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| Nigeria Communications Commission |
Nigeria’s digital economy is expanding at a remarkable pace, yet a recent survey by the Nigerian Communications Commission (NCC) has exposed a significant readiness gap among telecommunications and internet service licensees for implementing the 2026 Internet Code of Practice (ICOP). Only two of the 19 licensees surveyed reported full readiness, highlighting challenges in cybersecurity, artificial intelligence (AI) governance, and broader stakeholder engagement at a time when data consumption and broadband adoption are surging.
The findings, presented by Dr. Ibiso Kingsley-George, the NCC’s Head of Internet Governance, at the inaugural NCC Internet Governance Symposium 2026 held on Thursday, October 15, in Lagos, underscore the tension between rapid technological adoption and the institutional capacity needed to manage it responsibly. Nine licensees indicated partial preparedness, while five admitted they were not ready. The readiness data covered 16 of the 19 surveyed licensees, leaving three outside the disclosed categories.
The survey drew 47 responses from stakeholders across industry, academia, and civil society, including seven mobile network operators, five internet service providers, and 12 academic institutions. Beyond compliance shortfalls, it revealed limited participation in internet governance processes. About 53 percent of respondents had engaged with the Nigeria Internet Governance Forum (NIGF), 40 percent had attended no internet governance events, and five organisations reported zero engagement. Thirty-four percent were unfamiliar with the permanent mandate of the Internet Governance Forum. The NCC attributed these gaps to inadequate awareness, lack of internal organisational mandates, and a perception among some stakeholders that internet governance is not directly relevant to their operations.
Context: A Code Designed for a More Complex Digital Era
The Internet Code of Practice 2026, issued on 13 February 2026 under Section 70 of the Nigerian Communications Act 2003, replaces the 2019 version and significantly expands regulatory reach. While the earlier code focused primarily on Internet Access Service Providers (IASPs), the updated framework applies to a broader set of “impacted entities,” including online and digital communications platforms, digital service providers, and application service providers operating within the NCC’s purview.
Key provisions address traffic management (with rules against blocking or discriminating against lawful content except for reasonable network management), customer data protection (including a 48-hour breach notification window to both customers and the Commission, with a possible preliminary notice followed by a full update within 14 days), unlawful content handling (24-hour compliance with takedown notices), child online safety (parental controls, multilingual guidance, and default opt-in settings for minors), and AI deployment. Internet Access Service Providers must notify the NCC before deploying AI tools related to network management or customer engagement, detailing affected services, timelines, and impacts, while also informing subscribers—especially where non-human interfaces are used for complaints or redress.
The Code also requires applicable platforms to submit Community Rules aligned with Section 146 of the Nigerian Communications Act within six months of issuance, followed by bi-annual reporting, and establishes a Designated Online Governance Officer (DOGO) at the NCC as a focal point for harmful content and related issues. Implementation followed a phased approach: a 90-day gestation period, a further compliance window, and full monitoring and enforcement beginning around August 2026.
Guidance Notes accompanying the Code clarify expectations, though industry players have continued to seek more practical tools.
These requirements arrive against the backdrop of explosive growth in Nigeria’s digital ecosystem. Broadband penetration rose to 57.4 percent by July 2026 (with subscriptions around 124.4 million), climbing further toward 58 percent in subsequent months, while active internet subscriptions exceeded 157–158 million. Data consumption surged dramatically—reaching about 1.66 million terabytes in July and 1.76 million in August 2026, with year-on-year increases approaching 47 percent in some periods and H1 2026 total usage estimated at 8.52 million terabytes (valued at roughly N3.67 trillion). Yet fixed fibre-to-the-home connections remain limited (hundreds of thousands rather than millions), underscoring reliance on mobile networks and the need for resilient infrastructure and governance.
AI: High Adoption, Lagging Oversight
Artificial intelligence stands out as a critical pressure point. The survey found that 73 percent of respondents were already using or piloting AI, yet only 39 percent had an approved AI policy and just 34 percent applied human oversight. Support for transparency was near-universal: 94 percent agreed consumers should be informed when interacting with AI systems. Opinions diverged on method, however, with 40 percent preferring periodic reporting over pre-deployment notification.
This imbalance—rapid deployment without corresponding governance—raises questions about accountability, bias, privacy, fraud risks, and the protection of vulnerable users, including children.
Engr. Abraham Oshadami, NCC Executive Commissioner for Technical Services (representing Executive Vice Chairman Dr. Aminu Maida), emphasised the point at the symposium: the growing influence of AI on learning, work, communication, and services necessitates multi-stakeholder cooperation. “These questions cannot be answered by one institution alone. The answer requires informed dialogue and cooperation across the communication sector and beyond it,” he said.
He noted that national, regional, and global Internet Governance Forums demonstrate the value of diverse voices and that Nigeria’s communications sector can contribute practical experience while translating global outcomes into local action.
Cybersecurity, online safety and child protection, data protection and cross-border data flows, and AI governance ranked as Nigeria’s top internet governance priorities for 2026 and 2027. The Cyber Resilience Framework for the Nigerian Communications Sector complements the Code by focusing on infrastructure resilience, while the ICOP targets safer online behaviour and platform accountability.
Addressing the Gaps: Working Group, Guidelines, and Workshops
In response, the NCC formally launched its Internet Governance Working Group at the symposium to create a sustained platform for collaboration among industry, government, academia, the technical community, and civil society. The Commission plans to publish clearer implementation guidelines, frequently asked questions, and reporting templates for the Internet Code of Practice. Workshops will target operators lagging in readiness, while the working group aims to close participation gaps and strengthen the sector’s contribution to national and international discussions, including issues around the .ng domain and global policy.
Nearly all surveyed organisations (46 of 47) expressed willingness to join future consultations, suggesting latent interest that structured engagement could convert into active involvement.
Broader Implications and the Road Ahead
The survey findings illustrate a classic challenge in emerging digital economies: technology and usage scale faster than policy frameworks, organisational capacity, and cultural buy-in. Nigeria’s internet governance ecosystem benefits from existing multi-stakeholder platforms such as the NIGF and West Africa Internet Governance Forum, yet awareness and internal mandates remain uneven. For licensees, the practical hurdles include mapping existing systems against new obligations (especially AI notification and data-breach processes), designating focal persons to liaise with the DOGO, updating terms of service, and building evidence of compliance.
From a regulatory perspective, success will hinge on the clarity and practicality of forthcoming guidelines, the consistency of enforcement, and the ability of the working group to move beyond dialogue into coordinated action. Overlaps with other frameworks—such as the Nigerian Data Protection Act’s 72-hour breach notification window versus the Code’s 48-hour rule—will require careful coordination by operators.
For consumers and the wider economy, stronger implementation of the Code could enhance trust in digital services at a moment when more Nigerians are relying on the internet for education, commerce, finance, and daily communication. Weak readiness, conversely, risks uneven protection, potential enforcement actions, and slower progress toward a safer, more inclusive digital environment.
The NCC’s immediate task is translating symposium discussions and survey insights into concrete support measures. Industry operators, for their part, face a clear choice: treat the Code as a compliance checklist or as an opportunity to embed responsible practices into operations that are already heavily dependent on AI and data-intensive services.
Bridging the readiness gap will determine whether Nigeria’s digital expansion is matched by the governance structures needed to sustain it.
Samuel O. Sulaimon is the founder and Editor-in-Chief of Naijapiz. He covers News, Sports, Finance, Faiths, Education, Politics and Technology.
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