Africa’s ambition to build a unified digital economy faces growing regulatory challenges as differences in national data protection laws threaten cross-border financial transactions, digital trade and the movement of personal information between countries.
The fragmented regulatory environment could complicate the expansion of fintech companies, mobile money operators and other digital businesses across African markets, particularly as countries implement the African Continental Free Trade Area (AfCFTA) Digital Trade Protocol.
Stakeholders at the 2026 Data Protection Africa Summit in Lagos on Wednesday warned that differences in national privacy laws and how regulators interpret them could undermine regional digital integration, calling for stronger cooperation and harmonised data protection practices across the continent.
Teki Akuetteh, executive director of the Africa Digital Rights Hub, said differences between Nigeria’s and Ghana’s data protection frameworks, for instance, could affect the ease of transferring information and conducting financial transactions across the two countries.
She said, even where countries have similar legislation, differences in regulatory interpretation and enforcement could create uncertainty for businesses handling personal information across multiple jurisdictions.
“Even when you have the same laws, different regulators may interpret and implement them differently, making strategic partnerships important for building trust and facilitating cross-border data flows,” Akuetteh said.
The challenge presents a growing concern for Africa’s digital economy, where businesses increasingly depend on exchanging customer information across national boundaries to process payments, verify identities, provide financial services and operate digital platforms.
For financial technology companies, inconsistent requirements could mean navigating different compliance expectations in each market, potentially increasing operational costs and complicating regional expansion.
The issue also extends to healthcare providers, telecommunications companies and digital platforms that process personal information across multiple African countries.
Akuetteh said the African Union’s data policy and the AfCFTA Digital Trade Protocol provide opportunities for countries to strengthen cooperation on digital trade and data protection.
However, translating these continental frameworks into practical arrangements will require regulators to agree on responsibilities, share experiences and establish mechanisms for addressing cross-border privacy challenges.
She announced plans to promote an outcome-based collaborative regulatory approach that would bring regulators and other stakeholders together to identify problems, agree on responsibilities and establish whether agreed solutions had been implemented.
The approach seeks to shift regulatory cooperation from overlapping enforcement activities towards resolving specific problems affecting individuals and businesses.
Akuetteh illustrated the problem with examples involving mobile money transactions and healthcare records, where the handling of personal information by different service providers and institutions could leave consumers exposed when responsibilities are unclear.
She also announced plans to establish a Centre of Excellence where African universities, regulators and practitioners would jointly research data protection challenges and develop solutions.
The proposed centre is expected to strengthen institutional capacity and provide a platform for sharing knowledge and regulatory experiences across African markets.
Vincent Olatunji, national commissioner of the Nigeria Data Protection Commission (NDPC), said effective implementation of data protection legislation was impossible without cooperation across different sectors.
He said Nigeria’s population, expanding volume of personal information and increasing number of data protection cases made it difficult for the commission to address privacy challenges without support from public and private sector organisations.
Olatunji stressed that partnerships were necessary to expand public awareness, improve compliance and strengthen the country’s privacy ecosystem.
Nigeria enacted the Data Protection Act in 2023, establishing a legal framework for regulating how organisations collect, process and manage personal information. However, enforcement and public understanding remain important to ensuring that the law delivers meaningful protection.
Lagos state governor Babajide Sanwo-Olu, represented by Ganiyu Oseni, his special adviser on technology, innovation and broadband, said data protection had become central to public trust as government services increasingly moved online.
He said citizens who submitted personal information to access public services expected government institutions to handle such information responsibly and use it only for legitimate purposes.
Sanwo-Olu said cooperation among government agencies, regulators, technology companies, businesses and civil society was necessary to achieve the objectives of Nigeria’s data protection legislation.
He added that effective data protection could strengthen public confidence, support responsible innovation and create a more secure environment for investment and economic activities.
Beyond regulatory institutions, stakeholders said public awareness would be critical to strengthening Africa’s privacy ecosystem.
Olufolarin Ogunsanwo, a traditional ruler and Lagos State University chancellor, called for traditional institutions and universities to support grassroots privacy education, particularly among children and young people exposed to online risks.
He said digital privacy awareness should extend beyond technology professionals and regulatory authorities to ordinary citizens who increasingly use social media, digital payment platforms and online services.
The summit also extended its awareness campaign to schools, health centres and markets to improve public understanding of data protection.
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The gathering brought together data protection regulators from more than 15 African countries, alongside policymakers, industry representatives, academics and digital rights advocates.
For Africa’s digital trade ambitions, the central challenge is moving beyond the adoption of national privacy laws towards practical cooperation that allows businesses to operate across borders without weakening the protection of citizens’ personal information.
Without greater consistency in regulatory interpretation, institutional cooperation and cross-border data governance, differences in national frameworks could remain an obstacle to the regional digital integration that African governments are seeking to achieve.
Royal Ibeh is a senior journalist with years of experience reporting on Nigeria’s technology and health sectors. She currently covers the Technology and Health beats for BusinessDay newspaper, where she writes in-depth stories on digital innovation, telecom infrastructure, healthcare systems, and public health policies.
