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DPO360

Data protection in Nigeria.

The Nigeria Data Protection Act (NDPA), 2023 is Nigeria's principal data protection law, enacted on 12 June 2023. The Nigeria Data Protection Commission (NDPC) oversees it, and the heaviest duties fall on controllers and processors of major importance.

In force
June 2023
Regulator
NDPC
Maximum fine
Greater of NGN 10M or 2%
Abuja

At a glance

Nigeria, in seven lines.

Law
Nigeria Data Protection Act (NDPA), 2023
In force
Enacted 12 June 2023
Regulator
Nigeria Data Protection Commission (NDPC)
Registration
Controllers and processors of major importance register with the NDPC, within six months of the Act or of becoming of major importance
Data protection officer
Mandatory for controllers of major importance; may be an employee or an outsourced provider
Breach notification
Within 72 hours of awareness to the NDPC; data subjects immediately where there is a high risk
Maximum fines
Major importance: greater of NGN 10 million or 2% of annual gross revenue. Others: greater of NGN 2 million or 2%

A summary for orientation only, not legal advice. Requirements depend on your organisation; talk to us for an assessment.

Key obligations

What the law asks of you.

Four obligations organisations in Nigeria meet first, and where we help with each.

Register as a controller of major importance

Controllers and processors of major importance register with the NDPC.

DPO360 helps with

Registration and licensing filings with national data protection authorities

Appoint a Data Protection Officer

Mandatory for controllers of major importance. The DPO can be an employee or engaged under a service contract.

DPO360 helps with

Formal DPO appointment and mandate definition, where permitted by law

Breach notification

Notify the NDPC within 72 hours, and data subjects immediately where there is a high risk.

DPO360 helps with

Incident and breach logging, escalation and regulator notification

Transfers abroad

Transfers of personal data outside Nigeria need an adequate level of protection or appropriate safeguards.

DPO360 helps with

Cross-border data transfer governance: legal basis, safeguards and approvals

How the framework came together

From the law to the regulator.

  1. 2019

    Data protection regulation

    Nigeria's earlier data protection regulation sets the baseline for organisations processing personal data.

  2. 12 June 2023

    The NDPA is enacted

    The Nigeria Data Protection Act, 2023 becomes the principal law, formalising the NDPC as regulator.

  3. March 2025

    GAID 2025 is issued

    The NDPC issues its General Application and Implementation Directive, with operational rules on registration and cross-border transfers.

NDPC

Regulatory authority

Nigeria Data Protection Commission (NDPC)

The NDPC oversees compliance with the NDPA, 2023, including the registration of controllers and processors of major importance.

Dr. Vincent Olatunji, National Commissioner

Visit the website

What the NDPC does

  • Registers major-importance controllers

    Controllers and processors of major importance register with the NDPC.

  • Receives breach notifications

    Breaches are notified to the NDPC within 72 hours.

  • Enforces the Act

    Enforces the NDPA with fines linked to annual gross revenue.

Penalties

What non-compliance can cost.

Major importance

NGN 10M

or 2% of annual gross revenue, whichever is greater

For controllers and processors of major importance, the maximum is the greater of NGN 10 million or 2% of annual gross revenue in the preceding financial year.

Everyone else

NGN 2M

or 2% of annual gross revenue, whichever is greater

For other controllers and processors, the maximum is the greater of NGN 2 million or 2% of annual gross revenue in the preceding financial year.

Readiness check

Where do you stand?

Tick what is already in place. A quick read on where you stand in Nigeria, for orientation only.

0/6

Plenty to tighten.

A short scoping call will map the gaps and the order to close them.

Close the gaps with us

Compare

Eight countries at a glance.

Tap a country to highlight its column. Scroll sideways for the rest.

LawProtection of Personal Information Act (POPIA)Data Protection Act, 2019Nigeria Data Protection Act (NDPA), 2023Data Protection and Privacy Act, 2019Personal Data Protection Act, 2022Law No. 058/2021Data Protection Act, 2021Data Protection Act, 2024
In forceJuly 2021 (most provisions from July 2020)November 2019June 2023May 2019 (regulations March 2021)May 2023October 2021 (full compliance October 2023)April 2021June 2024
RegulatorInformation RegulatorOffice of the Data Protection Commissioner (ODPC)Nigeria Data Protection Commission (NDPC)Personal Data Protection Office (PDPO)Personal Data Protection Commission (PDPC)National Cyber Security Authority (NCSA)Office of the Data Protection CommissionerMalawi Communications Regulatory Authority (MACRA)
RegistrationRegister your Information Officer with the RegulatorMandatory above thresholds, and in certain sectors, with the ODPCControllers and processors of major importance register with the NDPCEvery data collector, processor and controller registers with the PDPOCollectors and processors register with the PDPCControllers and processors register with the NCSANo one may act as a controller or processor without registeringControllers and processors of significant importance register with MACRA
Data protection officerInformation Officer required for every organisationMay be designated; relevant for public bodies, large-scale monitoring and sensitive dataMandatory for controllers of major importanceA DPO must be designated by the head of the institutionA DPO must be appointedRequired in certain cases (large-scale monitoring or sensitive data)A DPO must be appointed, under the Commissioner's guidelinesRequired for public authorities, and for large-scale monitoring or sensitive data
Breach notificationAs soon as reasonably possible, to the Regulator and data subjectsWithin 72 hours to the ODPC; data subjects within a reasonably practical periodWithin 72 hours to the NDPC; data subjects immediately where high riskImmediately, to the PDPOPromptly, to the PDPCWithin 48 hours to the NCSAWithin 24 hours to the Commissioner; data subjects as soon as practicableWithin 72 hours to MACRA
PenaltiesAdministrative fines up to ZAR 10 million; up to 10 years' imprisonment for listed offencesUp to KES 5 million or 1% of annual turnover, whichever is lower; offences: up to KES 3 million and/or 10 yearsMajor importance: greater of NGN 10 million or 2% of annual gross revenue; others: greater of NGN 2 million or 2%Up to about UGX 4.8 million and/or 10 years for listed offencesPenalty notices up to TZS 100 million; companies up to TZS 5 billion; individuals up to TZS 20 million and/or 10 yearsAdministrative fines of RWF 2 to 5 million or 1% of global turnover; corporate criminal fines of 5% of annual turnoverCorporate bodies: greater of 100 million penalty units or 2% of annual turnover; individuals up to 1 million penalty units and/or 5 yearsAdministrative penalties up to MWK 20 million; ignoring a compliance order: MWK 20 million and up to 5 years
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A summary for orientation only, not legal advice. Requirements depend on your organisation; talk to us for an assessment.

Reviewed October 2026 against: Nigeria Data Protection Act, 2023 (sections 40 and 48) and the NDPC's General Application and Implementation Directive, 2025.

Regional hub

Nigeria Hub

West & Northern Africa

DPO360 in Nigeria

How we support organisations in Nigeria.

Our Nigeria hub covers West & Northern Africa, so support for organisations in Nigeria is local to the region and close to the regulator.

  • Registration and licensing filings with the national authority
  • Breach logging, escalation and regulator notification
  • Consent, policy and records-of-processing frameworks
  • Data mapping, including where data is processed
  • Data subject access request management
  • A standing DPO appointment, with DPO-as-a-Service

39a Tai Solarin Ave, Gwarinpa, Abuja 900108

dpo360.ng@lawyeringafrica.com

+234 7901 569 623

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