NIGERIA Trends and Developments Contributed by: Chiagozie Hilary-Nwokonko, Chukwuyere Ebere Izuogu and Priscilla Bidemi Ben-Okoh, Streamsowers & Köhn
and encouraging long-term investment. Stakehold - ers also continue to advocate for greater transpar - ency through the publication of reasoned decisions together with proportionality and predictability in filing fees. Although no confirmed changes to the merger fee framework had been publicly announced at the time of writing, discussions concerning fee reform are likely to remain relevant as Nigeria competes for investment within the wider African market. Regionally, the operationalisation of the ECOWAS Regional Competition Authority (ERCA) may increas - ingly require transaction parties to co-ordinate merger strategy across multiple jurisdictions. Where parallel filings become necessary, parties should plan care - fully for: • consistent economic narratives across jurisdic - tions; • co-ordinated transaction timelines and conditions precedent; • disciplined interim conduct pending regulatory approvals; and • alignment between national and regional competi - tion obligations. More broadly, the trajectory of Nigerian merger control suggests a gradual transition from a relatively proce - dural notification regime towards a more integrated system of market governance in which competition regulation, consumer protection, digital conduct and data governance increasingly operate as intercon - nected regulatory objectives. The next phase of Nigerian competition law develop - ment will likely depend not only on the FCCPC’s sub - stantive enforcement choices, but also on the quality of institutional co-ordination, transparency, economic sophistication and the credibility of post-merger com - pliance oversight. Conclusion During 2025–2026, Nigeria’s merger control regime continued to evolve in both scope and institutional confidence, with broader cross-sector relevance and increasing sensitivity to digital, consumer-facing and data-driven theories of harm. The publication of at least 46 merger matters by the FCCPC since our
last publication, together with the continuing promi - nence of simplified procedure filings and cross-border transactions involving Nigerian market connections, demonstrates that transaction activity has remained resilient despite ongoing macroeconomic pressures. For transaction parties, this combination of sustained filing activity and broader regulatory scrutiny makes the quality of the competition narrative, together with the credibility of post-closing governance and compli - ance arrangements, increasingly important. The broader trajectory of Nigerian merger control suggests a gradual transition from a relatively proce - dural notification regime towards a more integrated framework of market governance in which competi - tion law, consumer protection, digital regulation and data governance increasingly converge. The practical implication is that merger review in Nigeria is becom - ing progressively less concerned solely with whether transactions increase concentration and increasingly concerned with how market power may subsequent - ly be exercised, particularly in consumer-facing and data-intensive markets. The central strategic imperative is therefore early and evidence-based regulatory planning. Parties should map approvals across relevant agencies, assess juris - dictional questions at an early stage, and treat consum - er outcomes, complaints history and data governance as core transaction considerations rather than periph - eral compliance issues. Where remedies are likely to arise, they should be designed from the outset with operational realism, monitoring mechanisms and gov - ernance accountability in mind. Even in the absence of extensive published decisional practice, merger con - trol in Nigeria has clearly become both a core transac - tion risk and a broader strategic governance issue for boards, investors and transaction advisers. Ultimately, the future effectiveness and credibility of Nigerian merger control will depend not only on the strength of substantive enforcement, but also on the development of transparent decisional practice, insti - tutional co-ordination, economic sophistication and proportionate regulatory oversight capable of balanc - ing consumer welfare, market contestability and long- term investment incentives.
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