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VOL. 12, ISSUE 3 (2026)
Public registers and private rights: A critique of data safeguards in Nigeria's PSC Regulations 2022 and the UK persons with significant control framework
Authors
Oyinkare Omemu-Harrison, Jonathan Ekperusi
Abstract
Corporate transparency and individual privacy are core tenets of modern
democratic governance. They are constitutionally and legislatively recognised.
Beneficial ownership disclosure most poignantly illustrates the intersection of
the two values when a public register mandates disclosure of personal
information by Persons with Significant Control (PSCs) in companies and other
corporate business arrangements. This article provides a doctrinal critique of
the data protection mechanisms in Nigeria's Persons with Significant Control
Regulations 2022 and the United Kingdom's PSC Regulations, as revised by the
Economic Crimes and Corporate Transparency Act 2023. The article draws from
data protection scholarship, constitutional law, and the Nigeria Data Protection
Commission’s (NDPC) published guidance. It identifies three design flaws in the
data protection mechanisms in Nigeria’s PSC Regulations: First, there is an
undefined disclosure authority. Secondly, there is the absence of a
proportionality assessment, and thirdly, there is the absence of a mechanism
for guaranteeing the actual identity of PSCs. The UK’s PSC Regulations
demonstrate the constitutional ability of a public register framework to
protect private interests. The article combines an unprecedented systematic
comparison of the constitutional and data protection frameworks regarding
Nigeria’s PSC Regulations with legal scholarship and provides five specific
recommendations for legislative reforms.
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Pages:139-146
How to cite this article:
Oyinkare Omemu-Harrison, Jonathan Ekperusi "Public registers and private rights: A critique of data safeguards in Nigeria's PSC Regulations 2022 and the UK persons with significant control framework". International Journal of Law, Vol 12, Issue 3, 2026, Pages 139-146
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