Nigeria operations

Nigeria is where the gap is most acute. Oil and gas is where the consequences are largest.

Three independent lines of inquiry over three years document the scale and consistency of the decision governance gap in Nigeria: fifty documented incidents, eighteen upstream operators assessed, four additional capital-intensive sectors tested.

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forensic lines of inquiry across Nigeria

documented upstream incidents, 2020 to 2026

$0.0B

confirmed direct losses, 23 named entities

$0.0B

confirmed avoidable loss across the incident base

Nigeria decision classes

Four decision class examples. All documented. All recurring.

The four decision classes below are drawn directly from the Nigeria evidence base. Each one represents a category of recurring operational commitment where the absence of decision governance architecture amplified the loss. Each is a DR® entry point.

Gas supply commitment governance

Force majeure, October 2022

An LNG producer declared force majeure from October 2022 to August 2023. Three upstream JV feedgas suppliers had committed volumes against pipelines with a documented history of disruption.

GSPA compliance · NUPRC

Maintenance deferral decision governance

Grid disruption, 2025

A grid disruption at an indigenous upstream operator's asset followed a maintenance deferral decision made without a formal tolerance threshold governance. The decision was not undocumented because the engineering was absent. The governance of the decision was absent.

Asset integrity governance · PIA 2021

GSPA enforcement decision governance

Arrears accumulation: NGN 5.6 trillion

A federal power sector administrator accumulated NGN 5.6 trillion in unpaid bills across the sector because individual commitment decisions to supply or procure power under GSPA structures were made without formal assumption documentation. Suppliers continued full delivery through the accumulation.

Power sector governance · NERC compliance

Integrity margin decision governance

Production budget shortfall across consecutive target years

Sector operators set production budget targets against integrity thresholds that were not formally reviewed between annual planning cycles. The integrity margin governing the gap between operating level and formal threshold was not documented, owned, and escalated when conditions changed.

NUPRC operational integrity · PIA 2021

The accountability environment

The regulatory position has changed. The governance architecture in most operators has not.

PIA 2021 creates statutory obligations for Nigerian operators covering decision records, governance processes, and individual accountability. Under CAMA 2020, personal liability attaches to named directors where the standard of care is undocumented. The executive operating without a defensible decision governance record in 2026 faces regulatory investigation, reputational exposure, and personal liability. The accountability gap is documented and accelerating.

Statutory

PIA 2021 and CAMA 2020

Creates statutory obligations for Nigerian operators covering decision records and governance processes. Personal liability attaches to named directors where the standard of care cannot be demonstrated.

Regulatory

NUPRC and NMDPRA enforcement posture

The Nigerian Upstream Petroleum Regulatory Commission and the Nigerian Midstream and Downstream Petroleum Regulatory Authority have strengthened enforcement under the PIA framework. Regulatory investigations now look for documented decision processes, not only operational outcomes.

Parliamentary

Parliamentary committee record

Committee reports have named individual operators and their leadership in findings on operational failures since 2023. The public record of decision governance absence is growing.

The standing of the record

An externally produced governance record carries materially different standing under formal inquiry than one produced internally.

Under PIA 2021 enforcement, board scrutiny, and JV partner review, the origin of a decision governance record matters. A record produced by the operator about its own decisions is a self-certification. A record produced by an independent party, calibrated against a cross-operator forensic evidence base, carries the structural weight of external validation.

Self-certified governance record

Produced internally. Describes decisions made by the same organisation reviewing those decisions. Cannot independently verify the basis on which commitments were made. Structurally weaker under regulatory investigation.

Externally produced governance record

Produced by an independent party. Calibrated against a documented cross-operator evidence base. Not subject to the same political constraints that govern internal governance functions. Carries independent standing under PIA 2021 enforcement, board scrutiny, and JV partner review.

Nigeria: three independent lines of inquiry, three-year period, one structural conclusion.

Three inquiries. One structural question.

Three independent lines of inquiry were conducted over three years across the Nigerian upstream oil and gas sector. Each addressing a different dimension of the same structural question. Each using a different methodology, a different source base, and a different unit of analysis. All three reached the same structural conclusion.

first inquiry - The 50 incident evidence base

How the losses were estimated.

Documented incidents

Nigerian oil, gas and energy, 2020 to 2026

$0.0B

Confirmed direct losses

Across 23 named entities

0.0%

Due to decision governance absence

Of total confirmed losses arose from absent decision governance response, not the triggering events. This portion was avoidable.

0.00x

Average amplification

The estimate of how much larger a loss became because no governance architecture existed to structure the response.

TEC™ / GAC™ cost decomposition - USD 9.5B total, 50 incidents

70.3%

29.7%

USD 6.7B - Triggering Event Cost™

Unavoidable through decision governance. Attributable to the physical or external event.

USD 2.8B - Governance Amplification Cost™

Avoidable. Arose from absent decision governance response, not from the triggering events themselves.

Where this evidence base comes from

Three independent forensic investigations over three years. The origins of the evidence base, and the two careers that identified the gap before the investigations confirmed it.

How the gap was found

second inquiry - The decision governance gap

The decision governance investigation.

The second forensic investigation examined decision governance practices across eighteen Nigerian upstream operators: five IOCs, one NOC, and twelve indigenous operators. The investigation assessed how consequential operational decisions are governed across the sector. Twelve indigenous operators scored and assessed.

Across the twelve, the majority carry no structured decision governance at the operational commitment layer yet control some of Nigeria's largest producing assets. None hold a decision governance framework capable of meeting the accountability obligations those assets attract under PIA 2021.

Decision governance practice - 12 indigenous operators assessed

50%

None

33.3%

Minimal

16.7%

None

No structured decision governance. The governance gap is largest precisely where the asset scale is highest.

Minimal

Partial documentation. No structured decision governance at the operational commitment layer. IOC divestiture gap impact heavy.

Emerging

Listing-driven disclosure only.

Mature

No maturity.

third inquiry - Cross-sector confirmation

The gap is not sector-specific.

The third investigation extended the analysis beyond oil and gas, testing whether the same structural failure was present across other capital-intensive sectors in Nigeria. The pattern held in every case without exception.

Power

0.00x

Peak amplification multiplier

Twelve unplanned national grid collapses between 2023 and 2024. No evidenced decision governance before collapse. Reactive restart protocols in each case. The structural pattern matches the oil and gas register.

Electricity Act 2023 · NERC enforcement · EFCC investigation

Banking

NPL exposure, three retail banks

Three banks faced CBN enforcement action following decisions made without evidenced decision governance. NPL tolerance drifted without a formally defined decision governance that required board escalation.

CBN enforcement · Board removal · Recapitalisation orders

Infrastructure

$0B

Cumulative opportunity cost

Three concession failures each produced losses attributable to absent decision governance. Capital was recommitted without formal decision governance rigour as conditions deteriorated.

ICPC investigation · EFCC enforcement · ICRC oversight

Telecoms

Repatriation fine reduced from $330B

A leading TelCo faced repatriation fines following the absence of documented decision accountability for FX commitment authority. An underperforming TelCo's subsequent collapse followed capital allocation decisions with no pre-defined decision governance as the debt position deteriorated.

NCC enforcement · CBN FX compliance · Court records

The amplification range across power, banking, infrastructure, and telecoms (1.67x to 2.22x) is consistent with the fifty-incident oil and gas base. The gap is a property of consequential decisions made under uncertainty wherever the cost of getting it wrong is large, recovery is slow, and the consequences are institutional. It is not sector-specific.

The structured response to the gap

The decision governance gap is documented. The enforcement environment is active. The approach DecIQ® has built to address it, and the sequence it requires.

The DecIQ® approach

Entity disclosure