Ensuring comprehensive coverage of state-owned enterprises
It is important to ensure that any beneficial ownership regime will comprehensively cover SOEs in complex organisation chains, taking into consideration the fact that SOEs can take many forms and be set up through different mechanisms, such as by statute. Without robust legislation, these mechanisms may exclude them from the scope of the disclosure regime.
In Nigeria, businesses are regulated by the Corporate Affairs Commission (CAC). The CAC register shows the control of NNPC by two government ministries – the Ministry of Petroleum and the Ministry of Finance,  both of which contain special divisions that are incorporated by statute. As instruments of government ministries, no further information about their involvement is held on the CAC register. This makes it difficult to gather a detailed picture of control.
To comprehensively cover SOEs, consideration should be given to the following:
- Scope of the legislation
- Legal forms
- SOEs created by statute
 Federal Republic of Nigeria Official Gazette (2021), Petroleum Industry Act, 2021, Section 53(3). Retrieved from http://www.petroleumindustrybill.com/wp-content/uploads/2021/09/Official-Gazette-of-the-Petroleum-Industry-Act-2021.pdf.