Strengthening Beneficial Ownership Compliancew (NG0048)

Thematic Area: Fiscal Transparency

Commitment Number 5
Thematic Area: Fiscal Transparency
Commitment: Strengthen the compliance with BO reporting requirements and utilisation of the BO register

Brief Description of Commitment:
This commitment seeks to address the issue of compliance with BO reporting requirements by registered entities and also enhance the use of BO data by relevant stakeholders.

General Problem/Challenge Addressed by the Commitment:
Despite Nigeria's commendable effort in establishing a Beneficial Ownership Register in 2023, the compliance levels, particularly by legacy companies and the utilisation of the data to inform decision-making remain sub-optimal.

Non-optimal filings of BO information by legacy companies (registered before the deployment of BO register) to promote beneficial ownership transparency. Expanding integration, institutionalisation and use of the data in the BO Register by stakeholders and other authorized persons.

Rationale for the Commitment:
This commitment would support the rapid increase in the level of compliance by legacy companies and the enhanced use of BO data by key government regulators and CSO actors, for effective compliance, transparency and attainment of Nigeria's anti-corruption goals. There has been a substantial utilization of the register by competent authorities like LEAs and the NFIU, effort should focus on discrepancy reporting and resolution, direct integration and enhanced verification protocol.

Main Objective:
To improve transparency in company ownership and control to prevent corruption.

Anticipated Impact:
Transparency in business, reduced corruption and money laundering, and improved trust in public institutions.

Expected Outcomes | Milestones (Performance Indicators)
1. Enhanced compliance with BO filings by legacy companies
• By the expiration of this NAP cycle in 2029, ensure a 20% increase in BO filings by legacy companies, achieved through incremental growth of at least 5% per year over the four-year period.
2. Improved ease of doing business
• Improved level of transparency and accountability within the business sector.
• By 2026, CAC publishes clear, user-friendly BO filing guidelines online and launches annual user surveys in 2027 which report progressive improvements in clarity and ease of compliance.
• By 2027, at least one professional body (e.g., Nigerian Bar Association, Institute of Chartered Secretaries, or Institute of Chartered Accountants), in collaboration with the CAC, delivers an annual survey evidencing increased confidence in using BO data for due diligence. Survey findings show measurable year-on-year growth in BO data use from 2027 through 2029.
3. Increased API access among relevant stakeholders to facilitate verification and use of BO data
• Increase in the number of API or login access to the BO register.
• Onboard key competent authorities with institutional login access
• From 2026-2029, at least one new institutional government users (e.g., NRS BPP, NUPRC) are onboarded to the BO register API or login access each year, with at least three of these government stakeholders actively using the API or login access by 2028 and demonstrating documented cases of verification or oversight impact.
4. Targeted government agencies institutionalise and proactively use BO data to strengthen due diligence, enforcement, and policy oversight―resulting in more effective action against corruption, tax evasion, procurement fraud, and other financial crimes.
• At least one additional government agency institutionalises the use of BO data for core functions (tax, procurement, licensing, or enforcement) each year from 2026-2029. OR At least one targeted government agency (BPP, NRS, NUPRC or CCB among others) institutionalises the use of BO data for core functions (tax, procurement, licensing, or enforcement) each year from 2026-2029.
• At least one new case per year from a minimum of 3 of the "State Actors" listed above (audit, investigation, procurement review, or enforcement action) demonstrates the use of BO data, with cumulative evidence of measurable financial or compliance gains by 2029.

Planned Activities | Start Date | End Date | Expected Output(s) | Output Indicator(s)
1. Provide institutional login access to all competent authorities without API integration | Jan 2026 | Dec 2029 | • Unique login credentials issued to each competent authority • A user access policy document defining roles, permissions, and data access levels for each authority • A training guide or onboarding manual for institutional users on how to navigate the register | • Number of competent authorities that received institutional login credentials Percentage of competent authorities with active accounts (logged in at least once within 30 days of account creation) Number of BO searches or queries conducted by competent authorities per quarter • Average time from access request to credential issuance (in working days) • Number of institutional users trained on using the portal • Number of support tickets raised and resolved related to institutional access
2. Partner with civil society organizations to independently verify a sample of beneficial ownership entries on the BO Register and confirm the accuracy of declared information. | Jan 2026 | Dec 2029 | • A signed partnership agreement or MoU between CAC and selected CSOs defining scope, methodology, and data access terms • A verification framework document outlining sampling criteria, assessment methodology, and reporting standards • A pilot verification exercise completed on a defined sample of BO entries A verification report from each participating CSO documenting findings, error rates, and data quality issues • A remediation action plan based on CSO findings to correct inaccurate or incomplete entries • A feedback mechanism for CSOs to flag discrepancies directly to the registrar | • Number of CSOs formally partnered for independent BO verification • Number of BO entries sampled and independently assessed • Percentage of sampled entries found to be accurate and complete • Percentage of sampled entries flagged for discrepancies or errors • Number of verification reports published by CSOs • Number of corrective actions taken by the registrar based on CSO findings • Time taken (in working days) to resolve flagged discrepancies after CSO reporting • Number of verification cycles completed per year
3. Train and sensitize key stakeholders on how to access, use, and benefit from the Beneficial Ownership Register to strengthen transparency and compliance. | Jan 2026 | Dec 2029 | A stakeholder mapping document identifying target groups (MDAs, private sector, CSOs, law enforcement, financial institutions, legal practitioners) • A tailored training curriculum for each stakeholder group covering register access, data interpretation, and practical use cases • Sensitization workshops delivered across the six geopolitical zones • Training sessions conducted for competent authorities on using BO data for investigations and compliance Printed and digital awareness materials (fact sheets, user guides, FAQs) distributed to stakeholders • A dedicated online learning module or resource page on the BO Register platform • A post-training feedback and evaluation report summarizing knowledge gains and participant recommendations | Number of sensitization workshops conducted • Number of stakeholders trained, disaggregated by stakeholder group and geopolitical zone • Percentage of trained stakeholders who demonstrate improved understanding of the BO Register (measured through pre and post assessments) • Number of training materials developed and distributed • Number of unique visits to the online learning module or resource page • Number of new BO Register searches conducted by trained stakeholders within 90 days of training • Number of geopolitical zones covered by sensitization activities Percentage of participants rating the training as useful or very useful in feedback surveys
4. Develop and publish a BO data field harmonisation standard to align definitions, identifiers, and disclosure requirements across CAC, BPP, NRS, NUPRC, NEITI, and MCO. | Jan 2026 | Dec 2027 | A cross-agency technical working group established and meeting regularly to oversee implementation of the standard. | • A published BO data field harmonisation standard or technical guidance document agreed upon by participating agencies. • Number of cross-agency technical working group meetings held per year • Evidence of reduced data mismatche cross-agency BO queries following adoption. | Whether a harmonisation standard has been published (Yes/No, with date). Number of agencies that adopt the harmonised data fields in their own systems.
5. Implement a structured BO data verification mechanism, in partnership with CSOs, to assess accuracy, completeness, and consistency of information in the BO Register | Jan 2026 | Dec 2029 | • A BO verification methodology developed and documented. • At least two CSO partners trained and accredited to conduct BO data verification. Annual verification reports produced, with findings submitted to CAC for remediation. | Number of CSO partners formally engaged in BO verification activities per year. • Number of BO entries verified annually. • Number of discrepancies or inaccuracies identified and reported to CAC. • Percentage of flagged discrepancies resolved by CAC within an agreed timeframe.
6. Establish a BO discrepancy resolution protocol, drawing on the Austrian WiEREG model, to enable systematic identification and correction of inaccurate or inconsistent BO declarations. Produce and publish Nigeria's BO transparency progress report (2016-2026), and institutionalise annual BO data reporting | January 2027 | Dec 2028 | June 2027 | December 2027 | • A Nigeria-adapted discrepancy resolution protocol drafted and approved by CAC. A pilot run of the protocol with at least one sector or agency completed by end of 2027. • A discrepancy resolution workflow integrated into CAC's BO register operations. • A published report documenting Nigeria's BO transparency journey from 2016 to 2026, covering legislative milestones, register performance, FATF greylist exit, and outstanding challenges. • An annual BO data report produced by CAC from 2026 onward, covering compliance rates, API and login access usage, agency uptake, and register accuracy trends. | . Whether the discrepancy resolution protocol has been published and adopted (Yes/No, with date). • Number of discrepancy cases processed through the protocol per year. • Percentage of discrepancy cases resolved within defined timelines. • Evidence of CAC capacity to operationalise the protocol without external technical support by 2029. • Whether the 2016-2026 progress report has been published (Yes/No, with date and accessibility). Number of annual BO data reports produced and made publicly available • Number of data points collected and disaggregated by user category (law enforcement, financial institutions, procurement agencies, CSOs).
7. In partnership with CSOs, conduct legal and policy groundwork for a presidential executive order or ministerial regulation establishing CAC as Nigeria's primary BO registry authority. | Jan 2026 | August 2027 | • A legal analysis produced by CAC and the Federal Ministry of Justice mapping existing provisions in CAMA, the Money Laundering Prevention and Prohibition Act, and Nigeria's data protection legislation relevant to BO data governance authority. • A policy gap analysis identifying where existing law is insufficient and where the executive order or ministerial regulation needs to fill the gap. • A draft instrument prepared, reviewed for legal coherence and enforceability, and circulated to key stakeholders for input. | • Whether the legal and policy analysis has been completed and shared with relevant MDAs (Yes/No, with date). • Whether a draft instrument has been produced by FMOJ in coordination with CAC (Yes/No, with date). • Number of legal review sessions or consultations held between CAC and FMOJ. • Whether the draft has been circulated to NUPRC, NEITI, NEPZA, MCO, and other named agencies for input (Yes/No, with date).
8. Convene a multi-agency consultative process to validate the draft instrument and agree on a cross-sectoral BO data alignment framework. | | | • A multi-agency consultative session convened with sector regulators including NUPRC, NEITI, NEPZA, MCO, NFIU, BPP, and NRS to review the draft instrument and agree on alignment requirements. . A cross-sectoral BO data alignment framework produced, specifying harmonised identifier standards, disclosure protocols, and submission requirements for each agency. . A defined transition period agreed upon, with agency-specific compliance milestones documented. A consultation report produced, capturing agency positions, commitments, and outstanding concerns. | Number of multi-agency consultative sessions held. • Number of sector regulators that formally participate in the consultative process. • Whether a cross-sectoral BO data alignment framework has been produced and agreed upon (Yes/No, with date). • Whether agency-specific transition timelines have been documented and shared (Yes/No, with date). Whether a consultation report has been produced and made available to OGP stakeholders (Yes/No, with date).
9. Finalise, gazette, and communicate the executive order or ministerial regulation and monitor agency compliance with its requirements through to 2029. | June 2027 | January 2028 | • The executive order or ministerial regulation signed, gazetted, and publicly accessible. Formal communication of the instrument to all named agencies through official circulars and implementation guidance. • An annual compliance review mechanism established, with CAC tracking and reporting on agency alignment progress each year from 2027 to 2029. At least one mid-term review conducted by 2028 to assess implementation gaps and trigger corrective action where agencies are non-compliant. | Whether the instrument has been signed and gazetted (Yes/No, with date and Federal Gazette reference). Number of agencies that receive formal communication and implementation guidance from CAC. • Number of agencies that complete alignment of their BO data protocols with CAC's published standards within the transition period. Number of annual compliance review reports produced by CAC. • Whether a mid-term review has been conducted and its findings published (Yes/No, with date). • Number of corrective actions initiated against non-compliant agencies, with documented outcomes.