Helping Was Illegal: Inside Nigeria’s War on the Organisations Serving Its Forgotten Communities

On the morning of February 28, 2023, aid workers across Adamawa State woke up to a government order that stopped them mid-sentence.

Governor Ahmadu Fintiri suspended every single NGO operating in the state, citing allegations of vote buying. “It has become evident that most NGOs are dabbling into politics in the name of providing humanitarian assistance to the people,” Fintiri told a press briefing at Government House in Yola. “In furtherance of our desire to reorder the electoral behaviour of our people and remove the influence of NGOs, government has decided to suspend the activities of local and international NGOs throughout the state until March 15, 2023, when the elections are over.”

He made no distinction between political actors and the organisations delivering food to children, healthcare to mothers, and shelter to the internally displaced. With one broadcast, all of it stopped.

When the second round of elections was subsequently postponed, the Adamawa State Government extended the suspension of NGO activities until after the rescheduled election date. High-level advocacy efforts by the United Nations and humanitarian partners were immediately initiated to restore the essential work of humanitarians for the well-being and safety of people in need in Adamawa.

Amnesty International described the suspension as repressive and a direct attack on civic space. “Targeting organizations solely for carrying out their normal activities when they are saving lives will mostly hurt the vulnerable communities they are serving,” Amnesty’s statement read. “This crackdown on independent organizations and human rights defenders must stop.”

The ban was eventually lifted in May 2023. The Adamawa State Government announced that all NGOs could resume operations and engage in humanitarian work, subject to compliance with applicable laws and regulations.

But the damage done in those weeks — to humanitarian pipelines, to community trust, to the organisations themselves — was not reversed by the lifting of a ban. And the deeper problem, the one that made the Adamawa suspension possible and that continues to shape the operating reality of civil society organisations across Nigeria, remained entirely in place.

This Was Not the First Time. It Will Not Be the Last.

The Adamawa suspension did not happen in a vacuum. It was the loudest moment in a much longer, quieter war on civil society in northern Nigeria, one being fought not only through dramatic executive orders but through legislation, regulatory overload, and administrative strangulation.

The Nigerian military had forced international organisation Action Against Hunger to stop providing aid in northeast Nigeria years earlier, accusing it of supplying insurgents with drugs and food. A military spokesman said the organisation had been engaging in “subversive” activities “despite several warnings to desist from aiding and abetting terrorists.” In December 2018, the military briefly suspended UNICEF from operating, accusing the agency of training and deploying spies who supported insurgents. The suspension was quickly reversed following emergency talks but the signal it sent to the humanitarian community was not quickly forgotten.

Nigeria saw a significant increase in all types of aid worker incidents, including killings, injuries, and kidnappings, from 2023 to 2024, according to the Aid Worker Security Report. The people who show up to deliver food, medicine, and shelter in Nigeria’s northeast do so at increasing personal risk, under increasing institutional pressure, and with decreasing resources. The architecture of restriction that surrounds them did not assemble itself by accident.

The Laws That Are Choking Civil Society

To understand the full architecture of that restriction, you need to understand what Nigerian civil society organisations are navigating before they can deliver a single bag of relief food or conduct a single health screening.

The non-profit sector in Nigeria operates under a complex regulatory framework involving multiple agencies, each responsible for different aspects of nonprofit operations. A recent desk study referenced over 20 different agencies, policies, rules and regulations governing the civic space alone in Nigeria. When compliance requirements across all applicable laws, including federal legislation, state-level requirements, anti-money laundering obligations, and sector-specific regulations, are aggregated, the total number of regulatory instruments an NGO must navigate runs to 53, according to the NNNGO Civil Society Regulatory Frameworks report.

The centrepiece of that framework is the Companies and Allied Matters Act 2020, and its most contested provision is Section 839.

Section 839 of CAMA empowers the Corporate Affairs Commission to suspend the trustees of an association and appoint interim managers to manage the affairs of the association where it reasonably believes there has been misconduct or mismanagement in the administration of the association. This provision is the most concerning because it provides an avenue for the government to interfere in the activities of associations and with the constitutional right of freedom of association. It appears that the intent is to bring in stricter regulation that could not be introduced with the NGO Regulation Bill. Notably, the terms “members” and “reasonable evidence” are not clearly defined, and the new Act does not provide for any remedial steps to be taken first administratively before the intervention of the regulator and the court.

The Federal High Court declared several sections of CAMA unconstitutional in two separate cases in 2023, including Section 839(1), in cases brought by the Registered Trustees of the Christian Association of Nigeria against the Corporate Affairs Commission and the Minister of Trade and Industry, and Emmanuel Ekpenyong against the National Assembly. Appeals against those rulings are currently pending.

In response to civil society pressure, the Agents for Citizen-driven Transformation Programme collaborated with NNNGO and the Open Society Initiative for West Africa to engage CSOs across the country to review the regulations. A consortium of 42 civil society networks and coalitions formed a working group that successfully influenced the CAC to revise provisions of the CAMA 2020 Act to require that in the case of religious or cultural associations, any interim manager appointed must be a person of that religion or culture. It was a partial victory, hard-won through sustained advocacy. The fundamental concern about government overreach into civil society governance remained.

Then came the Non-Profit Governance Code 2023.

Proposed by the Financial Reporting Council of Nigeria, the Non-Profit Governance Code 2023 seeks to further regulate the non-profit sector, focusing on areas such as board composition, board responsibilities, financial management, and stakeholder engagement. According to a position paper by Spaces for Change, this new Code raises significant concerns about overregulation, as existing legislation, particularly CAMA 2020, already addresses many of the issues in the proposed Code. This only serves as an unnecessary additional layer of regulation of the non-profit sector in Nigeria, potentially leading to what could be described as regulatory overkill.

The ICNL, which provides technical assistance to NNNGO to analyse laws affecting civil society operations and advocate for an enabling legislative framework, has consistently identified this pattern as a deliberate tool of civic space restriction. ICNL has supported CSOs in their advocacy against restrictive laws through providing comments on proposed bills impacting on freedom of expression, association, and assembly rights, including the Hate Speech Bill, the False News Bill, CAMA 2020, and the Infectious Diseases Bill of 2020. ICNL’s work has expanded to include technical assistance to CSOs to monitor legislative measures and respond to restrictions on civil society resulting from government’s attempts to counter money-laundering and terrorism financing.

Under current requirements, CSOs must file Currency Transaction Reports for any transactions exceeding NGN 10,000,000, approximately USD 6,500 as of September 2025, for corporate bodies and NGN 5,000,000 for individuals, as well as submit Suspicious Transaction Reports for any transaction deemed suspicious. These reporting requirements can be burdensome for CSOs. For a small Nigerian NGO operating in a remote LGA in Adamawa, Yobe, or Borno, compliance with these obligations requires legal expertise, administrative capacity, and financial resources that many simply do not have. The cost of staying legal is, for many, the cost of staying open.

The ICNL’s analysis of how closing civic space affects development and humanitarian civil society organisations documents a globally consistent pattern: multiple reports have outlined the plight of human rights and advocacy organisations in the face of escalating legal restrictions on civil society. Often overlooked is the similarly difficult experience of organisations focused on development, which have also witnessed the deterioration of an enabling environment conducive to their success. Nigeria is not an outlier in this global pattern. It is one of its clearest examples.

The People Paying the Price

While lawyers debate the constitutionality of Section 839 and regulators propose new governance codes, the consequences of these restrictions are landing on people who have no role in any of those conversations.

Nearly 35 million Nigerians are likely to face acute food insecurity during the 2026 lean season. Of those, 5.8 million are in Borno, Adamawa, and Yobe states in the northeast. Malnutrition is a devastating challenge nationwide. In northeastern Nigeria, the malnutrition crisis is particularly acute, where it is estimated that at least 75 children face death every single day if they do not receive urgent therapeutic care.

Of the 1.5 million people targeted for food assistance in 2026, only 35 percent, all situated in Borno State, have been reached. No beneficiaries have received support in Adamawa and Yobe states due to shortages and access constraints.

Read that again. No beneficiaries have received food support in Adamawa and Yobe in 2026. Not because the food does not exist. Not because the organisations do not want to deliver it. Because access constraints, funding shortfalls, and an operating environment that makes humanitarian work progressively harder have combined to leave the gap open and the people inside it without recourse.

Of the 3.5 million children in Nigeria facing severe acute malnutrition, 65 percent live in just six northern states: Borno, Adamawa, Yobe, Sokoto, Zamfara, and Katsina. Of the 4 million displaced across the country, 63 percent have been displaced for five years or more. Civilian casualties have intensified in 2025, with more than 3,600 deaths reported, the highest number per year in the last decade.

Humanitarian partners have launched an urgent appeal for USD 516 million to provide lifesaving support to 2.5 million people in the BAY states in 2026. Women and children account for eight out of every ten people in immediate need.

The organisations best placed to close that gap are the same ones being squeezed by CAMA Section 839, by the proposed Non-Profit Governance Code, by state-level suspensions, and by compliance requirements that consume the administrative bandwidth of organisations trying to serve communities on the edge of catastrophe.

The World Food Programme has warned that without urgent funding, millions will be left without vital support, risking more instability and deepening a crisis that the world cannot afford to ignore. WFP officials have cautioned that reducing food aid at this stage could trigger a chain reaction of humanitarian and security challenges, as food shortages often lead to secondary displacement, as families abandon camps and host communities in search of survival.

What “Accountability” Has Come to Mean

Every instrument of restriction discussed in this report was justified, at the time of its introduction, by the language of accountability. Section 839 was introduced to address misconduct and mismanagement in associations. The Non-Profit Governance Code is framed as improving board oversight and financial management. The Adamawa suspension was described as protecting the integrity of the electoral process. The military’s removal of Action Against Hunger was framed as a counter-terrorism measure.

Accountability is a legitimate and important value. Nigerian NGOs, like institutions everywhere, must be held to standards of financial transparency and governance integrity. Nobody arguing for an enabling environment for civil society is arguing for unaccountable civil society.

But accountability, in the Nigerian context of the past decade, has become the country’s most convenient weapon against the very people it is supposed to protect. When a government can suspend every humanitarian organisation in a state with a single broadcast, citing a broadly worded concern about political influence with no evidence presented, no due process followed, and no distinction made between political actors and emergency food distributors, that is not accountability. That is control dressed in the language of governance.

The Nigerian government has established its own NGOs, known as GONGOs. Since 2015, the number of pro-government NGOs appears to have increased significantly. The contrast is instructive: government-affiliated civil society organisations operate without the regulatory scrutiny applied to independent ones. The accountability framework that is most rigorously applied to Nigerian civil society is the one that is applied selectively, to the organisations that are most independent, most critical, and most effective at reaching the communities the government itself has failed to adequately serve.

In 2025, NNNGO advanced its commitment to building a strong, inclusive, and enabling environment for civil society organisations through strategic programmes, capacity development initiatives, and research. The Network played an active role in the EU System for an Enabling Environment, contributing to initiatives that support civic space and civil society sustainability. The EU-SEE programme, which NNNGO participates in as a key partner, is specifically designed to address the enabling environment challenge that sits at the root of every restriction described in this report. Its core premise is that civil society organisations cannot serve communities effectively when the regulatory environment is designed to constrain rather than support them.

What Must Change

The argument of this report is not that Nigerian NGOs should be exempt from regulation. It is that the current regulatory architecture is disproportionate, discriminatory in its application, and directly harmful to the communities it claims to protect.

Three changes are necessary and possible.

The 53-instrument regulatory framework that Nigerian NGOs must navigate requires urgent rationalisation. The NNNGO and its partners have consistently advocated for a single, coherent, proportionate legal framework for civil society that eliminates duplicative compliance requirements, defines its terms clearly, and provides genuine administrative remedies before regulatory intervention rather than after. The Commonwealth Foundation’s analysis of Nigeria’s civil society policy framework concluded that the existing laws need to be amended to reflect the realities of the CSO sector. That amendment process has been deferred for too long.

Section 839 of CAMA must be amended in line with the Federal High Court’s constitutional findings, while the appeals process is concluded. The provisions that allow government interference in civil society governance without clearly defined grounds, without defined evidence standards, and without prior administrative process are inconsistent with the constitutional rights of freedom of association and freedom of thought. The Federal High Court said so in 2023. The legislature should act on it.

State governments must be held to a standard that prohibits blanket suspensions of humanitarian organisations during elections or any other politically sensitive period. The Adamawa precedent, if left unchallenged and unaddressed in law, becomes a template. Fourteen years into the northeast Nigeria conflict, over 7.9 million people across Borno, Adamawa, and Yobe face severe protection concerns and daily threats to their well-being. Children and women make up 83 percent of those in need. No election in Nigeria’s history has been more important than those 7.9 million people’s access to food, medicine, and shelter. The regulatory framework must reflect that hierarchy of urgency.

The Cost of Waiting

The Food Security Situation Analysis for 2026 projects that 1.4 million people will be food insecure in Adamawa between June and August 2026, with 2.9 million in Borno and 1.6 million in Yobe. These are not projections about a future crisis. They are projections about what is already unfolding, in communities that humanitarian organisations exist to serve and are being prevented from serving at full capacity.

WFP Country Director David Stevenson stated the security dimension plainly: “Communities are under severe pressure from repeated attacks and economic stress. If we can’t keep families fed and food insecurity at bay, growing desperation could fuel increased instability with insurgent groups exploiting hunger to expand their influence, creating a security threat that extends across West Africa and beyond.”

The organisations that stand between that warning and its worst realisation are still being squeezed. The laws that constrain them are still in force. The precedents that legitimised their suspension are still on the books.

In Nigeria, it has been made possible, through law, regulation, and executive order, to treat helping as illegal. The people who paid the price for that possibility in Adamawa in March 2023 were not politicians. They were hungry children, displaced mothers, and communities without access to the basic services that humanitarian organisations were in the middle of delivering when the broadcast came through.

Their names were not in the governor’s press statement. They are not in the legal filings challenging Section 839. They are not in the regulatory consultation documents on the Non-Profit Governance Code.

They are in the OCHA field reports, in the WFP nutrition clinic data, in the Cadre Harmonisé food security projections, in the numbers that keep rising while the argument about who is allowed to help them continues.

That argument needs to end. And it needs to end on the side of the people who have already waited long enough.