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Nigeria Design Report 2019-2021

Nigeria’s second action plan continues commitments on budget openness, public contracts, extractive industry, anti-corruption measures and implementation of freedom of information legislation. The plan also provides new focus on improved service delivery, inclusion and civic space. While civil society and development partners continue to play a vital supporting role, fulfilment of commitments requires sustained engagement and institutional ownership from the leading government institutions.

Table 1. At a glance

Participating since: 2016

Action plan under review: Second

Report type: Design

Number of commitments: 16


Action plan development

Is there a multistakeholder forum: Yes

Level of public influence: Collaborate

Acted contrary to OGP process: No


Action plan design

Commitments relevant to OGP values: 15 (94%)

Transformative commitments: 4 (25%)

Potentially starred commitments: 4


The Open Government Partnership (OGP) is a global partnership that brings together government reformers and civil society leaders to create action plans that make governments more inclusive, responsive, and accountable. The Independent Reporting Mechanism (IRM) monitors all action plans to ensure governments follow through on commitments. Nigeria joined OGP in 2016. Since, Nigeria has implemented one action plan. This report evaluates the design of Nigeria’s second action plan.

General overview of action plan

The development of the action plan coincided with pre-general election activities in the first half of 2019, generating challenges for the OGP process. The dissolution of the Federal Council affected the functioning of the OGP Secretariat housed in the Ministry of Justice and delayed preparation of the plan.

Compared with the previous plan, the development of Nigeria’s second action plan saw a deeper level of engagement with non-state actors, over a period of six months. While the Technical Committee still did not provide documented feedback on stakeholders’ suggestions, CSOs were provided with several commitment drafts and opportunities to offer further input. Interviewed civil society representatives note that some proposals did not make it into the final action plan. However, most of their priority issues were incorporated into commitments, such as measures related to the fight against corruption and improvement of civic space. To ensure full transparency, the OGP Secretariat needs to create a publicly available website on the OGP process and ensure continued engagement of civil society in the action plan implementation. Nigeria’s OGP process could become more effective by engaging senior leadership of implementing institutions providing sustained and regular higher-level political support for delivery of commitments.

The current action plan consists of 16 commitments, 13 of which build from the previous action plan. They cover a variety of relevant topics, such as budget openness, disclosure of public contracts, transparency of the extractive sector, beneficial ownership transparency, implementation of the freedom of information law, and fostering integrity in public service delivery. Most commitments are closely aligned with policy priorities in Nigeria’s 2020 Vision and other international commitments, such as the Extractive Industries Transparency Initiative. Unlike the first action plan, this plan emphasizes the cross-cutting topics of inclusion and gender, although expected outcomes are not always clearly outlined. Overall, the plan includes potentially meaningful commitments, but implementation will require concerted efforts of government and development partners to ensure vital political and technical support.

The commitments in this action plan are highly relevant to integrating transparency and accountability safeguards for COVID-19 emergency relief and debt funding and stimulus. Proposed initiatives on budget transparency, procurement, and beneficial ownership align closely with the set of commitments made by Nigeria to the International Monetary Fund for receiving emergency financial assistance.[1] Therefore, the government needs to devote more expedited support to implementing these commitments.

Noteworthy commitments with transformative potential impact include the expansion of citizen participation in the budget cycle (commitment 1), introduction of a public register of beneficial owners of corporate entities (commitment 6), and measures to strengthen asset recovery legislation (commitment 7). Additionally, commitment 10 could significantly improve government ministries, departments, and agencies’ (MDAs) Freedom of Information Act (FOIA) compliance by deploying FOI desk officers in MDAs and introducing accountability mechanisms for non-compliance with release of information.

Table 2. Noteworthy commitments

Commitment description Moving forward Status at the end of implementation cycle
1. Citizen participation in the budget cycle

Pass a constitutional amendment establishing a budget timeline, create a fiscal transparency portal, and conduct a citizen participatory audit on government programs.

To maximize the impact of this commitment, the Budget Office could ensure institutionalization of the budget calendar with appropriate timelines and sanctions. The Supreme Audit Institution could integrate the participatory audit in the formal audit process. The Open Treasury portal could publish machine-readable data on budget allocations and expenditure for the COVID-19 response. Note: this will be assessed at the end of the action plan cycle.
6. Public register of beneficial owners of corporate entities

Create an Electronic Register of Beneficial Owners and enact the new Companies and Allied Matters Act Bill.

During implementation, the Corporate Affairs Commission could establish a data collection methodology, ensuring interoperability of data. To ensure higher usability of data, the register could collect data on politically exposed persons, include unique identifiers for companies, and ensure legally required disclosure of a natural person as the beneficial owner. Note: this will be assessed at the end of the action plan cycle.
7. Strengthen Nigeria’s asset recovery legislation

Enact the Proceeds of Crime Act (POCA) to strengthen management of recovered assets.

For successful implementation, it will be crucial to focus on political coordination for stakeholders on enacting POCA. Note: this will be assessed at the end of the action plan cycle.
10. Improve FOIA compliance

Deploy FOI desk officers in public institutions and introduce accountability mechanisms in cases of non-compliance with release of information.

During implementation, the Bureau of Public Service Reforms could annually monitor FOIA compliance. The IRM also recommends coordinating MDAs’ approach to FOI rules and allocating sufficient funding for public institutions to handle information requests. Note: this will be assessed at the end of the action plan cycle.


IRM recommendations aim to inform the development of the next action plan and guide implementation of the current action plan. Please refer to Section V: General Recommendations for more details on each of the below recommendations.

Table 3. Five KEY IRM Recommendations


Institutionalize multistakeholder thematic working group meetings to ensure active monitoring and implementation of commitments.


Build and maintain a publicly available repository that includes documentation on the action plan development and implementation; publish reasoned responses to suggestions received and publish feedback given.


Continue efforts to establish the beneficial ownership register of companies with an eye to publish high quality data, promote interoperability, user uptake, civil society and private sector engagement.


Pursue fiscal transparency reforms with the focus on timely publication of budget and audit reports and creation of viable mechanisms for public feedback and participation.


Improve civic space through measures to simplify CSO registration, clarify taxation and address police conduct during public demonstrations.



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