The rapid integration of artificial intelligence into socio-economic systems has
intensified global debates on the adequacy of existing legal frameworks to
regulate emerging technologies.
In Nigeria, while there is currently no dedicated artificial intelligence
legislation, the Nigeria Data Protection Act (NDPA) 2023 (hereinafter
referred to as NDPA 2023) establishes a comprehensive framework for the
regulation of personal data processing. This article examines the extent to
which the NDPA 2023 may already function as an indirect foundation for
artificial intelligence governance in Nigeria.
The analysis is grounded in key provisions of the NDPA. It explores how core
data protection provisions may influence the design, deployment, governance,
and oversight of AI systems that rely on personal data. Through practical
illustrations drawn from sectors such as fintech, recruitment, healthcare, and
digital platforms, the article demonstrates how these provisions intersect with
algorithmic decision-making and automated processing.
The article argues that while the NDPA 2023 was not designed as an artificial
intelligence statute, it may nonetheless provide an important conceptual and
legal foundation for AI governance in Nigeria. However, this foundation
remains incomplete and will likely require complementary regulatory
frameworks to adequately address the complex risks posed by advanced AI
systems. The paper recommends the adoption of a complementary AI governance framework in Nigeria that builds upon existing data protection
principles while addressing AI-specific concerns such as algorithmic
accountability, transparency, explainability, bias mitigation, human
oversight, and regulatory coordination. Ultimately, the article contends that
while the NDPA 2023 may not constitute a comprehensive AI governance
framework, it represents a significant starting point in Nigeria’s evolving
regulatory response to artificial intelligence.