Regulatory Update: Public Private Partnerships

Introduction

The Infrastructure Concession Regulatory Commission ("ICRC"), in August 2025 issued the PPP Regulatory Notice (the 'Notice'), pursuant to the powers conferred on it under Section 34 of the Infrastructure Concession Regulatory Commission Act (the "ICRC Act"). The Notice introduced significant changes to the approval thresholds for PPP projects in Nigeria. In September 2025, the ICRC also released a new set of guidelines to regulate the development and implementation of Public-Private Partnerships (PPPs) in Nigeria ("the Guidelines").

This review focuses on the Notice and the Guidelines, examining the implication for investors, project developers and public institutions while highlighting the opportunities that were presented by the revised framework.