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AI law comparison · Data verified 2026-08-22

GDPR Article 22 vs Nigeria Data Protection Act

GDPR Article 22 and Nigeria Data Protection Act are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.

Find which laws apply to my business

Side by side

Attribute
GDPR Article 22
Nigeria Data Protection Act
Region
EU
NG
Effective date
2018-05-25
2023-06-12
Enforcement begins
Who must comply
GDPR Art. 22 applies to: (1) any organization established in the EU/EEA; (2) organizations outside the EU/EEA that offer goods or services to EU/EEA data subjects or monitor their behavior. The "solely automated" thresho…
Applies to: any data controller or processor that processes the personal data of individuals resident in Nigeria, wherever the organisation itself is located (NDPA 2023 has extraterritorial reach where a controller/proce…
Maximum penalty
€20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5))
Two-tier structure: Data Controllers/Processors of Major Importance face NGN 10,000,000 OR 2% of annual gross revenue, whichever is higher; other controllers/processors face NGN 2,000,000 OR 2% of revenue, whichever is higher. Up to 1 year imprisonment for willful violations; data subjects may separately recover civil damages.
Compliance requirements
5 tracked
3 tracked
Enforcement actions on record
2
2
Data last verified
2026-08-22
2026-08-22

Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.

The key difference

GDPR Article 22 takes effect first, so it is usually the more urgent of the two. GDPR Article 22 tracks 5 compliance requirements and Nigeria Data Protection Act tracks 3. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.

EU

EU GDPR Article 22 — Automated Decision-Making & AI Profiling

GDPR Article 22 (in force since May 25, 2018) gives EU and EEA residents the right not to be subject to decisions based solely on automated processing — including AI profiling — that produces legal or similarly significant effects (credit scores, hiring, insurance pricing, content moderation). Organizations must inform individuals of automated processing, provide meaningful explanations of logic, implement human revi…

Full GDPR Article 22 requirements
NG

Nigeria Data Protection Act 2023 (NDPA)

Nigeria's Data Protection Act 2023 (signed June 12, 2023) replaced the 2019 NDPR framework and established the Nigeria Data Protection Commission (NDPC) as the regulatory authority. The NDPA applies to any organization processing personal data of Nigerian residents, wherever the organization is located. This is Africa's most comprehensive data protection law and directly addresses AI-driven processing. Section 24 pro…

Full Nigeria Data Protection Act requirements

Common questions

Could both GDPR Article 22 and Nigeria Data Protection Act apply to my business?

Yes. GDPR Article 22 and Nigeria Data Protection Act are separate regulations with separate scopes — a business can fall under both at once. GDPR Article 22 covers GDPR Art. Nigeria Data Protection Act covers Applies to: any data controller or processor that processes the personal data of individuals resident in Nigeria, wherever the organisation itself is located (N… If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.

Which has the higher maximum penalty — GDPR Article 22 or Nigeria Data Protection Act?

GDPR Article 22: €20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5)) Nigeria Data Protection Act: Two-tier structure: Data Controllers/Processors of Major Importance face NGN 10,000,000 OR 2% of annual gross revenue, whichever is higher; other controllers/processors face NGN 2,000,000 OR 2% of revenue, whichever is higher. Up to 1 year imprisonment for willful violations; data subjects may separately recover civil damages. Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.

When does each law take effect?

GDPR Article 22 — effective 2018-05-25. Nigeria Data Protection Act — effective 2023-06-12. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.

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