Nigeria's National AI Strategy and its draft code gap | TLY

AI Regulation Tracker  /  National strategy

Nigeria's National AI Strategy sets a 2025 to 2029 agenda, while the code of practice that would bind anyone stays in draft

Nigeria's Federal Ministry of Communications, Innovation and Digital Economy published the National Artificial Intelligence Strategy in September 2025. The separate NITDA code of practice, the document that would actually carry technical obligations, was still in draft in early 2026.

What the ministry published

The National Artificial Intelligence Strategy runs to a five-year horizon, 2025 to 2029, and pursues three broad goals: economic growth and competitiveness, social development and inclusion, and technological advancement and leadership. The Federal Ministry of Communications, Innovation and Digital Economy leads it. NITDA is the key implementing body, working with the National Centre for Artificial Intelligence and Robotics.

Its origin is unusual and worth noting. The strategy was co-created through a workshop held between 15 and 18 April 2024 that deliberately convened AI researchers of Nigerian descent from around the world, rather than being drafted purely in-house.

Where obligations would come from, and why they are not here yet

A strategy does not bind anyone. The document that would is NITDA's Code of Practice for Artificial Intelligence, a separate instrument intended to set technical requirements for AI providers around transparency, risk assessment and human oversight. It was still in draft in early 2026.

There is a structural criticism of this arrangement worth taking seriously. NITDA is both the promoter of AI adoption in Nigeria and the drafter of the code that would govern it. Absent an independent oversight body, the code risks operating as self-regulation by the agency whose mandate is to grow the sector. That is a live question, not a settled one.

What actually binds AI operators in Nigeria today

This is the practical point for a compliance function. Nigeria already has AI-adjacent enforcement happening through existing regulators, and none of it waits for the strategy. The Central Bank has moved on automated anti-money-laundering model validation. The data protection commission has run an audit touching AI imagery. The consumer and competition commission has probed generative AI and news content.

If you are assessing Nigerian exposure, those are the surfaces to map, alongside the Nigeria Data Protection Act. The strategy tells you where policy is heading. It does not tell you what you are liable for.

How the strategy compares across African frameworks

Nigeria is one of a group of African states that have published national AI instruments. The differences that matter are whether a binding instrument exists underneath the strategy, and whether an independent regulator sits behind it.

Comparison
CountryInstrumentBinding rules underneath?Dedicated AI body
NigeriaNational AI Strategy, Sept 2025No. NITDA code of practice still draftNone independent; NITDA implements
KenyaAI Bill, 2026 (before Parliament)Proposed, not enactedProposed Office of the AI Commissioner
Cote d'IvoireSNIA 2030 + data governance strategyNo. Local-content AI law plannedANIA proposed by the strategy
SerbiaAI Development Strategy 2025-2030No binding AI lawAI Council established by strategy

What a US firm operating in Nigeria should do with this

Treat the strategy as a forecast, not a checklist. It tells you the direction of travel: transparency, risk assessment and human oversight are the three concepts NITDA has signalled its code will turn on, so a deployer that can already evidence those three will not be scrambling when the code lands.

The nearer-term exposure is data. The Nigeria Data Protection Act applies now, and the data protection commission has already run an audit touching AI-generated imagery. If you are processing Nigerian personal data through a model, that is the live obligation, and it does not wait for the code of practice.

Watch for two things specifically. First, whether the finalised code arrives with an independent regulator attached or stays inside NITDA. Second, whether the several AI bills before the National Assembly overtake the code, which would move the whole regime from self-regulation to statute.

What the strategy does not do

It does not create obligations, penalties or a registration regime. It does not establish an AI regulator, and it does not bring the code of practice into force. It does not displace the Nigeria Data Protection Act or any sectoral rule. Treating the NAIS as Nigeria's AI law would be a category error.

Frequently asked questions

Does Nigeria have an AI law?

No. Nigeria has a published National Artificial Intelligence Strategy, which is a policy instrument. The NITDA Code of Practice for Artificial Intelligence, which would carry technical requirements, remained in draft in early 2026.

Who leads AI policy in Nigeria?

The Federal Ministry of Communications, Innovation and Digital Economy leads, with the National Information Technology Development Agency as the key implementing body and the National Centre for Artificial Intelligence and Robotics involved in delivery.

What binds an AI deployer in Nigeria right now?

Existing law and sectoral regulators, including the Nigeria Data Protection Act and actions by the Central Bank, the data protection commission and the competition and consumer commission. The strategy itself imposes nothing.

Is there independent oversight of AI in Nigeria?

Not at present. NITDA both promotes AI adoption and drafts the code of practice, which is why commentators have called for a separate AI governance regulatory body before the code is finalised.

Last verified: July 27, 2026