Governing the Algorithm: <br> The Case for a Dedicated AI Act in Nigeria

Nigeria's National Artificial Intelligence Strategy (NAIS), launched in September 2025, is a serious and ambitious document. It sets a five-year roadmap for Nigeria's AI development, explicitly calls for a legal framework to govern AI, and acknowledges the governance risks of deploying AI without adequate regulation. This article takes the NAIS seriously, and on precisely that basis, argues that it is insufficient. A strategy is not a law. It creates no cause of action, assigns no liability, and empowers no court to provide relief to a citizen harmed by an AI system. Nigeria's existing legal architecture, principally the Nigeria Data Protection Act 2023 (NDPA), the Cybercrimes Act 2015 (as amended 2024), and sector-specific guidelines, addresses AI incidentally and incompletely. Two AI bills have been introduced in the House of Representatives. Neither has been enacted. No Nigerian court has directly adjudicated AI liability. The gap between AI deployment and legal governance is widening. This article makes the case for a dedicated Nigerian AI Act through a systematic comparative analysis of four jurisdictions: the European Union (mandatory, risk-based, horizontal legislation), Singapore (voluntary, principles-based, sector-layered governance), China (iterative, state-led, content-control-oriented regulation), and Canada (a cautionary study in legislative failure). It extracts from each jurisdiction the lessons and the warnings most relevant to Nigeria's regulatory context, institutional capacity, and economic development objectives. It then proposes a hybrid framework suited to those conditions. The article is candid throughout: where the NAIS is weak, it says so. Where the compared jurisdictions have failed, it says so. Nigeria's AI governance challenge is real, its window is narrowing, and the intellectual work of designing adequate legislation must begin now.