Feature/OPED
Banks’ N1.96trn Black Hole: Who Took the Loans, Who Defaulted, and Why the Real Economy Suffers
By Blaise Udunze
Nigeria’s banking sector has entered a season of reckoning. Eight of the nation’s biggest banks have collectively booked N1.96 trillion in impairment charges in just the first nine months of 2025 which represents a staggering 49 percent increase from the N1.32 trillion recorded in the same period of 2024.
Behind these figures lies a deeper question that speaks to the very soul of Nigerian finance on who received these loans that have now turned sour? Were they the small and medium enterprises (SMEs), entrepreneurs, and job creators that fuel real economic growth, or were they politically connected insiders and corporate giants whose failures are now being quietly written off at the expense of the public trust?
The Central Bank of Nigeria (CBN) is unwinding its pandemic-era forbearance regime, a policy that allowed banks to restructure non-performing loans and delay recognizing potential losses. It was a relief measure meant to protect the economy during the COVID-19 shock. But as the CBN begins to phase out this regulatory cushion, the hidden weaknesses in many banks’ balance sheets are now coming to light.
The apex bank has since placed several lenders under close supervisory engagement, restricting them from paying dividends, issuing executive bonuses, or expanding offshore operations until they meet prudential standards. Those that have satisfied the conditions are being gradually transitioned out ahead of the full forbearance unwind scheduled for March 2026. This shift, though painful, is forcing banks to confront the true state of their loan books and the picture emerging is anything but flattering.
A review of financial statements of Nigeria’s top listed banks reveals the distribution of impairment charges as of the third quarter of 2025.
– Zenith Bank Plc leads the pack with an eye-popping N781.5 billion in impairments, a 63.6 percent jump from N477.8 billion in 2024. Most of this amount to about N711 billion which occurred in the second quarter of 2025, driven by losses on foreign-currency loans and the end of regulatory forbearance. The bank’s gross loans declined by 9 percent to N10 trillion, and though its non-performing loan (NPL) ratio improved to 3 percent, that was largely due to massive write-offs.
– Ecobank Transnational Incorporated (ETI) followed closely, provisioning N393.7 billion, up 47 percent year-on-year. Inflation, exchange-rate volatility, and macroeconomic stress in Nigeria and Ghana all contributed to loan-quality deterioration. Its total loan book stands at N21.1 trillion, with a modestly improved NPL ratio of 5.3 percent.
– Access Holdings Plc posted impairments of N350 billion, representing a 141.5 percent surge year-on-year. About N255 billion of this came from loans to corporate entities and organizations, while the rest were loans to individuals. The bank cited changing macroeconomic conditions, inflationary pressures, and continued regulatory adjustments as the main culprits.
– First HoldCo reported N288.9 billion, up 68.6 percent from N171.4 billion a year earlier. The bank attributed the spike to revaluation losses and write-downs of legacy exposures in the energy and trade sectors. Notably, about N100 billions of this was incurred in the third quarter alone.
– United Bank for Africa (UBA) saw a dramatic improvement, cutting impairments from N123.5 billion to 56.9 billion, thanks to recoveries of N50.4 billion. The bank’s proactive loan-book management and collateral recoveries were credited for this performance.
– Guaranty Trust Holding Company (GTCO) posted N69.8 billion, up slightly from N63.6 billion last year. The group wrote off a key oil-and-gas exposure but maintained strong profitability, with pre-tax return on equity (ROAE) of 39.5 percent.
– Stanbic IBTC Holdings Plc recorded N11.6 billion, a sharp 80 percent decline year-on-year following recoveries of N16.3 billion on previously impaired loans.
– Wema Bank Plc, with N11 billion in impairments, reported one of the lowest provisioning levels in the industry, despite 30 percent loan growth.
Altogether, these eight banks have set aside almost N2trillion in provisions to cover potential losses, a sum roughly equivalent to Nigeria’s entire federal capital expenditure for 2025.
There have been recent claims of a modest level of loan growth that is not commensurate with the overall expansion of the banking system’s balance sheet. Data from MoneyCentral shows that the combined total loans of the nine banks stood at N65.37 trillion as of September 2025, representing a 7.42 percent increase from N60.86 trillion in 2024. This contrasts sharply with a 52.63 percent surge in combined loans recorded in the 2024 financial year and a 32.64 percent increase in 2023, according to data gathered by MoneyCentral.
The underlying question, therefore, is which sectors of the economy are actually benefiting from this reported loan growth?
The real puzzle behind these numbers is who actually received these loans that are now being impaired. While banks have long positioned themselves as engines of private-sector growth, evidence suggests that much of their lending goes to a narrow base of corporate borrowers, politically connected elites, and oil-and-gas companies. These sectors offer large-ticket deals and quick interest earnings but also carry enormous risk.
In contrast, the SME sector, which employs more than 80 percent of Nigeria’s workforce, continues to face credit starvation. Many small businesses are forced to rely on expensive informal loans or personal savings because banks deem them too risky. The pattern is clear that banks chase safety and short-term profits over inclusive growth. When their big corporate bets fail, they write them off through impairment charges, but the cumulative effect is that real economic activity suffers while the credit system grows more fragile.
Another dimension to the problem is the banking industry’s heavy investment in government securities. Over the past two years, Nigerian banks have channeled N20.4 trillion into treasury bills, bonds, and other fixed-income instruments, reaping risk-free returns rather than funding productive ventures. This “securities trap” is profitable for banks but disastrous for the economy. Instead of financing factories, farmers, or tech innovators, banks earn easy money by lending to government thereby crowding out private investment and weakening the transmission of credit to the real sector. When interest rates rise or currency values swing, the market value of these securities falls, forcing banks to record mark-to-market losses that translate into impairment charges. Thus, the same safety net that shields banks from loan risk ends up creating financial volatility of its own.
Beyond macroeconomic challenges, Nigeria’s banks are also grappling with homegrown problems like insider abuses, weak corporate governance, and ineffective risk management. Past crises in the banking sector, from the 2009 consolidation fallout to the 2016 oil-sector shock, reveal a consistent pattern: directors and senior executives often have outsized influence over loan approvals, sometimes extending credit to themselves or politically exposed entities without proper collateral or due diligence. These insider-related loans frequently turn toxic, hidden under layers of restructuring and accounting manoeuvres until a regulatory audit forces exposure.
The recent impairments may well reflect a new cycle of these historical sins as loans extended under pressure, influence, or misplaced optimism, now coming home to roost as the CBN tightens oversight. Corporate-governance codes exist, but enforcement remains uneven. Some banks continue to operate “relationship banking,” were loyalty trumps prudence. The lack of whistleblower protection, combined with weak internal-audit independence, further compounds the problem. Until boards and regulators impose real consequences for reckless lending, the system will continue rewarding the wrong behaviour and punishing taxpayers and shareholders in the long run.
At its heart, impairment is a measure of how well banks anticipate and manage risk. A rise in impairments signals that too many loans were made without properly assessing the borrower’s ability to repay, or that risk models failed to adjust to changing macroeconomic conditions. Several banks blamed their losses on exchange-rate volatility and inflation, but these are hardly new risks in Nigeria’s economic environment. The fact that impairments ballooned even as profits remained high suggests that risk-management frameworks were reactive rather than preventive which focused on compliance rather than foresight. In some cases, the sheer scale of provisioning, such as Zenith’s N781 billion or Access’s N350 billion, points to systemic underestimation of credit risk.
Every naira written off as an impairment represents not just a failed loan but a lost opportunity for the real economy. N1.96 trillion could have funded tens of thousands of new small businesses, millions of jobs, and critical infrastructure projects. Instead, these funds are trapped in the closed circuit of banking losses or vanish into opaque corporate failures. This has broader implications: as banks absorb losses, they tighten lending criteria, making it harder for genuine borrowers to access loans. High impairments signal instability, discouraging foreign investors and depositors, while credit flow dries up, productivity and job creation suffer. The result is a paradoxical economy where banks post impressive profits yet the productive sector languishes.
If there is a silver lining, it is that some banks, notably UBA, Stanbic IBTC, and Wema Bank are demonstrating improved loan-recovery strategies, more disciplined credit models, and a stronger focus on risk-weighted assets. Their experiences prove that impairment is not inevitable; it is the outcome of choices like governance, culture, and accountability. For others, the current round of provisioning should serve as a wake-up call to rethink their business models, diversify exposures, and strengthen compliance culture.
To its credit, the CBN’s forbearance unwind is a critical step toward transparency. By compelling banks to recognize their true loan losses and restricting dividend payouts until they meet prudential standards, the regulator is forcing a long-overdue cleansing of the system. However, reform must go deeper than technical compliance. The CBN must enforce public disclosure of insider-related loans, tighten penalties for concealment, and promote lending to productive sectors through targeted incentives. For instance, a tiered capital framework could reward banks that extend a higher proportion of credit to SMEs and manufacturing, while imposing stricter capital charges on speculative or insider-related lending.
Nigeria’s banking sector has shown resilience through crises, from the global financial meltdown to oil-price collapses. But resilience should not become an excuse for complacency. The N1.96 trillion impairment charges of 2025 are more than a balance-sheet adjustment; they are a mirror reflecting structural flaws in lending culture, governance, and the alignment between finance and development. To rebuild trust and relevance, banks must reorient lending toward real-sector growth, invest in credit analytics and risk intelligence that anticipate shocks, enforce transparency in board-level loan approvals and insider exposures, and collaborate with regulators to design sustainable credit frameworks for SMEs. Above all, there must be a moral recalibration of banking purpose from chasing short-term profits to fueling long-term national prosperity.
The spike in impairment charges does not mean Nigeria’s banks are collapsing. Rather, it signals an industry confronting its hidden fragilities. As the forbearance curtain lifts, the system has a chance to reset to clean up bad debts, rebuild credibility, and reconnect finance with development. But that opportunity will be wasted if the same patterns persist: insider lending, governance lapses, and a preference for easy returns over real investment. Until these issues are confronted head-on, the question will continue to echo through boardrooms and regulatory halls are Nigerian banks truly financing growth or merely recycling risk and protecting privilege? Only transparency, discipline, and a renewed sense of purpose can answer that question in the affirmative.
Blaise, a journalist and PR professional writes from Lagos, can be reached via: [email protected]
Feature/OPED
AI and Cybercrime in Nigeria: Can Weak Laws Support Strong Technology?
By Nafisat Damisa
Introduction
The proliferation of generative AI has transformed Nigeria’s cybercrime landscape, enabling deepfake fraud, automated social engineering, and AI-enhanced phishing at scale. In early 2024, scammers using AI-generated deepfake videos impersonating a company’s CFO defrauded a Hong Kong finance worker of $25.6 million. As similar threats emerge in Nigeria’s fintech sector, this article examines whether the Cybercrimes (Prohibition, Prevention, etc.) Act 2015 (as amended 2024) is legally adequate, or whether Nigeria’s evidentiary and accountability frameworks are too weak to support effective prosecution of AI-driven cybercrime
Current Legal Landscape
Nigeria’s primary legal framework on preventing cybercrime is the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, amended in 2024 to address cryptocurrency transactions, cyberbullying and various forms of digital misconduct. Complementary frameworks include the National Information Technology Development Agency Act 2007, the Nigerian Data Protection Act 2023, and sectoral regulations such as the CBN’s Risk-Based Cybersecurity Framework. However, the majority of these frameworks were issued far before now, and emerging risks like AI-driven threats are not really being addressed. The Act nowhere mentions “artificial intelligence,” “algorithm,” or “autonomous system.” Notably, the National Artificial Intelligence Commission (Establishment) Bill, 2025, is currently pending before the Senate. If passed, it would establish a dedicated commission to coordinate AI strategy, research, and ethical deployment. However, the Bill in its present form focuses primarily on development and innovation promotion, with limited provisions on criminal liability, evidence handling, or enforcement against AI-facilitated cybercrime, leaving the core accountability and evidentiary gaps largely unaddressed.
AI as a Double-Edged Sword
AI paradoxically enables both defence and attack. Nigerian financial institutions deploy AI for real-time fraud detection and pattern recognition. Conversely, cybercriminals exploit generative AI for deepfake creation, automated credential stuffing, and convincing phishing tailored to Nigerian English and Pidgin. The same technology that powers fraud detection systems can be weaponised to evade them. Take justice delivery as an example, the Evidence Act 2011 (as amended 2023) admits computer-generated evidence under Section 84, but remains silent on AI’s capacity to seamlessly generate or alter electronic records, creating “doctored AI-generated evidence”. These and many more issues await Nigeria’s digital space in the coming years.
The Legal Gaps
There are multiple critical gaps that undermine AI governance. For this article, three are considered. First, no framework attributes criminal liability when an autonomous AI commits an offence. The question of whether the developer, user, or owner should bear criminal responsibility for the acts of an autonomous system remains entirely unanswered under Nigerian law, leaving prosecutors without a clear legal theory of culpability.
Second, Section 84 of the Evidence Act 2011 governs computer-generated evidence but does not address AI-generated outputs. The Act’s definition of “computer” excludes AI’s cognitive processing capabilities, creating a statutory blind spot where evidence produced by generative or autonomous systems falls outside the existing admissibility framework.
Third, Nigeria lacks any framework for mandatory AI-generated content labelling, impeding deepfake traceability. Computer-generated evidence under Section 84 of the Evidence Act 2011 remains admissible if unchallenged at trial, a dangerous precedent for AI evidence, as opposing parties may lack the technical capacity to mount any challenge at all.
Comparative Jurisdictions: Rich Laws, Tangible Results
Jurisdictions with advanced AI laws demonstrate clear outcomes. The EU AI Act (Regulation 2024/1689) mandates transparency obligations, requiring synthetic content labelling and informing individuals when interacting with AI systems; non-compliance triggers significant penalties. The US Algorithmic Accountability Act of 2023 is a proposed Act that will require impact assessments for high-risk AI systems in housing, credit, and employment, with FTC enforcement and a public repository. China implemented mandatory measures for the Identification of AI-generated (Synthetic) content. These rules, mandated by the Cyberspace Administration of China (CAC) and others, require explicit (visible labels) and implicit (watermarks/metadata) identification for all AI-generated text, images, audio, video, and virtual scenes to ensure transparency, traceability, and combat disinformation. These laws contribute to measurable results: forensic traceability, expedited prosecution of deepfake fraud, and clear liability chains. Nigeria has none of these.
Hope or Illusion?
Without legislative intervention, AI’s promise against cybercrime remains an illusion. Nigeria requires the following to boost its hope:
- Amendment of the Cybercrimes Act to include AI-specific offences and mandatory content provenance standards;
- Revision of Section 84 of the Evidence Act 2011 to address AI-generated evidence credibility, not merely admissibility;
- Investment in digital forensic capabilities is currently hampered by inadequate enforcement, weak forensic capabilities, and a lack of specialised personnel; and
- A risk-based framework drawing from EU and US models.
- Review of both secondary and tertiary education curricula to address the knowledge gap in AI and prepare the next generation for the AI-driven future.
Conclusion
AI can help curb cybercrime in Nigeria, but only if legal capacity catches up with technical capability. The Cybercrimes Act 2024 amendments were a step forward, but they did not address AI accountability, algorithmic transparency, or evidentiary credibility. The pending National Artificial Intelligence Commission Bill, 2025, signals legislative awareness, but without substantive provisions on liability, evidence, and enforcement, it cannot fill the existing gaps. The effectiveness of existing frameworks remains a question. An optimistic but cautious path exists, but until Nigeria enacts AI-specific legislation, whether through amending the Cybercrimes Act, revising the Evidence Act, or strengthening the pending Bill, weak laws will remain unable to support strong technology.
Nafisat Damisa is a Legal Research Associate in Olives and Candles – Legal Practitioners. For further information, enquiries, or clarification, please contact Nafisat via: [email protected] or [email protected]
Feature/OPED
Before Oil Hits $150: A Warning Nigeria Cannot Ignore
By Isah Kamisu Madachi
As of April 30, 2026, the crude price is said to have reached $125 in the global market. The all-time high price per barrel was recorded in 2008, when it surged to $147. It is obvious that the price is heading in that direction or even towards what experts have predicted — crude reaching a new all-time high of $150 in the near future if crude passages remain closed in the Middle East, which would ultimately come with several disproportionate challenges for businesses and households.
In Nigeria, what began as a mild adjustment in the price of gasoline and other refined crude products has not stopped anywhere until it reached N1,400 per litre of petrol at filling stations. When the price was surging, experts in energy, economics, marketing, business and other relevant fields tried to come up with explanations for how Nigeria, despite housing the largest petrochemicals refinery in Africa and being one of the largest oil-exporting countries on the continent, would continue to absorb this shock.
Despite our advantages, Nigeria recorded the world’s second-highest surge in petrol prices following the escalating geopolitical tension in the Middle East. In Africa, Nigeria has the highest spike, with many sources citing it at 39.5% and above. Even non-oil-producing countries in Africa, and countries that do not refine a drop of oil, did not experience this surge. Also, African countries like South Africa at 1%, Morocco at 2.1%, and Tanzania at 2.7% experienced far smaller increases that are nowhere near Nigeria’s.
To put it in context, South Korea, Japan, and China are among the foremost dependents on the Strait of Hormuz, whose closure escalated the crude price, but none of these countries has recorded even a 20% increase in their petrol prices. Nigeria does not import its crude through the Strait of Hormuz. Yet, as an oil-exporting nation, we have suffered some of the sharpest petrol price increases in Africa.
What went wrong in Nigeria to warrant this surge is not the primary focus of this piece. What lies ahead is. As a result of the increase in petrol prices, Nigerians have been disproportionately affected. Life has become unbearably difficult, with sharp increases in transportation costs, rising food prices, and higher costs of goods and services. Even charging points that used to collect N150 for charging a phone or battery now charge N300 or more.
As it stands, the gap between the current crude price and the predicted new all-time high is about $25. This means that if the passages continue to remain closed, we are not far from another historic price peak. It is even said that reopening the passages may not immediately stabilise prices, as crude tankers would still take time to reach their destinations.
What this means for Nigeria is another sharp increase in refined petroleum product prices, which could trigger another wave of stagflation. Already struggling, Nigerians do not deserve this. They are only just adapting to the post-subsidy era, yet are being hit again by another round of global geopolitical tensions. Many are already in deep energy poverty, with businesses struggling due to unstable electricity supply.
Therefore, as crude oil prices hover above $125 per barrel and threaten to reach the predicted $150 if disruptions in the Strait of Hormuz persist, Nigeria must act decisively to shield its citizens. The Dangote Refinery exists. Nigeria refines oil. What the federal government owes Nigerians at this point is a deliberate policy decision to make that the refinery serve domestic needs first, with pricing that does not mirror whatever is happening in the global market. That is not complicated; other oil-producing countries do exactly this.
The NMDPRA has the authority to act on this. The question is whether there is a political will to act before another price wave hits and Nigerians are once again left to absorb what their counterparts elsewhere never have to.
Sub-national governments also have something to do. Commercial motorcyclists and small business owners are the people who feel every petrol price increase the hardest and the fastest. Pushing CNG and LPG adoption among this group beyond the FCT and Lagos, with genuine support, would cushion a significant part of the next shock. Expanding solar access in underserved communities would do the same. A shop owner running on solar is not at the mercy of the next diesel price spike.
These solutions are quite feasible. Nigeria has attempted versions of them before. Where we often seem to get it wrong is in execution, and Nigeria has to treat this with the same urgency and seriousness as given to elections, for the well-being of its citizens. The only thing that has never matched the problem is the seriousness of the response.
Isah Kamisu Madachi is a policy analyst and development practitioner. He writes via [email protected]
Feature/OPED
A Simple Guide to Obtaining Pension Clearance Certificate in Nigeria
By Gbolahan Oluyemi
In 2025, the National Pension Commission (PenCom) directed all Licensed Pension Fund Operators (LPFOs) to demand a Pension Clearance Certificate (PCC) from service providers before engaging their services. This new policy typically affects various types of entities, including small and medium-scale enterprises, most of which are not usually compliance-driven. Following this directive, the PCC has become an essential compliance document for both large, medium and small-scale firms. This article provides a guide on what a PCC is, why it matters, and how it can be obtained.
What is a Pension Clearance Certificate (PCC)?
A Pension Clearance Certificate (PCC) is an official document issued by PenCom confirming that an organisation has complied with the provisions of the Pension Reform Act. It is an annual document that must be renewed every year at no cost. The yearly renewal is intended to ensure that organisations treat compliance as a continuous activity rather than a one-off act.
Why is a PCC Important?
The PCC is important because it demonstrates that an organisation is compliant with the provisions of the Pension Reform Act, especially as it relates to employee pension contributions under Section 4 (1) of the Pension Reform Act and subscription to group life insurance under Section 4 (5) of the Pension Reform Act. It is also required for certain transactions, such as government contracts and engagements with compliance-sensitive partners. In essence, a PCC assures investors, partners, and clients that your business is properly structured and compliant with regulatory requirements.
Who Needs a Pension Clearance Certificate?
Under Nigerian law, companies with three or more employees are required to participate in the Contributory Pension Scheme (CPS). If your organisation employs at least three staff members and provides or intends to provide services to Licensed Pension Fund Operators (LPFOs) or other regulated entities, you are expected to obtain a PCC annually.
How Do I Obtain a PCC?
PenCom issues the PCC electronically and at no cost through its web portal: https://pcc.pencom.gov.ng/. Please note that Applicants who are just beginning compliance and remitting employees’ pensions are required to first obtain an employer code from a Pension Fund Administrator (PFA). This code is necessary to initiate the PCC application on the PenCom portal.
Upon logging into the portal, you will be required to complete your company profile by providing your date of incorporation, contact details, and website (if applicable), as well as uploading your CAC documents.
Next, you will upload an Excel schedule (using the template provided on the website) containing your employee list. After this, you will be required to upload Excel sheets detailing pension contributions. You will also need to upload your organisation’s group life insurance documentation and payment instrument.
Finally, you will review your application and submit it for further processing by PenCom. Before commencing an application, ensure you have the following:
- Certificate of Incorporation (CAC documents)
- Group Life Insurance Policy for employees
- Evidence of Pension Fund Administrator (PFA) registration for employees
- Three years’ proof of monthly pension remittances, including penalties for any defaults (where applicable). For companies less than three years old, provide proof of remittances from the date of incorporation
- A valid Tax Identification Number (TIN)
- An employee schedule showing staff details and contributions (usually in Excel format) Templates are available on the PenCom portal
Also note that for the portal to accept employee details and remittance records, employees must have completed their data capture with their respective Pension Fund Administrator and updated their records to reflect their current employer.
Conclusion
Obtaining a Pension Clearance Certificate in Nigeria may seem technical at first, but once proper processes are established, it becomes routine. The key is consistency in remittance, maintenance of accurate records and prioritisation of compliance in overall operations.
For many Nigerian businesses, the PCC is more than a regulatory requirement; it is a mark of credibility. In a competitive environment, that credibility can make all the difference.
Gbolahan Oluyemi is a Legal Practitioner and currently leads Olives and Candles – Legal Practitioners. For further information, enquiries, or clarification, please contact Gbolahan via: [email protected] or [email protected]
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