hlola is opening to new organisations in stages.Join the waitlist

Nigeria · Compliance

NDPA 2023 compliance guide for Nigerian organisations

What the Nigeria Data Protection Act, 2023 requires: the principles, lawful bases, data controllers of major importance, DPIAs, breach reporting and the NDPC's enforcement powers.

3 min readReviewed

Who the Act applies to

The Nigeria Data Protection Act, 2023 applies to processing of personal data by controllers and processors domiciled or operating in Nigeria, and to those outside Nigeria who process the personal data of data subjects in Nigeria. The NDPC's General Application and Implementation Directive (GAID) sets out how the Act is applied in practice.

The core obligations

ObligationWhere in the Act
Processing principles: fairness, purpose limitation, minimisation, accuracy, storage limitation, securitySection 24
A lawful basis for every processing activity, including consentSection 25
Data protection impact assessment for high-risk processingSection 28
Data protection officer for data controllers of major importanceSection 32
Rights of data subjects, including access, rectification, erasure and objectionSections 34 to 38
Security and breach notification within 72 hoursSections 39 and 40
Conditions for cross-border transfersSections 41 to 43
Registration of data controllers and processors of major importanceSection 44

Data controllers of major importance

The Act imposes extra duties on data controllers and processors of major importance: those the NDPC designates by the volume or sensitivity of the data they process, or their value to the economy. They must register with the NDPC, appoint a DPO and, under the GAID, file annual compliance audit returns.

Penalties

Under section 48, the NDPC can impose a remedial order and a penalty. For a data controller or processor of major importance, the higher maximum is the greater of ₦10 million or 2% of annual gross revenue in the preceding financial year. For others, the standard maximum is the greater of ₦2 million or 2% of annual gross revenue.

hlola loads the NDPA's controls for Nigerian entities, with the 72-hour breach clock and rights deadlines built in. See the NDPA in hlola.

Common questions

Did the NDPA replace the NDPR?

The Nigeria Data Protection Act, 2023 is now the primary law. The NDPC's General Application and Implementation Directive sets out how it is applied; the NDPR remains relevant only where it is consistent with the Act.

Who enforces the NDPA?

The Nigeria Data Protection Commission (NDPC), established by the Act.

What is the maximum NDPA fine?

For data controllers and processors of major importance, the greater of ₦10 million or 2% of annual gross revenue; for others, the greater of ₦2 million or 2% of annual gross revenue.

This guide explains the law in general terms and is not legal advice. Laws, regulations and regulators' guidance change; confirm how they apply to your organisation with qualified counsel. Last reviewed 25 October 2026.

See your own readiness.

hlola loads your country's law with its controls, deadlines and evidence before your first sign-in. Thirty minutes, on your regulator.