By Omoruyi ‘Uyilaw’ Edoigiawerie
Every digital transaction begins with a deceptively simple question: Who are you?
Whether opening a bank account, accessing healthcare, registering a business, paying taxes or signing a contract electronically, the answer to that question determines whether trust exists between parties who may never meet. In the digital economy, identity is no longer merely an administrative record; it is economic infrastructure.
This is why the National Identity Management Commission (NIMC) Act 2026 deserves careful attention. More than an amendment to Nigeria’s identity management regime, the Act represents one of the country’s boldest attempts to establish the legal architecture for a trusted digital economy. It seeks to move Nigeria beyond identity registration towards an integrated ecosystem in which digital interactions can be authenticated securely, efficiently, and at scale.
Its ambition is commendable.
For decades, Nigeria’s identity ecosystem has been characterised by fragmentation. Government agencies maintained separate databases. Financial institutions developed independent verification systems.
Businesses repeatedly collected the same customer information, while citizens endured multiple registration exercises for different public services. The result was duplication, inefficiency, higher compliance costs and increased exposure to fraud.
The NIMC Act 2026 attempts to change that narrative by positioning digital identity as a foundational layer of Nigeria’s Digital Public Infrastructure. Properly implemented, it could simplify public service delivery, improve financial inclusion, strengthen electronic commerce and enhance confidence in digital transactions.
For the private sector, the commercial implications are significant.
Banks, fintech companies, insurers, telecommunications providers and digital platforms all rely heavily on identity verification. A more interoperable identity ecosystem has the potential to reduce customer onboarding costs, improve fraud detection, strengthen Know Your Customer processes, and facilitate innovation across multiple sectors.
The legislation also reflects an important policy reality. As economies become increasingly digital, trust becomes a competitive advantage. Countries that can provide reliable digital identity systems often attract greater investment, enable faster innovation and deliver public services more efficiently. In that regard, the Act is undoubtedly a step in the right direction.
Yet ambitious legislation should not be mistaken for guaranteed success.
The true measure of the NIMC Act will lie not in its aspirations but in its execution. Indeed, several important questions remain unanswered.
The first concerns institutional concentration.
By designating NIMC as the Root Certification Authority for Nigeria’s digital trust infrastructure, the Act centralises significant authority within a single institution. While this promises consistency and standardisation, it also introduces systemic risk.
Every critical digital ecosystem has a single point whose resilience determines the stability of the whole. If that institution suffers operational failures, governance deficiencies, or cybersecurity breaches, the consequences could simultaneously reverberate across banking, telecommunications, public administration, and electronic commerce.
The challenge, therefore, is not simply building a trusted institution. It is ensuring that the institution itself remains worthy of that trust.
Equally important is the question of data governance.
The Act aligns itself with the Nigeria Data Protection Act 2023, reinforcing the principles of lawful processing and privacy. That alignment is both necessary and welcome. However, citizens are increasingly concerned with what legislation promises and less with what institutions actually do.
How will sensitive identity information be shared across agencies? What independent oversight mechanisms exist when breaches occur? How quickly will affected individuals be notified? What remedies will be available where personal information is unlawfully accessed or misused?
These questions cannot be answered by statutory language alone. They require transparent institutional practice.
There is also the risk of digital exclusion.
A modern identity system should expand economic participation rather than inadvertently restrict it. Millions of Nigerians remain outside the formal digital ecosystem for reasons ranging from geography and infrastructure deficits to socio-economic barriers.
As digital identity increasingly becomes the gateway to banking, healthcare, education, and government services, policymakers must guard against creating a system in which the absence of digital credentials effectively translates into exclusion from economic life. Inclusion should remain the defining objective of digital identity policy.
Another challenge lies in institutional coordination.
Nigeria’s regulatory landscape is populated by agencies with overlapping responsibilities and historically independent systems. While the Act rightly envisions interoperability, technology alone cannot eliminate institutional silos.
Genuine interoperability requires cooperation, clear governance frameworks and sustained political commitment. Otherwise, the country risks creating another ambitious framework that struggles to achieve practical integration.
Cybersecurity presents an equally compelling concern.
As Nigeria consolidates identity infrastructure, it simultaneously creates a more attractive target for sophisticated cybercriminals. The success of the new framework will therefore depend as much on investment in cybersecurity, digital resilience, and incident response capabilities as on the legal provisions that establish it. In the digital economy, trust is built not only by preventing attacks but also by responding effectively when they inevitably occur.
Perhaps the greatest lesson is that legislation cannot manufacture public confidence.
Trust is earned through consistent institutional behaviour, accountability and transparency over time. Parliament can establish legal frameworks. Regulators can issue guidelines. Technology can facilitate secure authentication.
But public confidence ultimately depends on whether citizens believe that their information will be handled responsibly and their rights respected. That confidence must be earned every day.
The NIMC Act 2026 therefore presents Nigeria with both an opportunity and a responsibility.
The opportunity is to build one of Africa’s most robust digital identity ecosystems, one capable of supporting innovation, attracting investment and improving public service delivery. The responsibility is to ensure that efficiency does not come at the expense of privacy, that centralisation does not weaken resilience, and that digital transformation remains genuinely inclusive.
If implemented thoughtfully, the Act may become one of the defining pillars of Nigeria’s digital economy. If implementation falls short, however, it risks becoming another example of ambitious legislation constrained by institutional realities.
The future of Nigeria’s digital economy will not be determined simply by whether we can identify people more efficiently. It will be determined by whether we can build institutions that citizens, businesses and investors trust. In the end, identity may indeed be infrastructure. But trust must still be earned.
