1. Introduction
The Internet Code of Practice 2026 (“2026 Code”), which came into effect on February 13, 2026, marks a significant milestone in Nigeria’s digital regulatory landscape. Issued by the Nigerian Communications Commission (NCC) pursuant to Section 70 of the Nigerian Communications Act 2003 (the Act), the 2026 code replaces the Internet Code of Practice 2019 (“2019 Code”). The 2026 Code reflects a more complex and interconnected digital ecosystem, recognising that internet governance now extends beyond traditional Internet Access Service Providers (IASPs) to a wider range of digital actors.
Alongside the 2026 Code, the Commission published Guidance Notes for the Implementation and Enforcement of the Internet Code of Practice 2026 (Guidance Notes) to clarify regulatory expectations, implementation timelines, and operational processes. The Guidance Notes are subordinate to the Code and are to be read alongside it.
From a policy perspective, the 2026 Code illustrates the NCC’s intent to adopt a more proactive regulatory approach. However, while the framework is ambitious, its effectiveness will depend on how clearly obligations are interpreted, the capacity of regulated entities to comply, and the consistency of enforcement.
