Enhancing beneficial ownership data collection and use in Nigeria

Part 2: The beneficial ownership ecosystem

Institutional landscape and roles

Nigeria’s BO ecosystem encompasses a diverse network of institutions, each contributing unique capabilities and perspectives; this diversity presents opportunities for enhanced coordination and mutual reinforcement.

The CAC serves as the primary authority for Nigeria’s central BO Register, providing a critical national resource for transparency. Several other bodies collect sector-specific information aligned with their mandates: the Nigerian Upstream Petroleum Regulatory Commission (NUPRC), NEITI, and MCO for extractive industries, and the Nigerian Export Processing Zones Authority (NEPZA) for free trade zones (FTZs). NRS, the Bureau of Public Procurement (BPP), and sector regulators use ownership information to support tax compliance and procurement integrity. Investigative bodies, including the EFCC, the ICPC, and the NFIU, leverage BO data for specialised analyses and enforcement actions. NIMC provides the foundational identity verification infrastructure through the NIN system.

Key institutional capabilities and challenges

This section groups agencies into three categories: data collectors including extractive sector regulators, data users, and identity verifying agencies.

Beneficial ownership data collectors

These are the agencies that gather and maintain ownership records, either at the point of company registration, licensing, or sectoral reporting.

Corporate Affairs Commission

The CAC successfully led the legislative reform process, culminating in the enactment of CAMA 2020, demonstrating strong policy influence and coordination capabilities. The CAC has established a comprehensive digital registration system capturing corporate identity, director information, shareholding structures, and BO information. The PSC Register provides structured data supporting company extracts and basic ownership searches. The API infrastructure and login access provided by the CAC enable direct access for competent authorities. Despite its achievements, the CAC has opportunities for improvement which are outlined below.

Verification challenges

Currently, system stability challenges with NIMC hamper automated NIN verification and limit identity verification to ID documents provided, such as a driver’s licence, an international passport, or a national identification card. Restoring automated NIN verification will strengthen identity confirmation, and additional automated access to other data repositories, such as the Nigerian Immigration Services, can address NIMC system stability challenges.

Access and data-sharing mechanisms

In addition, some agencies are also unaware of the availability of API access and login credentials, or of the process for obtaining these, as the CAC requires each agency to submit a formal request for access. Broader agency adoption of API and login access would enhance real-time data-sharing.

Institutional coordination and follow-through

The distribution of BO responsibilities across various CAC departments complicates coordination on BO-related issues, diluting focus and expertise. In practice, this fragmentation could affect core implementation functions, such as verification, monitoring, and inter-agency coordination. Effective BO systems require ongoing review of verification approaches: assessing whether current checks are working; identifying weaknesses; iterating processes; and responding to emerging risks. When responsibility is dispersed, no single team is accountable for reviewing verification effectiveness or driving iterative improvements. As a result, verification risks become procedural rather than strategic.

This structure could also affect follow-through on inter-agency initiatives. For example, proposals identified by stakeholders such as integrating BO data with immigration databases to verify nationality information, or cross-checking beneficial owners against the NFIU’s sanctions lists, require sustained coordination, technical engagement, and clear institutional leadership. Without a dedicated BO unit or, at minimum, specific BO contact persons spread across key departments, such initiatives risk remaining conceptual rather than operational. If operationally feasible, establishing a dedicated BO unit or otherwise identifying BO leads in key departments across the CAC would address these challenges by consolidating technical expertise, clarifying accountability, and creating a focal point for both internal coordination and external engagement.

Nigeria Export Processing Zones Authority

Establishment of a sector-specific beneficial ownership framework

=NEPZA has established a regulatory framework for collecting BO information from entities operating within Nigeria’s FTZs. At the point of licensing, it captures information on the entity, its beneficial owners, and elements of its ownership and shareholding structure. The authority has also developed BO regulations to guide data collection and has put in place screening processes intended to prevent fraudulent applications. [15] NEPZA also coordinates with immigration authorities to verify foreign investor eligibility, and works closely with LEAs including the EFCC, the ICPC, the Department of State Services (DSS), the National Drug Law Enforcement Agency (NDLEA), the NPF, and the NFIU, sharing basic BO data to support investigations and enforcement actions.

This is an important development, particularly given the scale of investment and cross-border activity associated with FTZs. However, from our assessment, NEPZA’s BO system appears relatively new and operates at a much smaller scale than the CAC’s register.

Alignment with national and international standards

A key issue is the extent to which NEPZA’s framework aligns with broader BO standards and Nigeria’s wider BOT architecture. Based on our review, the data fields collected appear to focus mainly on ownership and shareholding, but do not clearly capture the element of control in the way reflected in FATF standards, international good practice, and the CAC’s PSC approach. This may limit the register’s ability to identify beneficial ownership in more complex cases where control is exercised through means other than formal ownership. Greater alignment with the CAC’s PSC framework would therefore help promote consistency across Nigeria’s BO system.

Access, integration, and use

At the same time, the more important question is not only whether NEPZA collects BO data, but whether that data is being systematically used in practice. While NEPZA reports coordination with immigration authorities and LEAs, there is no public portal and no clear formal access mechanism for competent authorities beyond case-based or informal sharing. NEPZA’s register appropriately serves a different regulatory space from the CAC’s, but some degree of integration or interoperability between the two systems may still be beneficial. This could be particularly helpful where there are overlaps in ownership chains, such as when shareholders in a NEPZA-registered entity are companies also registered with the CAC. For NEPZA, the next phase of reform should not be limited to collecting BO data, but should also focus on improving alignment, clarifying access arrangements, and generating stronger evidence of how BO information is being used in practice, including in ways which demonstrate effectiveness in line with FATF expectations.

Extractive sector institutions (NUPRC, NEITI, MCO)

Progress in collection, but limited progress in systematic use

Nigeria’s extractive sector agencies illustrate both how far BO implementation has come, and where the next phase of reform still needs to go. Important milestones have already been achieved: sector-specific BO disclosure requirements exist; BO data is being collected by multiple agencies; and some use of that information is taking place in licensing and audit processes. The question now is less whether BO data should be collected, and more what “next-level” implementation looks like, i.e. how BO data can be used systematically across governments for verification, risk screening, licensing, and enforcement.

Currently, multiple agencies in the extractive sector collect BO information, including NUPRC, MCO, and NEITI. This creates some duplication and administrative burden for companies, but stakeholders interviewed for this assessment were not opposed to the existence of multiple registers. On the contrary, many saw value in parallel collections where these support cross-checking, sector-specific scrutiny, and stronger verification. The challenge is that this value cannot be realised through parallel collection alone. Without structured interoperability, common data standards, and intentional exchange mechanisms, multiple registers risk becoming duplicative rather than mutually reinforcing.

NUPRC: Strong regulatory framework with opportunities for strengthened integration and data use

NUPRC has taken meaningful steps to embed BOT into upstream oil and gas regulation. In December 2022, it issued a formal directive requiring all entities holding or applying for participating interests in upstream licences to declare their PSC through a standardised BO declaration form. In January 2024, it also announced plans to establish the Nigerian Oil and Gas Assets Beneficial Ownership Register (NOGABOR), a web-based portal intended to provide public information on the beneficial ownership of petroleum assets.

This is significant progress, particularly given the value and risk profile of the upstream sector. NUPRC’s BO declaration form broadly aligns with the CAC’s PSC data fields, which provide a useful foundation for future interoperability. At the same time, the register appears more advanced as a disclosure initiative than as an embedded operational tool. NOGABOR remains relatively nascent compared to the CAC’s PSC Register: there is no published data schema or API, no disclosed coverage statistics, and no formal protocol for automatic exchange of BO data with the CAC. This means that, even where both agencies collect similar information, discrepancies in declarations may go undetected. This is not a theoretical concern; it is evidence that more can be done to ensure systems speak to each other and that cross-checking happens in practice.

The more important challenge for NUPRC is not simply to establish NOGABOR, but to move beyond register creation and embed BO data more systematically into licensing and regulatory processes. Given the strategic importance and value of the extractive sector nationally, BO data should be doing more than confirming that companies exist and identifying their declared owners and directors. It should increasingly inform screening processes, support internal risk analysis, and become part of standard operating procedures (SOPs) for licensing and related regulatory decisions.

MCO: Evidence of practical use

Among the extractive agencies, MCO provides the clearest evidence of BO data being used in practice. It actively uses shareholder and director information in mineral title decision-making, not only to assess licence applications but also to identify cases where previous title holders attempt to evade liabilities by abandoning old licences and reapplying through newly formed companies. This is an important example of BO data being used not just for disclosure, but also for regulatory decision-making and revenue protection.

MCO’s experience is valuable because it shows what more practical use can look like. It demonstrates that BO data can help answer concrete regulatory questions, strengthen screening, and detect efforts to circumvent licensing or payment obligations. In that sense, MCO is already pointing toward the next phase of implementation that other agencies, particularly in higher-value sectors, should be aiming for.

NEITI: Well placed to drive coordination and evidence of value

NEITI has played an important leadership role in advancing BOT in Nigeria and remains strategically positioned within the extractive governance ecosystem. It has established a register containing ownership data for extractive companies covered by its 2012–18 audit reports, and these now include BOT as part of their treatment of contracts, licences, and leases. Nigeria’s 2023 EITI Validation also recognised the government’s use of ownership data in assessments of oil, gas, and mining licence applications. [16]

NEITI’s role, however, could go beyond transparency reporting. Because it sits at the intersection of key extractive sector regulators and transparency commitments, it is well placed to help convene and coordinate a more systematic approach to BO data use across the sector. This would include helping drive stronger integration between data-collecting agencies, encouraging more consistent standards, and building evidence of the actual value being generated by BO disclosures. At present, that evidence base remains thinner than it should be, especially given how critical the extractive sector is to Nigeria’s economy and risk environment.

From parallel collection to a whole-of-government approach

Despite the progress made, the broader picture remains one of fragmented but promising implementation. Access to the CAC’s BO data by extractive sector agencies is uneven, partly because awareness of its API and login access remains limited and the process for obtaining access is not widely understood. In practice, this means agencies often continue to collect their own BO data while also relying on the CAC’s public search functions to verify basic company information. This is functional, but inefficient, and falls short of a more coordinated whole-of-government model.

The next phase of reform should therefore focus less on creating additional disclosure points and more on improving how existing BO data is used across institutions. That means clarifying where sector-specific registers add real value, ensuring that such value is supported by actual interoperability, and embedding BO data more deeply into operational processes such as licensing, screening, risk analysis, and enforcement. It also means moving from broad assumptions about usefulness to stronger evidence of effectiveness. For the extractive sector, the challenge is no longer whether BO data should exist, but how to make it work harder across the system.

Beneficial ownership data users

These are the agencies that access and apply BO data to fulfil their regulatory, investigative, or enforcement mandates.

Nigeria Revenue Service

Integration of tax and company registration data

The NRS maintains extensive taxpayer information through profiles linked to tax identification numbers (TINs) and has demonstrated capacity to analyse ownership structures for compliance purposes, including transfer pricing and profit-shifting risks. By cross-referencing tax data with information from banks, customs, and other sources, it is able to compare declared income and liabilities against broader ownership and transactional patterns to identify possible discrepancies.

Historically, the integration between the CAC and NRS was designed primarily to streamline the registration-to-taxation pipeline. It enabled the automatic issuance of TINs when companies were registered with the CAC, reducing registration gaps and improving taxpayer onboarding. However, one of the issues with the previous system was duplication, including cases where different companies were linked to the same TIN. As part of the 2025 tax reforms now being operationalised, company registration numbers are expected to serve as the unique TIN for companies, while individuals will be able to generate a Tax ID using their NIN. This shift to a unified identifier framework is intended to reduce duplication, strengthen data integrity, and improve inter-agency and cross-border information matching.

Institutional coordination and capacity

Although the CAC-NRS API extends beyond basic company registration details to include PSC information, the more significant issue is whether this information is being used systematically across the NRS. BO data has clear potential value for functions such as high-net-worth individuals’ compliance, tax investigation, and automatic exchange of information, particularly in helping relevant teams understand ownership and control structures, identify hidden relationships, and detect revenue risks. The challenge appears to lie less in access than in institutional capacity – specifically, the ability of relevant teams to analyse BO information, extract operational value from it, and apply it consistently across the institution. At present, familiarity with BO concepts seems concentrated among a limited number of individuals rather than being embedded across the NRS, suggesting a need for stronger internal coordination and capability-building.

That said, where BO information is being used, there is no structured mechanism for the NRS to feed back relevant findings to the CAC, such as discrepancies between declared ownership and tax filing patterns. Consequently, intelligence currently flows in one direction rather than reinforcing the accuracy of the BO register.

Bureau of Public Procurement

Current access and verification use cases

BPP uses an API integration with the CAC’s database to verify companies bidding for government contracts or registering as government suppliers. Through this connection, it is able to check company registration details, including director and shareholder information, as part of its eligibility and integrity screening. However, this integration predates the CAC’s BO register and has not been updated to pull BO data since it was introduced.

As a result, BPP’s verification process still relies mainly on legal ownership information and does not consistently look beyond formal shareholding structures to identify who ultimately controls a bidding entity. This limits its ability to detect concealed conflicts of interest, identify shell companies, and track repeated bidder behaviour across different legal entities controlled by the same individual, all of which are relevant risks in Nigeria’s procurement system. This gap is particularly important given the scale of public procurement in Nigeria and its susceptibility to fraud and corruption.

Beyond access: Institutional capacity for meaningful use

At the same time, the challenge is not purely technical. Even if the CAC’s API access were updated to include BO data, BPP would still need the institutional capacity to understand that information, interpret complex ownership structures, and use it to answer practical procurement-risk questions. For example, BO data could support screening for concealed relationships between bidders, politically exposed ownership, repeated participation by related entities, or patterns suggesting bid rigging. Without that analytical capacity, BO access risks becoming an underused compliance feature rather than an operational tool for integrity screening.

This limitation is compounded by the fact that integration with the National Open Contracting Portal (NOCOPO) remains inactive, meaning procurement data and ownership verification continue to operate in separate systems rather than reinforcing one another. The main gap is therefore no longer the absence of basic infrastructure, but the need to update existing systems and build institutional capability to use BO data meaningfully within procurement workflows. Extending the CAC’s API connection to include BO data, strengthening linkage with NOCOPO, and building BPP’s capacity to analyse and act on ownership information would significantly improve its ability to detect procurement-related corruption risks.

Nigerian Financial Intelligence Unit

Operational use of beneficial ownership data in financial intelligence

The NFIU appears to be one of the strongest and most consistent institutional users of BO information in Nigeria. It was among the first agencies to secure comprehensive access to the CAC’s BO data and uses that information regularly as part of its intelligence function. Through its Anti-Money Laundering Intelligence Platform (goAML), NFIU receives and analyses Suspicious Transaction Reports, Cash Transaction Reports, and related data, including BO information. In practice, this allows analysts to go beyond surface-level company information and use ownership data to understand control structures, identify irregularities, and support intelligence products linked to potentially illicit financial activity.

NFIU’s active use of BO data is also shaped by its lead coordinating role in Nigeria’s AML/CFT framework and its responsibility for demonstrating effectiveness in line with FATF expectations. As a central institution in the country’s FATF compliance architecture, the NFIU is required to contribute to regular reporting and evidence that BO information is not only available, but is also being used to detect, analyse, and respond to money laundering and terrorist financing risks. This appears to have made the NFIU one of the clearest examples in Nigeria of an agency moving beyond theoretical access to actual operational use. Its Crime Records Information Management System also supports information exchange with other Nigerian agencies, further strengthening the potential value of BO information in intelligence development and case support.

Barriers to more impactful use of beneficial ownership data

That said, there are still barriers to more seamless use. Even where digital integration exists, discrepancies or concerns do not always appear to be resolved through the CAC’s built-in discrepancy-reporting functionality. In practice, coordination often shifts back to more manual channels, such as email, which can reduce efficiency and weaken the benefits of system-based interaction. More broadly, the assessment suggests that the next phase for the NFIU is not basic access, which is already in place, but continued strengthening of how BO data feeds into case workflows, discrepancy resolution, and inter-agency follow-through.

Law enforcement agencies

Operational use of beneficial ownership data in investigations

LEAs such as the EFCC, the ICPC, the DSS, and the NDLEA have demonstrated strong investigative capabilities and increasingly sophisticated use of BO data across their respective mandates. The EFCC leverages corporate ownership data from the CAC to identify assets held through shell companies and complex corporate structures. EFCC investigators have identified BO concealment as one of the major obstacles in tracking suspicious wealth, alongside third-party money laundering and trade-based laundering schemes. Access to the BO Register enables investigators to more rapidly uncover the individuals behind legal vehicles used to hold or conceal proceeds of crime, supporting interim and final forfeiture applications before the courts.

The ICPC similarly draws on BO data in its anti-corruption investigations, using BO information to detect conflicts of interest, trace unexplained wealth linked to public officials, and assess compliance across government agencies. The DSS and the NDLEA have also used BO data in their respective domains, with the DSS drawing on BO information for national security investigations and the NDLEA leveraging company data to disrupt corporate structures used to facilitate drug trafficking and launder narcotics proceeds.

Access constraints and delays in practice

Despite these use cases, access to comprehensive BO data through the CAC’s API and login portal remains limited for a few LEAs. As with the extractive sector institutions, this constraint is largely attributable to a lack of awareness about the availability of API access or login credentials, or otherwise about the formal request process the CAC requires. In the absence of direct system access, investigators typically rely on public searches of the CAC platform, which would not provide additional information unavailable in the public search and may lead to delays that could compromise time-sensitive investigations. The challenge is particularly acute for asset tracing, where suspects may move, dissipate, or restructure assets during the period between an initial enquiry and receipt of verified ownership data.

Feedback gaps and discrepancy reporting

A further structural challenge is the absence of formal feedback mechanisms between LEAs and the CAC. Investigators frequently encounter discrepancies in BO data during the course of their investigations, including outdated shareholder information, undisclosed changes in control, or nominee arrangements designed to obscure true beneficial owners. Currently, the discrepancy reporting platform is not active for LEAs to report findings to the CAC to trigger data verification, update the register, or flag entities for enhanced scrutiny. They are required to report discrepancies via email.

Identity verification infrastructure

National Identity Management Commission

The NIMC maintains Nigeria’s foundational identity infrastructure through the NIN system, which captures biometric and biographic data for enrolled individuals. This infrastructure provides a critical verification layer for the BO ecosystem, as cross-referencing NIN data enables the CAC to confirm the identity of natural persons declared as beneficial owners of Nigerian companies. When the integration is stable, the system allows the CAC to automatically verify that the identity details submitted by a declared beneficial owner (including name, date of birth, and photograph) match those held in the national identity database. This automated verification strengthens the reliability of BO declarations.

However, the technical integration between the NIMC and the CAC has experienced system stability challenges that disrupt automated NIN verification. During these periods, the CAC’s identity verification capability is reduced to manual checks against submitted identity documents, specifically driver’s licences, international passports, or NIN cards and slips. While these checks provide a baseline level of assurance, they are inherently less robust than automated verification.

“The system’s effectiveness will increasingly depend not on additional collection alone, but on stronger coordination, better interoperability, more systematic use, and clearer feedback loops across institutions.”

Overall, Nigeria’s BO ecosystem reflects meaningful progress, with important legal, institutional, and technical elements already in place across multiple agencies. At the same time, the assessment highlights that the system’s effectiveness will increasingly depend not on additional collection alone, but on stronger coordination, better interoperability, more systematic use, and clearer feedback loops across institutions. Part 3 therefore turns to the strategic assessment, setting out the main opportunities to address these gaps and enhance the impact, quality, and usability of BO information across the wider system.

Footnotes

[15] Nigeria Export Processing Zones Authority (Disclosure of Beneficial Ownership Information for Free Zones Enterprises) Regulations, 2023, Federal Republic of Nigeria Official Gazette No.5 Lagos, 8 January 2024, Vol III. Government Notice No. 17, B405-412.

[16] EITI, “Nigeria achieves moderate score in EITI implementation”, 30 November 2023, https://eiti.org/news/nigeria-achieves-moderate-score-eiti-implementation#:~:text=Minutes%20of%20NSWG%20meetings%20indicate,0.05%25%20of%20government%20mining%20revenues.

Next page: Part 3: Strategic assessment and opportunities for enhancement