By Ifeoma Ben, LLM, MBA
In an era where identity underpins access to services, Nigeria’s digital ID ecosystem, centred on the National Identification Number (NIN), is transforming civic inclusion, financial access, and public service delivery. This article provides a comprehensive overview of the National Identity Management Commission’s (NIMC) progress, key challenges, data protection considerations, and the evolving role of the legal profession in shaping a trusted digital identity framework.
NIMC’s Journey Toward Universal Digital Identity
The National Identity Management Commission (NIMC), established under the NIMC Act of 2007, oversees Nigeria’s national ID system, assigning unique NINs linked to biometric and demographic data. As of early 2025, over 122 million Nigerians have been enrolled with NINs, representing nearly 49% growth within two years, which brings the nation closer to achieving its universal ID coverage targets.
In 2024, Nigeria began issuing the next-generation General Multipurpose Card (GMPC), a multi-purpose credential compliant with ICAO travel standards. GMPCs incorporate QR codes for secure verification and integrate financial functionalities by partnering with banks and fintech platforms, thereby extending the card’s utility in both government and commercial ecosystems.
Inclusion Gaps, Data Integrity & Operational Bottlenecks
Despite progress, inclusion gaps persist. A UNICEF-supported report found that only 18% of Nigerians had a NIN by 2024; children under five in rural and poor communities are particularly underserved, with birth registration rates as low as 7% in some areas. Logistical hurdles, including inconsistent mobile enrollment, high correction fees, and localised corruption, further inhibit universal coverage.
Other core challenges include fragmentation across government-issuing bodies and limited interoperability among databases (e.g., NIMC, National Population Commission, voter registration systems), which undermines identity trust and inflates costs.
Legal and Data Protection Issues
The 2023 Nigeria Data Protection Act (NDPA), supported by the National Data Protection Commission, establishes robust legal guardrails for personal data, including biometric and civil registration information. It mandates breach reporting, transparent consent mechanisms, and cross-border data safeguards, with penalties up to 2% of annual turnover.
Given NIN’s role, especially its linkage to SIM cards, legal professionals must ensure compliance with NDPA/NDPR, audit data usage practices, and enforce data subject rights. The NDPC now oversees the enforcement and registration of major data processors, reinforcing accountability across government and private sector partnerships.
Implications for Digital Access & Civic Inclusion
NIN linkage has become a prerequisite for access to essential services such as SIM registration, cash transfer programs, social welfare, and mobile banking. This linkage amplifies opportunities for poverty reduction and digital inclusion, but also heightens the risk of exclusion if underserved populations cannot easily enrol.
To address these challenges, stakeholders emphasise the deployment of mobile enrollment units, partnerships with community leaders, and reduced sanctimony in registration fees. Legal reforms to curtail corruption and improve transparency are also viewed as essential.
The Role of the Legal Profession
Lawyers and legal advisors have become crucial actors in the digital ID ecosystem. Key responsibilities include:
• Advising NIMC and government agencies on drafting and implementing binding ID and civil registration legislation.
• Developing data-sharing agreements, consent frameworks, and cross-institution data governance protocols.
• Ensuring compliance with NDPA privacy and security standards through operational audits and breach response guidelines.
• Protecting citizen rights through legal recourse for identity theft, unauthorized NIN issuance, or wrongful exclusion.
• Supporting regional interoperability efforts in line with AU and ID4D strategies to foster cross-border recognition and economic integration
Conclusion
Nigeria’s digital ID journey has achieved remarkable scale, yet challenges of inclusion, privacy, and system integrity remain pronounced. Expanding access and ensuring accurate, trusted identity verification demands legal foresight, regulatory coherence, and community trust. As the foundation of Nigeria’s digital economy and governance, NIN and its associated infrastructure must evolve in line with constitutional rights and data protection imperatives. For lawyers, this means shaping policy, protecting rights, and ensuring that national identity becomes a tool for empowerment, not exclusion.
Ifeoma Ben is a Partner at The Law Suite and the Editor-in-Chief of Lawhauz Magazine and can be reached on 08033754299
