Enhancing beneficial ownership data collection and use in Nigeria
Part 3: Strategic assessment and opportunities for enhancement
Nigeria has already put in place many of the foundational elements of a BO framework, including legal reforms, a central register, and sector-specific collection points. The next phase should focus on ensuring that BO data is routinely used, shared, and cross-checked across institutions responsible for tax administration, procurement, financial intelligence, licensing, and law enforcement. This requires an implementation approach that places greater emphasis on institutional ownership, operational coordination, and a whole-of-government approach, rather than treating BO reform primarily as a legal or technical compliance exercise. The opportunities outlined below focus on deepening cross-agency integration to support data use, improving data quality, closing data gaps, and building the feedback mechanisms needed to keep the register accurate, comprehensive, and actionable.
Maximising the use of beneficial ownership data through a whole-of-government approach
Using beneficial ownership data to strengthen revenue administration and integrity in public procurement
A major opportunity for enhancement is to move BO data beyond agency-specific or ad hoc use and embed it more systematically across government functions where it can strengthen decision-making. For example, Nigeria’s 2025 tax reforms were explicitly aimed at fixing a tax system seen as fragmented and inefficient at collecting and generating the revenue needed for development, and the NRS was created to replace the Federal Inland Revenue Service with broader powers for assessment, collection, and accounting for federal revenue. [17] In that context, BO data should be treated as a practical tool for delivering the reform agenda: helping the NRS identify hidden relationships, test declared ownership against tax behaviour, detect possible revenue leakages, and strengthen risk analysis across functions such as high-net-worth compliance, tax investigation, and exchange of information. The key opportunity, therefore, is not simply access to BO data, which already exists, but embedding its use institutionally and systematically across the NRS so that it supports its broader mandate to improve revenue administration, reduce leakages, and strengthen data integrity.
“A major opportunity for enhancement is to move BO data beyond agency-specific or ad hoc use and embed it more systematically across government functions where it can strengthen decision-making.”
BPP is currently developing an electronic Government Procurement (e-GP) system, which presents a timely opportunity to embed BO verification into the supplier and contractor registration process. Rather than creating a parallel system for collecting BO information, the planned e-GP platform could integrate with the CAC’s BO register to retrieve relevant ownership data at the point of supplier onboarding. Suppliers could then be required to confirm the accuracy of the retrieved information as part of the procurement registration process. This approach would allow BPP to leverage the authoritative BO data already held by the CAC while avoiding duplication and the creation of a separate ownership registry.
BPP could draw inspiration from ChileCompra, Chile’s public procurement platform. [18] ChileCompra integrates mandatory BOT requirements into its public procurement system to help procurement authorities identify links between public officials and companies participating in bidding processes, revealing conflicts of interest that may not be apparent from director information alone. [19] Incorporating a similar integration within Nigeria’s e-GP system would strengthen procurement integrity, improve due diligence during supplier registration, and add an additional layer of transparency and accountability in public spending.
In addition, cross-referencing beneficial owners against the NFIU’s sanctions lists and suspicious transaction reports would add a further layer of intelligence-driven verification, enabling proactive identification of high-risk entities rather than reactive investigation.
Enhancing data quality through verification and systematic feedback mechanisms
BO disclosure consists of three primary layers of information that need to be verified: details about the company or legal entity; information about the individuals involved (that is, the PSC); and insight into the nature of the ownership or control relationship itself.
Verification of beneficial ownership information
Verifying the company is usually the most straightforward part of the BO verification process – in Nigeria, it is also well supported, as the CAC maintains a comprehensive database of registered companies. Verification of individual information is also often achievable through cross-checking with existing government systems. The CAC already collects identity information in accordance with the PSC Regulations, including NIN, international passport, and driver’s licence. [20] The CAC also requires an upload of the chosen ID and cross-checks the relevant information entered into the online form with the information on the uploaded ID. Ongoing efforts to resolve the system stability challenges in the API integration with the NIMC for automated NIN verification would be a crucial step toward improving data quality. In the interim, integration with the Nigeria Immigration Service could support passport verification, while collaboration with the Federal Road Safety Corps (FRSC) could enable authentication of driver’s licence information. These linkages would move the CAC closer to automated, real-time identity verification.
However, verifying the identity of the company and natural person is only one part of the challenge. The most complex step lies in verifying whether a declared BO relationship reflects reality. To address this effectively, a combination of inter-agency collaboration (including tax, immigration, financial intelligence, and procurement authorities), engagement with financial institutions and designated non-financial business and professions (DNFBPs), and risk-based verification mechanisms is required. Prioritising automated checks for higher-risk disclosures, such as individuals linked to an unusually high number of companies or ownership patterns commonly associated with misuse, would allow the CAC to focus resources where the integrity risks are greatest.
Box 1. International experience provides valuable models for verification
In Ukraine, automated systems trigger red flags when a beneficial owner’s declared ownership in a profitable company does not align with tax data indicating significantly lower income. [21] This discrepancy prompts further scrutiny.
Similarly, since September 2019, Costa Rica has implemented an IT system to check the identity information declared by the beneficial owner against details available in state databases, including those of: the Supreme Court (on national identification); the Foreign Ministry (on diplomats’ identities); the Immigration Office (on foreigners’ identities); the Commercial Register (on legal persons); the Economy Ministry (on trusts); and the National Directorate of Notaries (on validity of notarised documents). This register is a good example of the intercommunication between different databases in order to ensure consistency on common data points held in these registers and to flag discrepancies with declared BO information.
Austria uses a two-step verification model to manage large volumes of BO filings. An automated system first selects cases for review using random sampling and multiple risk indicators, after which trained registry staff manually verify the higher-risk cases by checking supporting documents and other data sources. The model shows how automation and targeted human review can work together to improve register accuracy without requiring a large verification team. For Nigeria, it offers a useful example of how the CAC could strengthen BO verification through risk-based case selection, access to other government-held data, and structured follow-up on flagged records. [22]
In the Nigerian context, enhancing the verification of ownership relationships will rely on a stronger collaboration with obligated entities, including financial institutions and DNFBPs. These entities already perform Know Your Customer processes and customer due diligence, positioning them well to assist in verification through structured discrepancy reporting. Discussions with the CAC indicate that some obligated entities may confuse legal ownership (i.e shareholding) with beneficial ownership. This presents an opportunity for the CAC to organise regular forums, perhaps quarterly, to foster shared understanding, strengthen collaboration, and improve the reliability of BO information.
Systematic feedback mechanisms
A major opportunity for strengthening Nigeria’s BO framework is to establish more systematic feedback channels between the CAC and the agencies which actively use BO data, particularly the NRS, the NFIU, and LEAs. These institutions do not simply access BO information; they analyse it against tax records, financial intelligence, investigative findings, and other underlying data sources. This places them in a strong position to identify inconsistencies between BO disclosures and actual financial behaviour, ownership patterns, or control arrangements. At present, however, there is no structured mechanism for this type of intelligence to flow back into the register in a way that supports ongoing verification and improvement.
This matters for more than discrepancy correction alone. A stronger feedback loop would help the CAC assess whether BO information is: accurate, adequate, and up to date; sufficient to answer operational questions raised by investigators and analysts; and structured in a way that supports practical use. In the case of the NRS, this could help identify discrepancies between BO declarations and tax filing patterns. In the case of the NFIU and LEAs, investigative insights could help flag suspicious ownership records, hidden control relationships, or cases where disclosures are incomplete or misleading. Over time, this would allow the CAC to move beyond passive data collection towards a more intelligence-driven verification model, where the experience of key data users helps improve the register’s accuracy, reliability, and enforcement value.
“A stronger feedback loop would help the CAC assess whether BO information is: accurate, adequate, and up to date; sufficient to answer operational questions raised by investigators and analysts; and structured in a way that supports practical use.”
On the BO Register, the discrepancy reporting feature could be enhanced to facilitate multi-user reviews (reviewing officers) and incorporate a feedback loop. Currently, discrepancies are reported via email, but a practical approach would be to integrate feedback and discrepancy reporting directly into the system architecture. This should allow authorised users to submit structured feedback that automatically flags records for review, temporarily marking companies as “under review” until the discrepancy is addressed. Implementing clear protocols for assessing and resolving feedback, including tracking whether BO data ultimately proves reliable or insufficient, would create a feedback loop between disclosure and use, enabling continuous improvement in the accuracy, adequacy, and usability of BO information.
Optimising multi-sector registers through strategic coordination
Stakeholders generally accept the existence of multiple sector-specific registers and often justify this on the basis that they create opportunities for cross-checking. In principle, this is a valid argument, but in practice, this cross-checking is not happening systematically, meaning the potential verification value of multiple registers is largely unrealised. At the same time, parallel collection places additional administrative burdens on companies, particularly where they are required to submit BO information separately to different regulators.
The immediate strategy is therefore to standardise BO data requirements across agencies, so that companies are not reporting BO information differently to other regulators. This means ensuring that all agencies collect the same core information on beneficial owners in the same format, including basic identity details, the nature and extent of ownership or control, and the date on which a person became a beneficial owner. At present, differences in formats and data structures make comparison and validation more difficult than necessary. A common BO data collection standard would therefore reduce reporting burdens, improve consistency, and make cross-checking between registers more effective.
Alongside this, stronger coordination and interoperability are needed so that the existence of multiple registers can truly support verification. This is particularly important because reporting triggers are not fully aligned: the CAC requires updates within 14 days of any change in beneficial ownership, while some sectoral regulators, such as NUPRC, appear to require updates only when there is a change in legal ownership (i.e shareholding). This is broader, and it may not capture other changes in control that should also trigger a BO update. As a result, differences between registers may arise not only from an attempt to mislead, but also simply from different reporting obligations. Although NUPRC uses the CAC’s BO declaration form, Box 2 shows that discrepancies in BO information still occur across the two registers. This suggests that harmonised forms alone are not enough. More systematic coordination and API-based integration are needed so that agencies can access current data, detect inconsistencies, and trigger resolution, including through automated notifications where ownership changes or conflicting declarations appear across registers.
Box 2. Illustrative example: Why coordination between extractive sector beneficial ownership registers matters
A review of selected companies across the CAC Register, NOGABOR, and the NEITI Register shows both the potential and the limitations of multiple BO registers. For Ocean Gate Engineering Oil and Gas Limited, the CAC register lists seven beneficial owners, although some information appears incomplete, including missing birth details, unclear statements of the nature of control, and no clearly stated percentage ownership for some records. NOGABOR, by contrast, lists one beneficial owner with 76.7% ultimate ownership, while the company does not appear on the NEITI register.
For Continental Oil and Gas Limited, the company appears in both the CAC and NEITI registers, but not in NOGABOR. While two beneficial owners are recorded across the CAC and NEITI registers, only one appears consistently in both; the second differs between the two.
These examples do not necessarily mean that one register is “wrong” and another is “right”. Rather, they illustrate the practical limits of maintaining multiple BO registers without structured interoperability, data standards, and institutional processes for reconciling discrepancies. Without structured coordination and intentional cross-checking, multiple registers risk operating as disconnected repositories rather than as mutually reinforcing tools for verification and licence screening.
“Without structured coordination and intentional cross-checking, multiple registers risk operating as disconnected repositories rather than as mutually reinforcing tools for verification and licence screening.”
A useful parallel can be drawn with Nigeria’s approach to biometric identity data, where the NIMC serves as the authoritative primary source for the biometric and biographical data of all Nigerians. Government agencies rely on NIMC as the single source of truth and are required to ensure consistency with it. For example, where a discrepancy arises during a passport application at the Nigeria Immigration Service, the applicant is directed to rectify the inconsistency at source with NIMC before the process can proceed. This architecture ensures data integrity, reduces duplication, and places accountability for accuracy with a single authoritative body.
Nigeria should explore applying this same principle to BO information, with the CAC registry serving as the equivalent authoritative source. Under this approach, two options are worth considering:
- The preferred option would be for agencies that currently collect BO information to cease doing so independently and instead pull directly from the CAC’s register, building any additional sector-specific information, analysis, or risk assessment on top of that foundation. This would eliminate the risk of conflicting information about the same entity sitting across multiple registers.
- Alternatively, where an agency chooses to continue collecting BO information for operational reasons, it should be required to cross-reference any submission against the CAC’s public portal at the point of collection. Where a discrepancy is identified, the submitting entity should be directed to rectify the information with the CAC before the agency proceeds, mirroring the NIMC model.
This recommendation builds on the existing multi-sector register approach, which stakeholders have expressed satisfaction with. However, as currently structured, the approach is not being leveraged for its verification potential as indicated above, thereby resulting in different, potentially conflicting information about the same company held across different registers with no mechanism for reconciliation. The above framework would preserve the multi-sector structure while introducing the coordination and consistency needed to make it genuinely effective.
Building institutional capacity
The CAC should formalise its BO coordination architecture. Whether through a dedicated unit, a designated coordinator role, or a structured inter-departmental working group, the key requirement is clear ownership of verification, discrepancy remediation, and stakeholder management functions. The current informal distribution of these responsibilities creates accountability gaps that risk register quality over time. The pattern across most company registry contexts is that BO responsibilities are distributed across existing functions, with coordination managed through designated focal points, internal protocols, or inter-agency agreements.
A formal operational inter-agency working group dedicated to BOT would significantly improve effective cross-agency technical collaboration. Without a designated, regularly meeting body composed of representatives from all relevant government agencies, the coordination of technical efforts, sharing of expertise, standardisation of data formats, and alignment of implementation strategies remain sporadic. This lack of a formal structure slows problem-solving on interoperability issues and ultimately undermines consistent, comprehensive implementation of the BO framework across all sectors.
Establishing specialised capacity is crucial for effective oversight. This dedicated approach would consolidate expertise and ensure focused attention on verification, discrepancy resolution, stakeholder coordination, and a consistent application of regulatory standards. A permanent inter-agency operational working group would provide a formal platform for technical collaboration, problem-solving, and continuous improvement to achieve desired regulatory outcomes.
Measuring and demonstrating impact through real-world success
The value of BOT reforms does not lie in the robustness of legislative and regulatory frameworks, the innovative systems used for data collection, or even the quality of the data collected: real impact happens when the data is used by data users, in conjunction with other data sets, to answer questions – whether investigative, regulatory, fiscal, or risk-based – and to inform decisions that lead to accountability and action. In Nigeria, multiple agencies have demonstrated the practical value of BO data through successful investigations and enforcement actions. These examples illustrate both the register’s effectiveness as well as opportunities for enhancement.
Case example 1, tax evasion detection: NRS investigators identified a shell company network using BO data alongside financial intelligence. By cross-referencing CAC records with bank transactions and procurement databases, investigators traced repeated use of Nigerian nominees by foreign controllers. The investigation revealed multiple companies with identical BO structures, resulting in successful enforcement actions and asset recovery.
Box 3. NRS case study: Uncovering a shell company network using beneficial ownership data and NRS financial data
A Chinese national and a Nigerian nominee established Company A, with a Nigerian as the only in-country director and shareholder. The Chinese national ran the company under a power of attorney and signed important bank documents. Within six months, Company A secured a contract and received large payments. Before the tax authorities could fully investigate, Company A was dissolved, and Company B was registered with the same Nigerian nominee but a different Chinese facilitator. The same pattern then occurred with Companies C and D.
Tax investigators became suspicious due to several factors, including Suspicious Transaction Reports showing rapid transfers between related accounts, procurement databases revealing new companies winning contracts with the same directors, and TaxPro Max flagging multiple company registration numbers linked to the same tax identification details. [23] The companies shared addresses and phone numbers, and used the same company secretarial firm for fast incorporation and dissolution.
These linkages led investigators to check CAC BO records for all entities, revealing repeated use of the same nominee and registered address. Further analyses of bank account details showed foreign IP addresses, frequent transactions with overseas banks, and payments to a single offshore account. BO declarations listed the Nigerian nominee as the ultimate owner, but the bank documents showed the Chinese nationals as the actual signatories, raising red flags. The company secretarial firm confirmed it provided quick incorporation and strike-off services. Invoice reviews exposed fake consultancy fees aimed at shifting profits offshore.
Using evidence from the NFIU and banks, investigators obtained court orders to freeze accounts and issue provisional tax assessments for all companies in the network. This consolidated assessment included unpaid corporate income tax, VAT, and withholding tax, as well as penalties and interest totalling hundreds of millions of naira. Authorities placed asset restraints on vehicles and property. The Nigerian nominee faced fines and criminal charges for aiding tax evasion and money laundering. Legal requests have been sent to trace and recover offshore funds.
Box 4. Case study: Uncovering hidden assets through data integration
The EFCC investigated a public servant suspected of concealing ownership of high-value assets, whose value was inconsistent with a civil servant’s earning potential. The challenge was proving the connection between the official and identified properties registered under different names or corporate structures.
As a first step, investigators employed a multi-source data approach. Primary data sources, like the CAC’s BO Register, were used to identify ultimate controllers of registered companies, and bank statements and records were used to trace money flows and asset acquisitions.
After acquiring all this foundational information, the investigative team cross-referenced data points across multiple agencies, searching for unique identifiers that remained constant across datasets. These included phone numbers, residential addresses, TIN, and NIMC data. When the same identifier appeared in multiple records, linking a company to financial transactions and personal documentation, it established a clear ownership trail.
Through systematic cross-checking, investigators uncovered the public servant’s hidden interests in three significant assets: a factory, a hotel, and an event centre. Despite attempts to obscure ownership through corporate structures, the convergence of data points across different registries revealed the beneficial owner.
The evidence gathered proved sufficient to secure asset forfeiture through a non-conviction-based process in court. All three properties were recovered and transferred to federal government control for public use. Criminal prosecution of the individual may follow as investigations continue. The integration of BOT with financial and regulatory data enabled authorities to pierce corporate veils and identify concealed assets that would otherwise remain hidden.
Box 5. Case study: Detecting fraudulent expatriate applications through inter-agency collaboration
NEPZA regularly processes applications from entities seeking to establish operations within FTZs. These applications often include requests for expatriate personnel to provide specialised expertise needed for operationalisation. NEPZA received an application from a prospective FTZ entity requesting approval for an expatriate expert. The applicant submitted comprehensive documentation, including the expatriate’s credentials, qualifications, and proposed designation within the organisation. Following standard protocol, NEPZA forwarded this information to the NIMC for verification.
During the NIMC’s investigation, a critical discrepancy emerged: the expatriate’s actual qualifications did not match the requirements for the stated role. The credentials provided were insufficient to support the claimed technical expertise. Shortly afterwards, the same individual resubmitted an application using identical documentation but listing a different job designation. This pattern immediately raised red flags within the verification system.
Through the existing collaborative framework between NEPZA and the NIMC, the identity management commission identified inconsistencies and ultimately denied the individual entry. The inter-agency coordination proved effective in preventing a potentially fraudulent placement.
While the collaboration successfully prevented the fraudulent entry, a significant process weakness was revealed: the absence of a formal feedback loop. Neither the applying entity nor NEPZA received any structured communication from the NIMC explaining the identified inconsistencies that led NEPZA to reject the application or the specific discrepancies identified.
These successes demonstrate the register’s practical impact while revealing opportunities for enhancement. Stronger technical integration, systematic feedback channels, and expanded API access would multiply these positive outcomes across the BOT ecosystem.
Measuring and communicating the impact of the Beneficial Ownership Register
The proposed inter-agency framework on BOT should embed a commitment to impact measurement as a core function. This means establishing baseline indicators at the outset and tracking, on at least an annual basis, the concrete outcomes that flow from BO data collection, verification, and use. This may include the number or value of investigations supported, contracts scrutinised, illicit financial flows identified, tax assessments informed, or debarment actions taken across participating agencies. Without this discipline, the considerable institutional effort invested in building and maintaining the register risks remaining invisible to the technical and political stakeholders whose buy-in is most critical.
Translating that data into accessible, publicly available insight pieces, such as brief annual reports or impact notes, would serve multiple audiences simultaneously. For the CAC and other participating agencies, documented impact provides institutional validation. It shows evidence that the verification exercises their staff undertake have tangible downstream consequences for governance and accountability. For civil society organisations and the broader public, it builds the case that BOT is not a technical compliance exercise but a practical tool for protecting public resources. Framing findings in plain language, with sanitised illustrative case examples would go a long way toward demystifying the BO Register and sustaining civic interest. It also helps sustain political will and national ownership of these reforms beyond the FATF requirements and could serve as a compelling justification for budgetary allocation to sustain the register and BO-related efforts.
A credible impact narrative also positions Nigeria more competitively for development partner support. Bilateral donors and multilateral institutions increasingly require evidence of effective use of a BO register, not just its existence, before committing technical or financial assistance. Annual impact documentation would give the CAC a ready-made body of evidence to present in funding conversations, demonstrating that the country’s BO architecture is not only operational but also generating measurable public value. The framework should therefore designate clear responsibility for impact tracking and reporting, with adequate resources to support it.
Footnotes
[17] Republic of Nigeria, “You Ask, We Answer: The Nigerian Tax Reform Bills”, n.d., https://fiscalreforms.ng/wp-content/uploads/2024/11/The-Nigerian-Tax-Reform-Bills-You-Ask-We-Answer.pdf.
[18] ChileCompra, home page, n.d., https://www.chilecompra.cl/.
[19] Guillermo Burr and Rodrigo Félix Montalvo, “Progress and steps taken”, in Beneficial ownership in Chile’s public procurement reform (Open Ownership, 2025), https://www.openownership.org/en/publications/beneficial-ownership-in-chiles-public-procurement-reform/progress-and-steps-taken/.
[20] Republic of Nigeria, “Companies and Allied Matters Act, No. 3, 2020 – Persons with Significant Control Regulations, 2022”, para. 4, January 2023, https://news.cac.gov.ng/wp-content/uploads/2023/01/PSC-Regulations-2022.pdf.
[21] World Bank, “Case Study 18: Asset and Interest Declarations – Reform of Asset and Interest Disclosure in Ukraine”, n.d., https://thedocs.worldbank.org/en/doc/457791611679267058-0090022021/original/ReformofAssetandInterestDisclosureinUkraine.pdf.
[22] UNODC and Open Ownership, “Verification of Beneficial Ownership Data in Austria, Germany and Slovakia”, in Implementation of COSP Resolution 10/6 on Enhancing the Use of Beneficial Ownership Information to Strengthen Asset Recovery (Open Ownership, 2025), https://www.openownership.org/en/publications/implementation-of-cosp-resolution-10-6/verification-of-beneficial-ownership-data-in-austria-germany-and-slovakia/.
[23] Federal Inland Revenue Service, “Public Notice: Updates to TaxPro Max”, n.d., https://assets.kpmg.com/content/dam/kpmg/ng/pdf/firs-public-notice-on-updates-to-taxpro-max.pdf.