President Bola Tinubu last month took a defining step to modernise Nigeria’s digital ecosystem by assenting the National Identity Management Commission (NIMC) Act 2026 into law. This landmark legislation represents his administration’s desire to enhance digital transformation, strengthen national security and position the country for a future driven by innovation, trust and inclusion.

The new law, which repeals the outdated NIMC 2007 status, highlights the most significant overhaul of Nigeria’s identity management framework since the commission was established nearly two decades ago. While a legal framework is a plausible step, realistically, is a new law enough on its own to ensure the seamless enrollment of the over 100 million Nigerians and legal residents still locked out of the system and adequately protect citizen data, given the commission’s other protracted hurdles? The answer remains extremely complex and convoluted.

Regardless, the significance of this law cannot be overemphasised as it reinforces the National Identification as the cornerstone of identity verification and authentication across the country. Its implementation would enable faster and more secure identity verification, strengthen the protection of citizens’ data, improve cybersecurity, improve interoperability across government and private-sector frameworks, enhance ease of doing business and provide a robust foundation for Nigeria’s digital economy and long-term national development.

It is against this backdrop that Abisoye Coker-Odusote, Director-General, National Identity Management Commission (NIMC), stated that the law provides the legal basis for a robust National Public Key Infrastructure (PKI), supports digital authentication, digital signatures, enhance trust in digital transactions, protect Nigerians in an increasingly connected economy and ensure that vulnerable and underserved populations have access to legal identity, enabling them to participate fully in social, economic and financial opportunities while providing the legal basis for NIMC to become the single root of trust (Root Certificate Authority) for all government transactions.

While the passage of this law has been widely celebrated, the government has termed it historic, just as NIMC labeled it as the foundation of a digital nation. However, critical challenges remain. Major questions persist over who will secure 200 million existing citizen records, the seamless capture and funding strategy for enrolling the remaining over 100 million Nigerians, and what measures will prevent this law from turning into an instrument for surveillance and systematic exclusion. It is as such pertinent to state that this law, though necessary, is incomplete owing to the underlisted flaws that could undermine it.

The Enrollment Hurdles

National Identity Management Commission (NIMC) is now backed by law. However, the harder part of the task starts now. Capturing the over 100 million more Nigerians and legal residents into its database remains another kettle of fish. In April last year, NIMC reported that it has successfully enrolled over 117.36 million Nigerians as of February, 2025. The UN global population forecast 2024 puts Nigeria at 223.8 million. These figures leave 106.44 million people outside its system.

Seamless capturing or enrollment means that every citizen, from a child in Delta to a herder in Kebbi, can get NIN within 10-20 minutes, for free, with correct data and without bribery. This, I strongly believe, is still not feasible, given the country’s peculiar challenges of internet infrastructure, power, bad roads, geography and distance. NIMC has less than 1,200 efficient enrolment centres across the 774 Local Government Areas across the country as at 2024. This is grossly inadequate. Similarly, more than half of Nigeria’s roads are not paved, and during the rainy season, several communities are cut off. Needless to mention that the country is battling chronic power outages, and enrolment machines need power and stable internet, thus making enrolment a city affair as rural communities, borders, and IDP areas are left out. This, to a large extent, has made enrolment a referendum on the commission.

The Unfunded Mandate and Human Capacity

The act orders national and universal enrollment without a guaranteed funding formula. Coupled with this is the fact that the meagre budgetary allocations for NIMC are often not fully released. To fully enrol every Nigerian as directed by the president before the end of 2026, NIMC requires systematic funding, staffing and enrollment units in rural and conflict-laden areas. Without a dedicated line in the Federation Account, we will have a replay of the 2021 scenario: 12-hour queues, touts charging ₦5,000 to access enrolment and unimaginable data errors. Corruption, burnt-out staff and slow enrolment will be the order of the day.

The Challenge of Duplication and Data Quality

Currently, the commission is grappling with several cases of duplicate enrollment and data quality issues. NIMC Technical Audit in 2023 revealed a high rate of duplicate enrollments due to name variations and poor biometric capture. A case in point was in 2019 when INEC had to clean up its voter register by removing about 2.7 million duplicate voters from the 84 million registered voters in preparation for the election. Therefore, if we do not clean the existing data first, the new 106.44m will inherit the same errors. The whole point of “one person, one ID” would become a mirage.

The Challenge of Security and Conflict Zones

Nigeria is currently grappling with insecurity. The common forms of insecurity in Nigeria include Terrorism, insurgency, banditry, ransom kidnappings, farmers/herdsmen conflicts, unknown gunmen attacks, robbery attacks, religious clashes, and ethnic/tribal clashes. In the North-East, North-West and North Central for instance, Boko Haram insurgency predominates. Currently, over 20% of Nigeria is affected by insecurity. Zamfara, Katsina, Borno, Benue, Plateau, and Niger currently house over 3.2 million IDPs. According to the data made available from Nextier’s Nigeria Violent Conflicts database, no fewer than 279 persons were kidnapped across Nigeria in May 2026, with 156 recorded violent incidents that resulted in 842 deaths. With these gory figures, no enrollment team would want to visit local communities or villages in many conflict zones, thus leaving many of the residents without NIN.

On a final note, it is expedient to highlight that the new NIMC law can certainly be President Tinubu’s biggest legacy if it can scale the above-mentioned hurdles or challenges, help security agencies trace and neutralise criminal and terrorist gangs and achieve much more. However, a law is nothing until it is tested. This is so because once the over 200 million fingerprints and faces of Nigerians and legal residents are captured in one database, we certainly cannot go back and rewrite the rules. We must fix the law now, while we still can.