Regulatory overlap is becoming a serious issue as Nigeria builds its digital economy and introduces new rules on data, cloud infrastructure and technology. I recently contributed to Techcabal on how overlapping requirements from different regulators could affect banks, fintechs and payment companies. It is a subject I have seen from both the policy and the implementation side.
My experience includes developing Nigeria’s first Standard Certification Programme for Data Protection Officers and helping to develop the NDPC Strategic Roadmap and Action Plan. Both taught me the same lesson: good regulation goes beyond writing rules. It depends on institutional capacity, clarity and coordination. Rules are not an aim in themselves. They exist to produce results in a specific environment.
Regulatory Overlap Is Not the Problem
My concern is not an argument against regulation. Nigeria needs rules that protect people, manage risk and give businesses and investors confidence.
The problem is overlapping legitimate mandates without coordination. A bank, fintech or payment company does not experience government as separate institutional boxes. It faces financial regulation, technology requirements, data protection obligations and cybersecurity expectations all at once. The question is: do these requirements work together?
Where Mandates Intersect
Consider the Central Bank of Nigeria, NITDA and the Nigeria Data Protection Commission. The CBN has sector-specific responsibilities in finance. NITDA has a broader technology and digital infrastructure role. The NDPC oversees data protection. These mandates naturally intersect, because modern financial services run on technology infrastructure and personal data.
Debates often fixate on which regulator is superior, but that is not the most useful question. The better one is how these mandates can be coordinated so that businesses and citizens get clear, workable rules.
Data Localisation: A Worked Example
The data localisation discussion shows why this matters. Which data should be localised? The answer reaches well beyond the location of a primary database. Businesses must also consider production environments, backups, disaster recovery, cloud infrastructure and service providers.
When several institutions have a stake in these areas, the practical questions multiply. For example, what happens if one rule governs where backups may be held while another sets standards for the cloud providers hosting them? Who is responsible for which part of the arrangement? Businesses should not have to reconcile these requirements on their own. Regulatory uncertainty becomes a cost in itself.
Regulatory overlap rarely resolves itself. It needs deliberate attention.
Who Bears the Cost of Regulatory Overlap
Uncertainty does not fall evenly. Large institutions can usually absorb extra compliance work with dedicated legal and compliance teams. Smaller fintechs cannot. For them, unclear or duplicated requirements can mean delayed launches, higher costs and, sometimes, abandoned products.
That matters because Nigeria wants innovation, investment and entrepreneurship. The regulatory environment should make it easier, not harder, for responsible businesses to build.
Coordination, Not Superiority
In my contribution to the report, I argued for interagency collaboration rather than regulatory superiority. That does not mean weakening any institution’s mandate. It means recognising that the digital economy does not fit neatly inside institutional boundaries. A fintech does not operate only within financial regulation. A cloud environment does not belong to one policy area. Data protection cannot be separated from infrastructure, cybersecurity or digital services.
Where mandates intersect, businesses should not have to guess which regulator takes precedence. In practice, managing regulatory overlap could take several forms:
- A standing joint working group of the relevant regulators
- Memoranda of understanding that define where each institution’s responsibilities begin and end
- Joint guidance on issues like data localisation, issued before implementation deadlines
- Multi-agency participation in regulatory sandboxes
Some of this should already be happening, especially where new rules carry significant implementation deadlines. As AI, cloud computing, fintech, digital identity and cybersecurity converge, the need will only grow.
Regulation and Innovation Are Not Opposites
Good regulation supports innovation by creating confidence. Businesses know the rules. Consumers understand their rights. Investors have certainty. Technology providers know their responsibilities. That only works when frameworks are understandable, coordinated and practical.
Nigeria is building a more sophisticated digital economy, and its regulatory environment must keep pace. We need to protect personal data and national interests, manage technology and operational risks, and develop local digital infrastructure and capacity, without creating unnecessary complexity because institutions approach the same environment from different mandates.
Regulatory overlap is not necessarily a problem. It becomes one when there is no coordination around it. Nigeria does not need fewer regulators. It needs regulators whose mandates are clearly understood and whose responsibilities are properly coordinated.
The question is not simply whether we have the right regulations. We should also ask whether our regulatory institutions are working together effectively enough to make them work. As the digital economy grows, getting regulatory overlap right will matter more and more. That is where I believe the conversation needs to go next.
Author: Jide Awe
Science, Technology and Innovation policy advisor.
Nigeria’s Inaugural Tech Mentor of the Year
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