While public attention remains fixed on artificial intelligence (AI) tools that write, generate, and automate tasks, a more consequential transformation is quietly unfolding across Nigeria’s digital economy: algorithms are beginning to make decisions that affect people’s financial lives.
AI is increasingly being used to make decisions rather than merely assist humans. In Nigeria’s fast-growing fintech sector, algorithms are beginning to influence who gets access to credit, how customers are assessed, how fraud is detected, and how complaints are resolved. As these systems become more sophisticated, a critical question emerges: who is accountable when an algorithm makes the wrong decision?
This question is particularly important in Nigeria because financial services are becoming increasingly digital. According to EFInA’s 2023 Access to Financial Services Survey, formal financial inclusion in Nigeria rose to 64% in 2023, up from 54% in 2020, while overall financial inclusion reached 74%. More Nigerians now access financial services through digital channels, meaning decisions once made by human loan officers are increasingly being delegated to automated systems.
AI-powered systems process applications faster, reduce operational costs, detect fraud more effectively, and expand access to financial services. For a country still working to deepen financial inclusion, these innovations offer enormous potential.
However, efficiency is not the same as accountability.
Unlike traditional credit decisions, where a loan officer can explain the factors that informed an outcome, AI-driven decisions are often based on proprietary models controlled entirely by the financial institution. Customers typically have no visibility into the metrics being used to assess them, no meaningful opportunity to challenge those metrics, and little understanding of how a decision was reached. This creates a significant information imbalance between service providers and consumers, undermining fundamental consumer protection principles such as transparency, fairness, and the right to seek redress.
Consider a digital lending platform that uses artificial intelligence to determine creditworthiness. An applicant is denied a loan despite having a stable source of income and a history of responsible financial behavior. When the customer seeks an explanation, the company may be unable or unwilling to provide one beyond a generic statement that the application did not meet the platform’s risk criteria. Yet the algorithm, the variables it relies on, and the weight assigned to those variables remain entirely within the control of the institution. From the consumer’s perspective, this is more than a technology problem. It is an accountability problem.
Who bears responsibility in such a scenario?
The company may argue that the system operates automatically. The software developer may insist that it merely provided the technology. The data provider may claim responsibility ends with supplying information. Yet from the consumer’s perspective, someone must be accountable.
What makes the Nigerian situation particularly significant is the speed at which technology adoption often outpaces regulation. According to the Central Bank of Nigeria’s Fintech Report, close to 11 billion transactions were processed through the NIBSS Instant Payment platform in 2024, more than double the approximately five billion recorded in 2022. The report also notes that AI is already being deployed across the fintech ecosystem.
Nigeria’s Data Protection Act already provides an important foundation for addressing some of these concerns. Because AI systems rely heavily on personal and behavioral data, organisations must comply with obligations relating to lawful processing, transparency, and accountability. However, data protection alone cannot answer the broader governance question.
That scale makes AI accountability a practical concern, not a theoretical one. A flawed employee may affect dozens of customers; a flawed algorithm can affect hundreds of thousands. The real challenge is ensuring that organisations remain responsible for decisions made through automated systems.
As businesses adopt advanced AI tools, there may be a temptation to treat algorithmic outcomes as neutral or objective. That would be a mistake. AI systems are designed, trained, deployed, and monitored by human organisations. Responsibility cannot disappear simply because technology is involved.
Nigeria has an opportunity to act before a crisis forces action. Rather than waiting for widespread disputes over automated decisions, policymakers now develop a clear framework for AI accountability in sectors where algorithms affect people’s access to services, opportunities, and financial resources.
The principle should be straightforward: automation should never eliminate accountability.
Companies should remain responsible for decisions made through systems they deploy. Consumers should have access to meaningful explanations where automated decisions significantly affect them. Regulators should be able to identify who bears responsibility when harm occurs.
This does not require an immediate, sweeping AI law. It requires clear rules that preserve innovation while ensuring that businesses cannot hide behind algorithms when things go wrong. The goal should be responsible deployment, not regulatory paralysis.
Nigeria has often had to regulate emerging technologies after problems have become widespread. AI offers a rare opportunity to take a more proactive approach.
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Omoruyi “Uyilaw” Edoigiawerie is a startup lawyer, policy advisor, and Founder of EandC Legal. He advises startups, investors, and institutions on technology, innovation, and regulatory strategy. His work focuses on technology governance, digital transformation, financial inclusion, and emerging technologies, with a particular interest in the policies shaping Africa’s digital and economic future.
