We have carefully reviewed the proposed Foreign Aid (Regulation, Transparency and Disclosure) Bill, 2026 (SB. 1034) sponsored by Senator Ibrahim Hassan Dankwambo. The importance of transparency, accountability, disclosure and effective coordination in the management of foreign aid is duly acknowledged. However, we are deeply concerned that the proposed legislation is unnecessary and risks creating an additional layer of bureaucracy that could undermine Nigeria’s civic space.

The proposed bill raises significant concerns about the potential for excessive government control over legitimate civic activities. Provisions requiring mandatory registration of all foreign aid, broad powers to demand information, conduct inspections, impose sanctions, and regulate recipients of foreign assistance could become tools for needless interference with the work of civil society organisations, community-based organisations, faith-based organisations, research institutions, and humanitarian actors.

Nigeria is replete with laws governing financial accountability, public procurement, anti-corruption, anti-money laundering, taxation, corporate regulation and the operations of non-governmental organisations and entities that receive grants and donations. Existing legal and institutional frameworks already provide government with broad powers to monitor financial transactions, investigate misuse of public and donor funds, ensure compliance with reporting obligations, and prosecute violations where they occur.

An example of such laws is the Money Laundering (Prevention and Prohibition) Act 2022, which is one of Nigeria’s main laws for ensuring financial transparency and accountability. It requires banks and other businesses to verify their customers, keep proper financial records, and report suspicious transactions to the relevant authorities. The law also gives agencies such as the Nigerian Financial Intelligence Unit (NFIU) and the Economic and Financial Crimes Commission (EFCC) the power to investigate and prosecute cases of money laundering, terrorist financing, and the misuse of donor or grant funds. Another important law is the Companies and Allied Matters Act (CAMA), 2020, which governs the registration and operation of companies, non-governmental organisations (NGOs), and other incorporated organisations in Nigeria. The law requires these organisations to register with the Corporate Affairs Commission (CAC), keep proper financial records, submit annual reports, and follow basic rules of good governance. It also gives the CAC the authority to monitor these organisations and take action where they fail to comply with the law.

Rather than creating a new regulatory commission with overlapping mandates, the examples above provide extensive powers for oversight of financial transactions and reporting obligations. Establishing another regulatory body would duplicate functions, increase compliance burdens, consume scarce public resources, and create uncertainty for organisations delivering essential humanitarian, development, health, education, and social services across the country.

We therefore urge the National Assembly to reconsider the necessity of this proposed legislation. Legislative efforts should instead prioritise:

• Strengthening the implementation and enforcement of existing laws and regulatory frameworks.
• Enhancing institutional coordination among existing oversight agencies.
• Improving transparency through better public access to information under existing legal mechanisms.
• Promoting constructive engagement with civil society and development partners rather than imposing additional regulatory restrictions.
• Ensuring that any reform respects the constitutional rights to freedom of association, expression, and participation in public affairs.

The need of the hour is not more legislation, but better implementation of the robust legal and institutional frameworks that already exist. Strengthening existing laws and institutions will achieve greater accountability without placing unnecessary constraints on the civic space that remains essential to Nigeria’s democratic and developmental aspirations.

Signed
OPEN ALLIANCE