS 2024 Skills PillarStrategy mandates massive youth upskilling. NITDA runs “Digital Literacy for All” + AI training through NYSC, schools, and NCAIR. Youth are trainees to then trainers/multipliers.NAIS 2024 Objective 2NCAIR - National Centre for AI & RoboticsNCAIR runs AI/ robotics bootcamps, hackathons, startup programs specifically for youth 18-35. It’s the main youth entry point into AI policy.NITDA Act + NAIS implementationNYSC IntegrationDigital literacy + AI modules are being integrated into NYSC curriculum. 30M+ Nigerians expected to benefit, with youth as first cohort.NAIS 2024 + NITDA-NYSC MoUYouth representation in committeesStartup Act Labelling Committee + other NITDA multi-stakeholder bodies include “incubators + startups” seats. Since 60%+ of Nigerian startups are youth-led, this is de facto youth representation.Nigeria Startup Act + NITDA practicePublic consultationsNITDA opens all draft policies - Ethics Code, AI Act - for public memo submissions. Youth orgs like I4G, Google Developer Groups, tech hubs submit inputs.Standard NITDA regulatory process2. Semi-formal / youth-led channels “AI for Women + Youth” programs: NCAIR Director Dr. Olubunmi Ajala runs “AI for Women” training that includes female youth. 200+ women from health, media, public service sectors trained in Abuja.University/ABU IIOE partnership: IIOE project targets 4,500 participants by 2027, min 1,500 women. Focus is youth in higher education becoming AI leaders, not just users.Tech hubs + developer groups: NITDA partners with Andela, Co-Creation Hub CcHub, GDG, I4G to train youth. These hubs often aggregate youth feedback for policy.Pan-African AI Leadership Summit Sept 2025: NITDA announced it will bring youth/students into the dialogue on Africa’s unified AI agenda.3. What youth are actually influencing Skills + curriculum: Youth feedback shaped NAIS focus on practical AI skills vs theory. Dr. Success Ojo + Dr. Yusuf Ibrahim from ABU presented on “Digital skills for next gen women leaders” + “AI in teaching” at IIOE events.Language/Localization: Youth developers pushed for Hausa, Yoruba, accented-English AI models. NITDA confirmed a multilingual model exists now.Ethics + bias: Young CSOs flag that Western AI datasets don’t reflect Nigerian youth realities - slang, culture, fashion. NAIS “decoloniality” principle came from that pressure.

Mean of all 10 indicator scores. West Africa mean 1.66 · all 54 states mean 1.55.

1. R7.1

   AU AI Strategy alignment

   Score 4 / 4

   Yes - Nigeria has several formal mechanisms for youth participation in AI governance, and youth are actually a core pillar of NAIS 2024.NAIS literally sets a target: 70% of Nigerian youth AI-skilled by 2030. So youth participation isn’t just “consultation” - it’s built into the strategy.1. Formal mechanisms written into policyMechanismHow youth participateBasisNAIS 2024 Skills PillarStrategy mandates massive youth upskilling. NITDA runs “Digital Literacy for All” + AI training through NYSC, schools, and NCAIR. Youth are trainees to then trainers/multipliers.NAIS 2024 Objective 2NCAIR - National Centre for AI & RoboticsNCAIR runs AI/ robotics bootcamps, hackathons, startup programs specifically for youth 18-35. It’s the main youth entry point into AI policy.NITDA Act + NAIS implementationNYSC IntegrationDigital literacy + AI modules are being integrated into NYSC curriculum. 30M+ Nigerians expected to benefit, with youth as first cohort.NAIS 2024 + NITDA-NYSC MoUYouth representation in committeesStartup Act Labelling Committee + other NITDA multi-stakeholder bodies include “incubators + startups” seats. Since 60%+ of Nigerian startups are youth-led, this is de facto youth representation.Nigeria Startup Act + NITDA practicePublic consultationsNITDA opens all draft policies - Ethics Code, AI Act - for public memo submissions. Youth orgs like I4G, Google Developer Groups, tech hubs submit inputs.Standard NITDA regulatory process2. Semi-formal / youth-led channels “AI for Women + Youth” programs: NCAIR Director Dr. Olubunmi Ajala runs “AI for Women” training that includes female youth. 200+ women from health, media, public service sectors trained in Abuja.University/ABU IIOE partnership: IIOE project targets 4,500 participants by 2027, min 1,500 women. Focus is youth in higher education becoming AI leaders, not just users.Tech hubs + developer groups: NITDA partners with Andela, Co-Creation Hub CcHub, GDG, I4G to train youth. These hubs often aggregate youth feedback for policy.Pan-African AI Leadership Summit Sept 2025: NITDA announced it will bring youth/students into the dialogue on Africa’s unified AI agenda.3. What youth are actually influencing Skills + curriculum: Youth feedback shaped NAIS focus on practical AI skills vs theory. Dr. Success Ojo + Dr. Yusuf Ibrahim from ABU presented on “Digital skills for next gen women leaders” + “AI in teaching” at IIOE events.Language/Localization: Youth developers pushed for Hausa, Yoruba, accented-English AI models. NITDA confirmed a multilingual model exists now.Ethics + bias: Young CSOs flag that Western AI datasets don’t reflect Nigerian youth realities - slang, culture, fashion. NAIS “decoloniality” principle came from that pressure.

2. R7.2

   Kigali Declaration endorsement

   Score 3 / 4

   es - Nigeria endorsed the Kigali Declaration on AI.But there are 2 different “Kigali Declarations”, so let’s clarify:1. Kigali Declaration on AI / Africa Declaration on AI - April 2025Status: Nigeria signed/endorsed This is the main AI one. At the Global AI Summit on Africa in Kigali, Rwanda on April 4, 2025, Nigeria was one of 54 signatories to the Africa Declaration on Artificial Intelligence. wcrp-climate.orgEvidence:Signatory list: Nigeria is listed among 54 countries that signed: “Nigeria” appears in the official signatories table.Minister present: Minister Bosun Tijani represented Nigeria at the launch and stressed “inclusive, ethical AI systems that reflect Africa’s values”.What it commits to: Data sovereignty, building digital infrastructure, harmonizing national strategies with AU Continental AI Strategy, $60B Africa AI Fund, creation of Africa AI Council.

   Scoring basis Official signatory list applied. Signatory of the Africa Declaration on AI (Kigali, 4 April 2025), C4IR list: "Endorsed" = 3.

   Sources c4ir.rw (opens in a new tab)

3. R7.3

   REC AI governance coordination

   Score 3 / 4

   Yes - Nigeria is actively participating in ECOWAS-level AI governance coordination. ECOWAS is Nigeria’s REC, and Nigeria is one of the drivers of the regional AI process.1. Formal participation mechanisms in ECOWASMechanismNigeria’s roleWhat’s happeningECOWAS Digital Economy Working GroupsNigeria is a lead member. Minister Bosun Tijani + NITDA reps attend ECOWAS ICT/Communications Ministerial meetings.The June 11-13, 2024 AU Specialized Technical Committee meeting had 100+ African ministers including Nigeria charting digital transformation + AI for the region.Harmonization of AI policyNigeria’s NAIS 2024 was designed to align with AU strategy, which ECOWAS is domesticating regionally. Goal: interoperable AI rules across West Africa.NAIS 2024 includes “intergovernmental cooperation + cross-border data flows” as a principle from the Kigali Declaration.ECOWAS AI capacity programsNCAIR + NITDA partner with ECOWAS Commission on training. Nigeria’s multilingual AI model for Hausa/Yoruba is relevant to ECOWAS francophone + anglophone states.NCAIR runs programs that ECOWAS members are invited to.Data protection alignmentNDPC Nigeria coordinates with ECOWAS on data governance. ECOWAS Supplementary Act on Personal Data Protection 2010 is the baseline. NDPA 2023 aligns with it.Makes cross-border AI data flows legal within ECOWAS.2. What Nigeria is pushing at REC level Regional data infrastructure: Nigeria advocates for shared West African compute + data centers instead of each country building small ones. Aligns with ECOWAS “digital single market” vision.Language diversity: Nigeria leads on African language LLMs. ECOWAS has 15 countries with 250+ languages. Nigeria’s Hausa/Yoruba model is a pilot for ECOWAS-wide multilingual AI.Ethics + decoloniality: Nigeria inserted “Decoloniality” into NAIS. It’s pushing ECOWAS to adopt Afro-centric ethics vs just copying EU AI Act.

4. R7.4

   Cross-border AI agreements

   Score 4 / 4

   Yes - Nigeria has both bilateral + multilateral AI governance cooperation agreements. Most are new, post-NAIS 2024.Here’s the landscape as of 2026:1. Multilateral agreements Nigeria signedAgreement/ForumStatusWhat Nigeria committed toAfrica Declaration on AI - Kigali DeclarationSigned April 4, 2025Data sovereignty, harmonize NAIS with AU strategy, $60B Africa AI Fund, join Africa AI Council. 54 countries signed.AU Continental AI Strategy 2024Co-drafter + adopterAlign NAIS pillars with AU: Research, Infrastructure, Data, Governance, Capacity. Nigeria reports progress to AUDA-NEPAD yearly.UNESCO Recommendation on Ethics of AIAligned via Ethics Code 2024Nigeria AI Ethics Code 2024 mirrors UNESCO’s 10 principles. NITDA uses it for audits.Bletchley Declaration - UK AI Safety SummitSigned Nov 2023Cooperate on frontier AI safety testing + risk research. Nigeria was one of 25+ countries.GPAI - Global Partnership on AIParticipant/ObserverShare best practices, ethics, data governance. NITDA/NCAIR attend working groups.UN Global Digital Compact 2024ParticipantPush for “inclusive AI for Global South” + differentiated responsibilities for developing countries.2. Bilateral agreementsCountry/OrgAgreementFocusStatusUnited StatesJoint Statement with US Dept of Commerce 2023AI + digital upskilling + privacy interoperability. Promote cooperation on AI policy + rules. Non-binding but sets cooperation framework.ActiveUKBletchley Declaration + ongoing tech partnershipFrontier AI safety, testing, research. Minister Tijani said UK is “long-standing ally” for AI capacity.ActiveRwanda/Smart AfricaKigali Declaration + Smart AfricaAfrica AI Council, cross-border data flows, shared infrastructure. Nigeria + Rwanda co-lead.ActiveChina/Tech firmsPartnerships via NITDAInfrastructure, cloud, model training. No public “AI governance treaty” but MoUs on tech transfer exist.OngoingUNDP/UNESCO/ITUMoUs for capacity buildingAI ethics training, multilingual models, digital literacy for 70% Nigerians by 2027.Active3. Key cooperation themes Nigeria pushes in all agreements Data sovereignty: “African data for African AI” - must be in every deal. Capacity building: Youth upskilling, NCAIR training, 70% digital literacy target.Language diversity: Multilingual AI for Hausa/Yoruba/Igbo + other African languages.Decoloniality: Agreements must allow Nigeria to build indigenous datasets/models, not just import Western ones.Interoperability: Make Nigeria’s NDPA 2023 + future AI Act compatible with ECOWAS, AU, OECD standards.

5. R7.5

   Election integrity AI provisions

   Score 4 / 4

   Yes - Nigeria has legal + institutional provisions that address AI in elections, but no standalone “AI in Elections Act” yet. Rules come from 4 sources:1. Legal provisions that cover AI useLaw/RuleHow it covers AIEnforcementElectoral Act 2022Bans false info, voter intimidation, undue influence. Section 127-128 criminalizes false political ads. Can be applied to AI deepfakes, chatbots, micro-targeting.INEC + Police + CourtsCybercrimes Act 2015Covers AI used for disinformation, deepfakes, impersonation, voter suppression online. Section 24 = cyberstalking/spreading false info.NCC + Police + CourtsNDPA 2023AI used for voter profiling/micro-targeting must have consent + lawful basis. Section 34 gives right to challenge automated decisions. Section 69 = Federal High Court jurisdiction.NDPC can fine + Federal High CourtConstitution 1999Section 39 Freedom of expression, Section 22 Press freedom. Limits how govt can ban AI content. But Section 45 allows restrictions for public order.CourtsDraft AI Act 2025Expected to create “high-risk AI” rules. Election-related AI likely to be classed as high-risk = extra transparency + human oversight requirements.Future AI Commission2. Institutional mechanisms INEC - Independent National Electoral Commission Code of Conduct for Political Parties: Bans false/misleading campaigns. INEC says it applies to “AI-generated content”.Fact-checking desk: INEC partners with CDD, Dubawa, AFP to flag deepfakes + AI misinformation during elections. Used in 2023 polls.BVAS + IReV: AI isn’t used to count votes, but INEC uses tech to protect results. Focus is on preventing AI-manipulated results.NDPC - Nigeria Data Protection Commission Political parties using AI for voter data must register + comply with NDPA. NDPC issued warnings in 2023 elections about unauthorized voter databases.NITDA Nigeria AI Ethics Code 2024 + NAIS 2024 list “non-discrimination + transparency” as principles. NITDA can issue advisories if AI systems show bias against regions/genders during elections.NCC + NBC Monitor telecoms/broadcast. Can sanction stations that air AI deepfakes without disclaimer. NBC Code says political content must be identifiable.3. What’s actually happening on the ground 2023 elections: First major test. INEC + fact-checkers flagged AI voice clones of politicians + WhatsApp chatbot disinfo. No prosecutions yet, but Cybercrimes Act warnings were issued.Deepfake policy: INEC position = “AI-generated candidate voice/video = illegal if not disclosed”. Treated as false info under Electoral Act Section 128.Micro-targeting: Parties using AI to profile voters must get NDPC compliance. NDPC says “political opinion” is sensitive data = needs explicit consent.

6. R7.6

   Disinformation response framework

   Score 2 / 4

   Nigeria doesn’t have one “AI Disinformation Law” yet. Instead it uses a 4-layer framework: Law + Institutions + Industry codes + Tech. Built for elections + general disinfo.1. Legal layer - what laws cover AI disinfoLawWhat it targetsPenaltyCybercrimes Act 2015, Sec 24“False messages for purpose of causing annoyance, inconvenience, danger, obstruction” online. Covers AI deepfakes, voice clones, chatbot lies.Up to ₦10M fine + 3 years jailElectoral Act 2022, Sec 127-128False info about candidates, results, polling units during elections. Applies to AI-generated content.Fine + imprisonment + cancel resultNDPA 2023AI used to create/target disinfo must have lawful basis. If AI profiles people to spread lies = consent + data breach rules apply.NDPC fines up to 2% global turnoverCriminal Code + Penal CodeDefamation, impersonation, sedition if AI content causes public disorder.Varies by offenseTerrorism Prevention ActAI used to spread violent extremist content.20 years +

7. R7.7

   AI election incidents documented

   Score 3 / 4

   There’s no single official “number” yet. But fact-checkers documented dozens of AI-related incidents in Nigeria’s 2023 elections, with 4-6 high-profile deepfake/audio cases going viral.Here’s what’s documented so far:1. Documented 2023 election incidents by typeTypeDocumented casesExamplesAI audio deepfakes3 major ones verifiedAtiku Abubakar + Okowa + Tambuwal “rigging call” hours before voting 2. Peter Obi + Bishop Oyedepo “religious war” call, 10.3M views on X 3. Peter Obi “call to Oyedepo” flagged by fact-checkersAI video/image deepfakes5+ viral casesHollywood stars + Elon Musk + Donald Trump “endorsing Peter Obi” - doctored from Wired interviews 2. Tinubu “meeting Joe Biden” fake photo 3. Tinubu “watching Obi on plane” edited photo 4. Celebrity placards for Obi circulated widelyAI-generated fake docsMultipleManipulated result sheets showing pre-filled outcomes before voting ended. Fake court rulings attributed to judgesAI text/bot networksScale documented, not exact countFact-checkers found AI generating thousands of posts framing elections as “rigged/stolen”, mimicking activists/clerics. Bots/trolls pushing hashtags

   Scoring basis Threshold applied. Scored on documented institutional response, not incident count. Raw value read from the evidence: "INEC says it applies to “AI-generated content”" [incidents: "dozens" in 2023, 4-6 high-profile deepfakes; INEC fact-check desk (CDD, Dubawa, AFP) flagged deepf. Checked against the evidence on 7 October 2026: confirmed.

8. R7.8

   Platform content moderation

   Score 4 / 4

   Nigeria is actively engaging platforms on AI content moderation, and it’s framed around “domestic context” = Nigerian languages, culture, elections, religion. Lead agency is NITDA.Here’s how the engagement works:1. Legal mandate: NITDA Code of Practice 2022 This is Nigeria’s main lever. Since 2022, NITDA requires platforms with >5M Nigerian users to:RequirementWhy it matters for AI + domestic contextRegister + appoint local rep in NigeriaGives NITDA/NCC someone to call when AI disinfo spikes during elections. Meta, Google, X, TikTok, LinkedIn complied by 2023.24hr takedown for urgent contentApplies to AI deepfakes, election lies, incitement. “Prohibited content” includes false info that can cause harm.Complaint mechanism for NigeriansUsers can report AI fakes in local languages. Platforms must respond.Transparency reportsPlatforms must publish takedown data for Nigeria specifically, not just global numbers.Content moderation for NigeriaPlatforms must “respect Nigerian laws + culture” when moderating. Means Hausa/Yoruba/Igbo/Pidgin moderation, not just English.Code was co-signed with NCC + NBC. Non-compliance = fines + possible service ban.2. Key engagements 2023-2025 2023 Elections: NITDA + INEC + NCC held direct meetings with Meta, Google, X, TikTok. Focus: Flag AI deepfakes of candidates, slow viral spread on WhatsApp Status/IG Reels/TikTok. Platforms set up “Nigeria Election Response Teams”.AI Ethics Code 2024: NITDA told platforms: “AI systems operating in Nigeria must be transparent, non-deceptive, respect cultural diversity”. Pushback against Western bias in AI moderation tools.Kigali Declaration April 2025: Nigeria + 53 other African states signed. Commits platforms to “data sovereignty + ethical AI”. Minister Bosun Tijani used summit to press Meta/Google on African language moderation.Multilingual AI push: Nigeria’s NCAIR is building Hausa/Yoruba LLMs and sharing data with platforms. Goal: Force platforms to train moderation AI on Nigerian languages instead of relying on English-only models that miss Pidgin/Hausa slurs.Platform reps: Meta appointed a Nigeria Public Policy Manager. TikTok + X also named Nigeria leads after NITDA pressure. Monthly calls happen between NITDA and platform policy teams.

9. R7.9

   Geneva Dialogue participation

   Score 2 / 4

   Nigeria is expected to participate in the UN Global Dialogue on AI Governance on 6-7 July 2026 in Geneva.There’s no public “Nigeria will send X minister” announcement yet, but all signals point to planned participation:

10. R7.10

    G20/multilateral AI engagement

    Score 3 / 4

    Nigeria is actively engaging in G20, BRICS, and other multilateral AI initiatives. Strategy = “Global South + Africa voice” with 3 tracks.1. G20 Engagement - Active Status: Full participant at 2025 G20 Summit, pushing AI governance agendaNigeria attended the 2025 G20 Leaders’ Summit in Johannesburg, South Africa under theme “A Fair and Just Future for All: Critical Minerals, Decent Work, Artificial Intelligence”.What Nigeria did:President Tinubu/VP Shettima speech: Nigeria “backed the creation of global ethical standards for Artificial Intelligence, aimed at accelerating development across the world” Key positions pushed: AI must be “tool of empowerment, not exclusion; job creation, not displacement” “G20 must address systemic bias and foster sustained multilateral dialogue so benefits of AI are shared equitably” Link AI + critical minerals: “Value addition at source” for Africa, not just raw material supply People-centred AI: Tinubu stressed “as world advances through green and digital transitions, progress must remain people-centred” Nigeria isn’t a G20 member but was invited as guest/partner. Using the platform to shape Global South position on AI governance.2. BRICS Engagement - Active, moving toward deeper integration Status: Partner country + participating in BRICS AI mechanismsMechanismNigeria’s roleEvidenceBRICS Youth AI Education AllianceFounding memberNigeria joined launch in Beijing alongside China, Brazil, Russia. Goal: Youth AI literacy + teacher training + competitions across BRICSBRICS Forum on New Industrial Revolution 2026Ministerial participationMinister of State for Industry John Owan Enoh attended Xiamen forum. Said “global industrial systems are being driven by AI, digital technology and green innovation”BRICS Health MinistersAI in healthMinister Salako at BRICS meeting highlighted Nigeria “scaling digital health and artificial intelligence tools across the system”Standards + finance accessPartner voiceDaily Trust analysis: As BRICS partner, Nigeria already accesses forums/finance. Full membership would give more voice on AI standards + pooled procurement + compute investment for Hausa/Yoruba/IgboNigeria’s BRICS angle = “South-South AI cooperation” + access to models, compute, local language corpora. NITDA DG said Nigeria exploring “cloud of clouds” model similar to Europe’s GAIA-X.3. Other multilateral AI initiatives - Very activeInitiativeNigeria’s engagementUN Global Dialogue on AI Governance July 2026Prep underway via “Nigeria Forum for AI Governance”. UNESCO RAM report launched to feed into UN process. NITDA/NCS organizing delegationUNESCO RAM + AI EthicsNigeria among first African countries to launch UNESCO AI Readiness Assessment July 2024. Co-pushing “ethical, inclusive AI”GPAI - Global Partnership on AIParticipant. NCAIR engages working groups on ethics, data governanceUS-Nigeria Joint StatementBilateral but multilateral alignment: Cooperation on AI governance + NIST AI Safety Institute + NCAIR knowledge exchangeEU-Nigeria STI AgreementForthcoming Science, Tech & Innovation Agreement to formalize AI research partnerships. EU “Generative AI for Africa” call: wants Nigerian researchers leading projectsBletchley DeclarationSigned Nov 2023 on frontier AI safety. Nigeria one of 25+ countriesAfrica Declaration on AI/Kigali 202554-country multilateral. Nigeria signed, commits to Africa AI Council + data sovereignty4. Nigeria’s core multilateral positions Equity + anti-bias: “AI cannot become one more divide... Global South must be active participants, not only consumers” Data sovereignty + compute: “Africa 15-19% of world population but <0.6% of global compute” . Pushing “cloud of clouds” for Africa African languages: Using BRICS + EU partnerships to build corpora for Hausa, Yoruba, Igbo Decoloniality: NAIS adds this principle. Pushes it in all multilateral forums vs copying EU/US frameworksBottom line

Mean of the 9 scored indicators; 1 carries no score. West Africa mean 0.63 · all 54 states mean 0.78.

No score: 1 not scored (excluded from the mean).

1. M8.1

   AI governance budget disbursed

   Score 2 / 4

   Nigeria has strong AI policy + commitments, but “actual disbursed” vs “committed” gap is wide. No single line-item for “AI governance budget” yet. Funding is mostly seed grants + partner money, not federal budget.Here’s the breakdown from what’s public:1. Committed / Pledged fundingSourceAmount committedFor whatStatusNAIS Seed funding 2024$3.5M totalAI Collective for Growth, NCAIR, multilingual LLM pilot, data centre$1.5M direct + $2M from 21st Century Technologies for pilotGoogle.org$2.1M / N3BAI talent + digital safety via 5 local orgsPledged 2024, channeled through partnersGoogle to Data Science NigeriaN2.8B20,000 youths in AI/data science via 3MTT programGrant announcedNITDA AI Research Scheme₦225M45 research teams/startups, up to ₦5M eachDisbursed to teamsFG Digital Economy Research₦12B planned3 research clusters: AI, connectivity, digital skills across 6 universities eachAnnounced at ICEGOV 2024/2025, “putting together”Infrastructure partners$120M + $240MRack Centre + OADC data centresPrivate investment, not govt budget2. Actual disbursed - what we can verify $3.5M seed funding: Confirmed received by NAIS/“AI Collective for Growth” led by NITDA + Lagos Business School. Runs for 3 years. This is the only AI-governance-specific pool with disbursement confirmed.₦225M NITDA research grants: DG NITDA confirmed released to 45 Nigerians for AI research. Google N2.8B grant: Announced, awarded to Data Science Nigeria for 3MTT. Disbursement schedule not public, but program is running.Federal budget: No dedicated “AI governance” line. AI work sits under Federal Ministry of Communications, Innovation & Digital Economy budget. 2025 allocation: N463.57B for whole digital economy ministry2026 allocation: N84.56B - 81.7% cut from 2025 The 2026 cut signals “consolidation phase” after capital projects, but AI governance doesn’t have its own budget line to track disbursement.

   Scoring basis Threshold applied. Raw value: 1500000 (USD). Raw value read from the evidence: "$3.5M seed funding: Confirmed received by NAIS" [public share = "$1.5M direct" ($2M from 21st Century Technologies is private); NGN 225M NITDA grants also disb. Checked against the evidence on 7 October 2026: confirmed.

2. M8.2

   Health AI regulation

   Score 3 / 4

   No standalone “AI in Healthcare Act” yet. Nigeria regulates AI in health through 4 layers: NDPA + medical practice rules + NITDA ethics + draft AI Act. It’s “principles-based” right now, not product licensing.1. Where AI in healthcare is regulated todayRegulator/LawWhat it covers for AI in healthStatusNDPA 2023 + NDPCAI using patient data = “sensitive personal data”. Requires explicit consent, lawful basis, Data Protection Impact Assessment. Section 34 = right to contest automated decisions. Health data breach = higher fines.Active since June 2023MDCN - Medical & Dental Council“Code of Conduct for Medical Practitioners”: Doctor must remain liable for patient care. AI is a “tool”, not a practitioner. Telemedicine guidelines 2022 apply to AI chatbots/diagnosis apps.ActiveNITDA AI Ethics Code 2024AI systems must be “safe, transparent, accountable, non-discriminatory”. Human oversight required for high-risk use like diagnosis. Calls for “algorithmic audits” on health AI.Active, voluntary for nowNAFDACIf AI is in a medical device/software, NAFDAC’s “Guidelines on Registration of Medical Devices” apply. Class II/III software needs registration + clinical data. No AI-specific guidance yet.ActiveFederal Ministry of Health - NHIS/NHIADigital health strategy mentions AI for diagnostics + health records. Pushes “interoperability + data security” but no AI approval process yet.Policy, not regulation2. What exists specifically for AI in health Draft AI Act 2025: Expected to list “AI for medical diagnosis, triage, treatment” as “high-risk AI”. Will require: risk management, data quality, transparency, human oversight, conformity assessment. Not law yet.NCAIR - National Centre for AI & Robotics: Building Nigeria’s multilingual LLM + health use cases. Works with Ministry of Health on pilots, but pilots follow NDPA + MDCN rules.NAIS 2024: National AI Strategy lists healthcare as priority sector. Target = AI for diagnostics, drug discovery, health records. Says governance must “protect patient privacy + ensure clinical validation”.Health Facility Regulation: State health boards require any clinic using AI tools to have licensed doctor supervising. You can’t replace doctor with AI chatbot legally.

3. M8.3

   Health AI devices approved

   Score 1 / 4

   1 formally approved AI/robotic health device as of late 2025. NAFDAC doesn’t publish a separate “AI health tools” list yet.1. Confirmed NAFDAC approvalDevice/ToolTypeApproval dateDetailsToumai Robotic Surgical SystemRobotic surgery platform with AI-assisted arms + 3D visualizationNov 22, 2025Approved for clinical use at NISA Premier Hospital Abuja. First robotic surgery platform approved in West Africa. Manufacturer: Shanghai MicroPort MedBot. Used for nephrectomy + prostatectomy

   Scoring basis Threshold applied. Raw value: 1 (authorised devices).

4. M8.4

   Government AI system registry

   Score 0 / 4

   Nigeria does NOT have a live public registry of AI systems in use yet. But it’s planned. Right now gov’t is tracking AI use through sector registries, not a central “AI systems register”.

5. M8.5

   AI governance M&E reports

   Score 1 / 4

   2-3 published M&E-type reports on AI governance implementation in Nigeria so far. No regular annual M&E report series yet.1. Published reports you can countReportPublishedTypeCoverageUNESCO AI Readiness Assessment (RAM) Report2024/2025M&E baseline assessmentFirst comprehensive assessment of Nigeria’s preparedness to develop, deploy + regulate AI ethically. Covers governance, data, skills, infrastructure. Called a “roadmap for informed policy decisions”“Two Years of Nigeria’s National AI Strategy: A Compilation of Ecosystem Impact”April 2026Implementation progress reportDocuments progress 2024-2026: multilingual LLM, NCAIR, AI Collective, startups funded, NITDA AI Transformation Plan. Minister calls it “compilation of ecosystem impact” - closest to M&E report NAIS hasAMET Governance Report - “Toward AI Governance Alignment in Africa, Middle East, and Türkiye”Apr 2026Regional M&E analysisCo-authored by DSN founder Dr Olubayo Adekanmbi. Includes Nigeria case in Africa governance alignment. Not gov’t report but covers Nigeria implementation

   Scoring basis Threshold applied. Raw value: 1 (reports).

6. M8.6

   Agriculture AI governance

   Score 4 / 4

   AI governance provisions specific to agriculture in Nigeria: Still sector-light, but 3 layers exist. NAIS names agriculture as priority, NATIP gives tech policy backbone, and pilots have governance rules. No standalone “Agricultural AI Act” yet.1. NAIS 2024 - National AI Strategy provisions for agriculture Agriculture is one of 5 priority sectors for AI adoption. Specific provisions:PillarAgriculture-specific provisionPillar 3: Accelerating AI Adoption & Sector TransformationObjective 3.1: “Drive Locally-led AI Innovation” - calls for AI accessibility across agriculture. Strategy 3.1.2: “Launch sector-specific AI adoption roadmaps” including agriculture to give tailored guidance on integrating AIEthics + Governance PillarsNAIS applies general AI principles to agriculture: ethical, transparent, accountable, human oversight. NAIS proposes “National AI Ethics Commission + regulatory body” to oversee high-risk AI including crop prediction/disease detectionImplementationNAIS includes KPIs + timelines + responsible entities. Agriculture flagged for “lighthouse projects showcasing AI potential” e.g. smart irrigation, yield forecasting, crop disease monitoringNAIS itself doesn’t have agriculture-only rules - it sets framework, expects “sector-specific roadmaps” to fill details.2. NATIP 2022-2030 + NDAS - Agriculture sector policy backbonePolicyAI Governance provisionNational Agricultural Technology & Innovation Policy NATIPProvides “strategic policy backbone for transforming agriculture into tech-enabled, youth-driven sector and promotes mechanization, digital agriculture”. Minister says NATIP is basis for AI in agriculture but doesn’t set AI audit/ethics rulesNigerian Digital Agriculture Strategy NDASReferenced by Federal Ministry of Agriculture as “vital framework driving digital transformation”. Permanent Secretary cites AI for smart irrigation + yield forecasting. NDAS + NATIP = sector policy, but governance details are thinNAPM - National Agribusiness Policy Mechanism May 2025Coordinates implementation under Presidential Food Systems Unit. Focus on delivery targets for youth/women agribusiness, not AI complianceBottom line: NATIP/NDAS mandate AI use, but delegate governance to NAIS + NDPA + NITDA ethics code.3. Active governance provisions in pilots/projects These show how gov’t is handling AI governance on ground for ag:AI-enabled Digital Agricultural Extension System DAES - pilot 2025: Data governance: Stakeholders flagged “data ownership, privacy, use frameworks to protect farmers while enabling innovation” as central concern Inclusion: Design must account for literacy, language diversity, shared phone ownership, women/youth/land-poor farmers to avoid exclusion Human oversight: Consensus AI must “complement indigenous knowledge + existing extension systems rather than override them” Interoperability: Need gov’t dataset interoperability + voice/USSD interfaces for low-literacy farmers VP Shettima’s AI for food production: Deploys AI + geospatial analytics + satellite climate intelligence to “monitor production, enhance transparency, connect producers to markets, reduce waste”. Gov’t frames this under National Development Plan 2021-2025 + Nigeria Agenda 2050. No separate AI audit rule, falls under general NAIS principles.NBS + ARCN MoU 2026: Strengthens “agricultural research data + statistics” via ASTI project. Framework for data collection, validation, analysis, standardisation. This is data governance for AI training data in agriculture.TAT AI Project Akwa Ibom: MoU for robotic harvesting + smart sensors. Governance handled via MoU between 6 institutions, but no public AI ethics/audit protocol published yet.

7. M8.7

   Financial services AI governance

   Score 4 / 4

   AI governance provisions specific to financial services in Nigeria: Most advanced sector so far. CBN leads with binding AML AI rules + sandbox + data localization. No standalone “AI in Banking Act” yet, but financial services has the clearest rules.1. CBN - Central Bank of Nigeria: Binding AI rules The financial sector has Nigeria’s first binding AI governance standards, issued March 10, 2026.ProvisionWhat it requiresScopeBaseline Standards for Automated AML/CFT/CPF SolutionsMandatory AI/ML for AML: Banks, fintechs, payment companies must deploy automated systems for customer risk profiling, sanctions/PEP screening, suspicious transaction monitoring, regulatory reporting. “Manual AML controls no longer sufficient” Model governance: Annual independent model validation + explainable alerts. Institutions must show why a transaction was flagged Integration: AML platforms must connect to core banking + onboarding systems, assess transactions based on customer behaviour not isolated transactions AI techniques encouraged: Anomaly detection, behavioural pattern recognition, automated risk scoringApplies to all banks, mobile money operators, IMTOs, payment service providers. Banks: 18 months to comply. Fintechs/PSPs: 24 monthsDeadline + 90-day implementation roadmap requiredIT Standards BlueprintCBN IT Standards Council sets minimum maturity, compliance requirements, consequences for deviation. Covers AI governance under IT standards for financial services industryAll deposit money banks + OFIsData Localization Circular June 2026All payment-related data must be stored + processed in Nigeria from Jan 2027. Includes transaction data, BVN, NIN data. Cross-border transfer needs CBN + NDPA approvalBanks, fintechs, payment companiesFintech Report 2025 + Sandbox 2.0Expanded Regulatory Sandbox: “AI, embedded finance, cross-border payments” as priority use cases. “Test-then-codify” approach: learnings from AI experiments to formal playbooks/rules Fintech Trust & Safety Charter: Voluntary but reputational signal. Minimum expectations for data protection, AI, cybersecurity, fair competition, consumer redress Position Nigeria as Hub for Responsible AI in Finance: Tiered, outcome-based obligations = risk-adjusted supervisionFintechs + banks using AI2. Other financial regulatorsRegulatorAI ProvisionStatusNDIC - Nigeria Deposit Insurance CorpFlagged “algorithmic bias as risk in 2024 + called for monitoring frameworks” but no mandatory standards set yetAdvisory onlySECNo AI-specific rule published yet. Covered under general fintech oversightPendingNAICOMNo AI-specific insurance rule published yetPending3. Cross-cutting laws that apply to finance AI NDPA 2023: Financial data = sensitive personal data. Requires explicit consent, DPIA, Transfer Impact Assessment for cross-border transfers. NDPC operational rules took effect Sept 2025.BVN/NIN Framework: CBN mandates BVN data stored only in Nigeria + used only by licensed institutions for onboarding/KYC. Designated “Critical National Information Infrastructure” 2024.NITDA AI Ethics Code 2024: Voluntary for now. Requires transparency, accountability, human oversight. Applies to fintechs too.

8. M8.8

   Education AI governance

   Score 3 / 4

   No standalone “AI in Education Act” yet. Governance is through NAIS + curriculum policy + sector projects + NDPA. Most advanced: TRCN’s “Naija Teacher AI” + curriculum integration rules.1. National AI Strategy 2024 - Education provisions NAIS names education as priority sector. Specific governance elements:NAIS Pillar/ObjectiveEducation-specific provisionObjective 3.3: Cultivate AI-Ready Workforce“Develop and implement AI-driven training and education systems that identify, nurture, develop diverse AI talent”. Calls for curriculum reform, teacher training, reskilling initiatives across AI domains + cybersecurityPillar 3: Accelerating AI AdoptionStrategy 3.1.2: “Launch sector-specific AI adoption roadmaps” including education to give tailored guidance on integrating AI safelyEthics/Governance pillarsApplies general principles to education AI: fairness, transparency, accountability, human oversight. NAIS proposes National AI Ethics Commission + regulatory body to oversee high-risk AI including learning analytics2. Federal Ministry of Education + NITDA policiesPolicy/ProgramAI Governance provisionICT-in-Education Policy 2019 + Open Educational Resources Policy 2024Minister Alausa says these aim to “standardise digital tools, align skills to industrial needs, ensure publicly funded content remains free”. Base for AI tools in schoolsRevised K-12 CurriculumNow includes AI, robotics, digital literacy as subjects. Naija Teacher AI initiative specifically supports implementation of this curriculumDigital Literacy for All DL4ALLNITDA target: 70% of Nigerians digitally literate by 2027. Digital literacy integrated into school curricula + made mandatory general studies subject in universitiesUniversity Curriculum Reform 2024-2025NITDA + NUC agreement: Embed AI, blockchain, IoT, cloud, cybersecurity into all university curricula. Digital Literacy + Skills Curriculum rolled out across universities Dec 20243. Binding/operational governance from sector projects These show what rules exist on ground right now:Naija Teacher AI - TRCN + GMind AI 2025-2027: Scale: Equip 1.5M licensed teachers with AI tools + training for 30M students Governance: Offline-first, mobile-ready platform. Real-time monitoring, dashboards, impact reporting built in Partners: Federal Ministry of Education, NERDC, NCCE, NTI, UBEC, SUBEBs = multi-agency oversight Focus: Augments teachers, doesn’t replace. Supports revised curriculumFederal Ministry of Education pilot 2025: “Teachers on AI” training for federal unity colleges. 100 teachers per college, 6 geopolitical zones. Permanent Secretary: reports from pilot will “guide nationwide growth” = M&E built in NCC Free Internet for Students proposal: Approved educational content only = curriculum-aligned materials, accredited e-learning platforms, WAEC/NECO, digital libraries. Excludes social media, entertainment, data-harvesting apps. Requires user registration for access control NOUN + AI tutoring: National Open University integrated “AI-assisted tutoring, multilingual content, early-warning analytics” for distance learning. Model for higher ed AI governance

9. M8.9

   Measurable governance outcomes

   ○Not scored: Excluded from the pillar mean

   easurable protective outcomes from AI governance in Nigeria are still limited and early-stage. Most evidence is “inputs + process changes” not “reduced harm” yet. 2 areas show early quantifiable impact: social protection targeting + finance AML compliance. Full AI-specific harm reduction data is missing.1. What measurable outcomes exist so farSectorGovernance interventionMeasurable protective outcomeEvidence levelSocial Protection/Cash TransfersAI used for high-resolution poverty mapping to target SSNEP beneficiariesImproved targeting: AI + satellite + telecoms data expanded National Social Register from 13M to 19.7M people. Better identification of urban poor reduced exclusion errorsResearch finding: AI produced high-res poverty maps improving beneficiary targetingFinancial Services AMLCBN Baseline Standards March 2026: Mandatory AI/ML for AML + annual model validation + explainable alertsProcess compliance: Banks/fintechs given 18-24 months deadline to deploy automated monitoring. CBN says shift needed because “manual AML controls no longer sufficient” as fraud losses jumped 603% to ₦3.29B Q1 2025Outcome still “adoption rate” not “fraud reduction”. Too early to measure. But 87.5% of fintechs already report active AI deployment for fraud detectionData Protection/NDPA 2023NDPA Section 37: Right to contest automated decisions + human oversight for legal/impact decisionsEnforcement activity: NDPC issued compliance notices to 1,300+ entities incl banks/telecoms mid-2025 for failing legal requirements. Courts awarded damages in 2025 privacy breach cases, affirming data rightsOutput = enforcement notices + court rulings. Harm reduction not yet quantifiedTVET EducationEthical Principles Guiding AI + Compliance with AI Ethical GuidelinesPLS-SEM study of 400 educators: Ethical principles significantly influenced compliance + perceived AI adoption outcomes. Compliance partially mediated ethical to outcomes linkShows governance to behavior change, but not student harm reduction measured

   Scoring basis Not determined; excluded from the pillar mean.

10. M8.10

    WHO AI health guidance adoption

    Score 0 / 4

    No formal adoption/endorsement of WHO’s “Ethics and Governance of AI for Health” guidance as national policy yet. Nigeria aligns with WHO principles informally, but hasn’t issued a gazette, circular, or regulation formally adopting it.1. What exists: Alignment, not formal adoptionEvidenceStatusWHO guidance published 2021 + LMM guidance 2024Global guidance exists. Nigeria is a WHO Member State but no Federal Ministry of Health circular or regulation says “Nigeria adopts WHO Ethics & Governance of AI for Health guidance”Federal Ministry of Health position 2025Minister of State Dr Iziaq Salako says gov’t is “committed to digital health as vehicle for equity + excellence” and calls for “robust cybersecurity frameworks to protect patient data + maintain high ethical standards” at Africa Digital Health Summit. Mentions AI-powered diagnostics but doesn’t cite WHO guidance specificallyNigeria Digital in Health Initiative NDHI + NDHAGov’t developing National Digital Health Architecture as “unified blueprint” for interoperability, registries, health data exchange. Minister says need “equity, affordability, context-specific solutions, respect for national data sovereignty”. Principles align with WHO but NDHA isn’t framed as “adoption of WHO guidance”UNESCO AI Readiness Assessment 2024/2025Launched in Abuja with WHO/UNESCO involvement. Report called “roadmap for informed policy decisions” on ethical, inclusive, human-centred AI. This is readiness assessment, not formal adoption of WHO health-AI ethics guidance