The Kiet Brief | September 2026
Introduction
September was a busy month for business regulation in Nigeria. The CBN cut the Monetary Policy Rate by 350 basis points, and a new interest regime for late tax payments took effect on 1 October. The SEC proposed rules that could reach offshore forex and CFD platforms serving Nigerians. In energy, NUPRC set a drill-or-drop deadline and prepared a new licensing round, while the Dangote Refinery launched Africa's biggest-ever IPO.
The September edition of The Kiet Brief brings these developments together in one place, across corporate and commercial law, capital markets, tax and banking, competition, data protection, intellectual property, startups and venture capital, oil and gas, power, mining, telecoms and clean tech.
CORPORATE & COMMERCIAL
FRC Tightens Assurance Firm Register Regime
On 14 September, the Financial Reporting Council published updated National Registers covering valuation firms, actuarial firms and other assurance service firms. The Council previously declared that only firms appearing on the relevant register are legally permitted to undertake or continue audit and assurance engagements within the regime, and has said the registers will be updated weekly.
Court Convicts 21 Companies for Unlicensed Investment Schemes
Justice Anyalewa Onoja-Alapa of the Federal High Court, Lafia Division, convicted and sentenced 21 companies for operating without licences from the SEC.
CAPITAL MARKETS & SECURITIES
SEC Proposes Rules to Regulate Offshore Forex and CFD Platforms
The SEC published proposed rules on Online Forex Trading and Contracts for Difference, which expressly contemplate application to offshore entities whose activities show an intention to serve Nigerian residents. Relevant connecting factors include listing Nigeria as a supported jurisdiction, marketing through Nigerian influencers or affiliates, and maintaining representatives, introducing brokers or customer support channels in Nigeria. The consultation window has closed, and a final framework is awaited.
SEC Sets October 15 Deadline for Sustainability Reporting Plans
The SEC directed all public companies and Significant Public Interest Capital Market Operators to submit implementation plans for the adoption of IFRS S1 and IFRS S2 by 15 October 2026. Plans must cover board oversight, gap assessments, data systems and internal controls, with mandatory adoption scheduled for accounting periods beginning on or after 1 January 2028.
TAX, BANKING & FINANCE
CBN Cuts Policy Rate by 350 Basis Points
At its 307th meeting on 21 and 22 September, the MPC reduced the Monetary Policy Rate from 26.5 per cent to 23 per cent. It retained the Cash Reserve Requirement at 45 per cent for Deposit Money Banks and 16 per cent for Merchant Banks. Borrowers on benchmark-linked facilities should review their pricing terms.
New Interest Regime for Late Tax Payments Takes Effect October 1
The Nigeria Tax Administration (Interest on Late Payment of Tax) Order, 2026 sets interest on Naira liabilities at the MPR plus one percentage point, subject to a floor equivalent to the 364-day Treasury Bill yield, and at SOFR plus six percentage points for foreign currency liabilities. Interest accrues daily, and the existing 10 per cent late payment penalty remains separate.
Crypto Industry Pushes Back on NRS Virtual Asset Tax Guidelines
On 1 September, the Virtual Asset Service Providers Association submitted a formal position paper to the NRS on Information Circular No. 2026/21. The paper challenges the proposed 1.5 per cent stamp duty on certain token and fiat conversions, the 1 per cent withholding tax on gross disposal proceeds, and the taxation of staking, mining and DeFi rewards. The Guidelines remain in force pending any revision.
COMPETITION & CONSUMER PROTECTION
FCCPC Scrutinises Uber's Exit From Nigeria
Uber ceased Nigerian operations with effect from 2 September 2026, and FCCPC Chief Executive Tunji Bello confirmed the Commission was examining the manner of the exit, with attention to whether obligations to customers remained outstanding. The move signals that a market exit by a consumer-facing platform is itself subject to regulatory oversight.
NCC Compensation Framework Enters Second Payment Cycle
Airtel Nigeria commenced a second round of airtime compensation to subscribers affected by network failures between February and April 2026 under the NCC's consumer compensation framework. Compensation is automatic and applies to both individual and corporate subscribers.
DATA PROTECTION & CYBERSECURITY
NDPC Commissions Africa's Largest Data Protection Authority Office
The NDPC's new Abuja headquarters was commissioned in September and described as the largest Data Protection Authority office in Africa.
NDPC Sets AI Governance Benchmarks at CAC Retreat
The NDPC presented AI governance benchmarks on integrating privacy into automated registries at the CAC Annual Retreat, which points to closer alignment between the company registry and the data regulator.
INTELLECTUAL PROPERTY
German Court Rules Against AI Music Generator Suno
The Munich Regional Court largely upheld GEMA's claims for injunctive relief, information and damages against Suno over AI training and outputs. The decision is a useful reference point for AI clauses in music and content contracts.
STARTUPS & VENTURE CAPITAL
US Firm Pigee to Take Controlling Stake in ShipAfrica
US logistics technology company Pigee agreed to acquire a controlling 55% stake in Nigerian logistics startup ShipAfrica in a cash-and-stock transaction to be completed in three stages over 18 months.
Aeon Raises $1m Pre-Seed for Critical Infrastructure Security
Nigerian cybersecurity startup Aeon raised $1 million in a pre-seed round led by Terra Industries, with participation from Resilience17, Kaleo, DFS Labs, Ajim Capital and Seedstars.
CASE LAW WATCH
ICC Tribunal Rejects Mambilla Claims Against Nigeria
An ICC tribunal rejected substantial claims by Sunrise Power and Transmission Company against Nigeria arising from the Mambilla Hydroelectric Power Project.
OIL & GAS
OB3 Pipeline Ready for First Gas, AKK Hits 95% Completion
NNPC reported that the $700m Obiafu-Obrikom-Oben (OB3) gas pipeline at 100% completion and ready for first gas following pre-commissioning at the River Niger Crossing, while the Ajaokuta-Kaduna-Kano (AKK) pipeline stands at 95%, with early gas targeted for Abuja before year-end. Together the projects are expected to unlock over 500 million standard cubic feet per day of additional gas supply for power generation, manufacturing and industry.
NUPRC to Launch Next Licensing Round in October, Eyes Twice-Yearly Cycle
NUPRC CEO Oritsemeyiwa Eyesan says the commission plans to open its next oil licensing round by early October, covering 13 unlicensed blocks carried over from the last round plus new deepwater, shallow-water and frontier onshore acreage. The commission wants annual (potentially twice-yearly) bid rounds going forward, targeting 300,000–600,000 bpd of additional output per round and $30–50 billion in new deepwater investment by 2030.
NUPRC to Introduce Crude Certificate Trading Platform
NUPRC is developing a compliance trading platform allowing crude producers who exceed their Domestic Crude Supply Obligation to trade certificates with export-focused producers, aimed at improving compliance with local refinery supply rules while cutting logistics costs through a netting mechanism.
NUPRC Enforces "Drill-or-Drop," Sets October 31 Deadline
NUPRC has given holders of licences from the 2020 Marginal Field Bid Round, 2022/2023 Mini Bid Round and 2024 Licensing Round until October 31 to disclose compliance status or risk non-extension, relinquishment and revocation. At least 62 awardees across the three rounds are affected, though the commission stressed the circular is an advisory, not a default notice.
NUPRC and Indonesia Target Energy Deals Ahead of Licensing Round
NUPRC held talks with Indonesia's Vice Minister of Foreign Affairs and state oil firm Pertamina, which is scouting Nigerian upstream assets ahead of the 2026 round as it seeks to lift its own output to 2.3 million bpd by 2030. Nigeria reiterated its 3-million-bpd-by-2030 target and noted 37 of 50 blocks from the last bid round have been awarded.
TotalEnergies, AMNI Reach FID on Ima Gas Field
TotalEnergies and AMNI International Petroleum took final investment decision on the Ima gas field offshore Nigeria, an $800 million project expected to generate roughly $4 billion in lifetime value.
Dangote Refinery Launches Africa's Biggest-Ever IPO
Aliko Dangote launched an IPO for Dangote Petroleum Refinery offering 4.1 billion shares at N525 each, open to retail investors buying as few as 10 shares. The refinery, which processes 700,000 bpd, aims to expand to 1.4 million bpd by 2029 through a $14.3bn investment programme; this marks a reversal from June, when the SEC had ordered a halt to premature IPO marketing.
FCCPC and NMDPRA Sign Competition Pact
The two regulators formalised an agreement to share market intelligence and coordinate enforcement against price fixing, cartel behaviour and market abuse across the petroleum value chain, alongside a separate NMDPRA push for 138 new competition regulations targeting infrastructure access and dominance abuse.
POWER & INFRASTRUCTURE
UAE and Nigeria Discuss 5,000MW Power Expansion
Power Minister Joseph Tegbe told UAE state media that Nigeria and the UAE are discussing raising Nigeria's generation capacity by roughly 5,000MW, with cooperation spanning financing, solar development and technical expertise. Nigeria's installed capacity stands at 13,625MW, but only about 5,000MW reaches the grid and 4,000MW reaches consumers.
Vertiv's $2.6bn AI Power Deal as Airtel Builds Lagos Data Centre
Vertiv agreed to acquire UtilityInnovation Group for up to $2.6 billion to expand data-centre power management as AI-driven electricity demand grows, coinciding with Airtel Nigeria's build-out of a 38MW hyperscale data centre in Eko Atlantic, Lagos, which will be Nigeria's largest.
Delta Targets 120MW Power Boost, Cuts Grid Reliance
Delta State is partnering with Supply Power to add 120MW to supply, building on an existing 8.5MW independent plant, and is courting investors to the Kwale Free Trade Zone to use the state's gas resources for local generation.
Nigeria Launches $300m DRE Fund; World Bank Adds $200m to DARES
NSIA, Africa50, SEforALL and the International Solar Alliance launched the $300 million Nigeria Distributed Renewable Energy Fund to scale mini-grids and standalone solar, aligned with the continent-wide Mission 300 goal. Separately, the World Bank approved $200 million in additional financing for the DARES off-grid programme, which targets 17.5 million Nigerians with new electricity access.
Minister Secures TBEA Commitment for Power Equipment Industrial Park
Following talks in Beijing, Chinese manufacturer TBEA committed to establishing a power and energy equipment industrial park in Nigeria, alongside accelerated delivery of transmission works expected to unlock over 2,000MW of stranded capacity.
SOLID MINERALS & MINING
Terra Industries Wins Lithium and Kaduna Mining Security Deals
Nigerian defence-tech firm Terra Industries closed $2 million in contracts to deploy 20 sentry towers and four drones across two lithium mining sites, its first commercial wins outside government contracts. It separately secured a $1 million deal with Anka Metals to protect the multi-metallic Jema'a Resource Project (gold, lithium, copper, nickel) in Kaduna State.
Nigeria-Australia Mining Skills Partnership Deepens
Nigeria and Murdoch University discussed the next phase of their Resource Industry Collaboration and Capacity Building Programme, which has trained two cohorts of 11 Nigerian mining officials since June 2025, with a third phase now planned.
Nigeria and US Sign Mineral Investment Pact
On the sidelines of UNGA, Solid Minerals Minister Dele Alake and US Deputy Secretary of State Christopher Landau signed an MOU covering geological exploration, mineral processing, refining and technical capacity. Alake stressed Nigeria wants local value-addition rather than raw-material exports; Nigeria holds 26 of roughly 60 minerals on the US critical minerals list.
CAPITAL MARKETS & CLIMATE FINANCE
NGX N-Zero Begins Corporate Climate Baseline Assessments
NGX Group's N-Zero initiative, run with DEG Impulse and Africa Foresight Group, has begun baseline climate-readiness assessments for participating companies including Access Holdings, Dangote Cement, UBA and Seplat. Over 50 companies have engaged with the programme, with 17 formally onboarded; the assessments are expected to conclude in September ahead of tailored support in October–November.
TELECOMS & DIGITAL INFRASTRUCTURE
Hotspot Wins World Bank-Backed Deal to Connect 500 Communities
Hotspot Network Limited will deploy telecom and broadband infrastructure, including 2G/4G, community Wi-Fi and renewable-powered sites, across 500 unserved communities under the $750 million DARES programme, which is separately targeting 1,350 mini-grids nationwide.
CLEAN TECH
Nigerian Startups Secure $450k from Africa Ecosystem Catalysts Facility
Trade Lenda and AirSmat became the first Nigerian companies funded by the $4 million AECF, managed by Village Capital with backing from the Dutch development bank FMO and RVO, sourced via Africa Fintech Foundry.
Biochar Industrial Group Raises $1.5m Pre-Seed
Founded by former Releaf Earth executives, Biochar Industrial Group raised $1.5 million led by Breega to scale its "Biochar-as-a-Service" model, converting agricultural waste from Nigerian food processors into carbon-removal credits.
Questions about any development in this brief? Our team can walk you through what it means for your business.
Kiet Business Attorneys
Lagos | Abuja
kietlaw.com
This publication is a general summary of legal and regulatory developments for information only. It is not legal advice, and you should seek specific advice before acting on any matter covered here.
