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GI-ESCR and Partners Submit Proposals for Nigeria’s Finance Bill 2027

GI-ESCR and Partners Submit Proposals for Nigeria’s Finance Bill 2027

Nigeria has introduced four landmark tax reform laws, which came into force on 1 January 2026. The reforms have been considered a good step in the right direction by many schools of thought, both nationally and around the world. One of the major results expected from this reform process is to unlock trillions of naira in new revenue annually from those who have the resources to pay more. However, the initial stage of implementation exposed some fundamental gaps. Some Nigerians believe that things are not going to change greatly.

In August 2026, the Federal Government, through the Federal Ministry of Finance, issued a memo aimed at reshaping Nigeria's ongoing fiscal reform landscape to be more equitable and supportive of economic growth. The Ministry invited Nigerian citizens to submit proposals on the laws and their implementation.

GI-ESCR, in collaboration with national civil society organisations, submitted a response, which you can find below this section. This action also serves as one of the advocacy drives under the #PayTax4Wetin campaign, seeking to address the growing tax burden on low-income earners and small businesses, the lack of transparency in tax incentives and the need for a more progressive and accountable tax system in Africa's largest economy.

 

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Nigeria’s Fiscal Reform Context and Its Significance

 

The Finance Bill 2027 proposals emerge against the backdrop of Nigeria's most ambitious fiscal overhaul in decades. On 26 June 2025, President Bola Ahmed Tinubu signed four landmark tax reform bills into law: the Nigeria Tax Act 2025, the Nigeria Tax Administration Act 2025, the Nigeria Revenue Service (Establishment) Act 2025 and the Joint Revenue Board (Establishment) Act 2025, which formally commenced on 1 January 2026. These statutes consolidated over 50 fragmented taxes into a unified code, replacing a dense web of overlapping legislation that had historically driven up compliance costs and litigation. The reform agenda was framed as a corrective response to decades of structural imbalance, aiming to broaden the tax base, modernise administration and reduce Nigeria's chronic over-reliance on oil revenues.

The underlying fiscal challenge is stark. Nigeria's tax-to-GDP ratio has hovered between 6 and 10 per cent for over a decade, one of the lowest globally and far below the OECD average of 25 to 35 per cent. With rising debt-service obligations and declining oil revenues, the Federal Government faced a structural revenue crisis that demanded far-reaching reform rather than incremental amendment.

The first year of implementation has revealed significant challenges. A January 2026 survey by SBM Intelligence found that 68.5 per cent of respondents completely distrust the government's use of tax revenues, and higher levels of awareness often correlated with stronger opposition. Better understanding appeared to foster scepticism rather than support. Resistance has been rooted, not merely in economic hardship, but in a deep trust deficit between citizens and government, compounded by fears over fiscal centralisation and the visible use of tax proceeds. Allegations of legislative irregularities, including discrepancies between the versions of the Nigeria Tax Administration Act 2025 passed by the National Assembly and those later gazetted, further eroded public confidence. The reforms also reignited long-standing debates over federal-state fiscal power, with experts warning that consolidating fiscal authority at the federal level without recalibrating state powers could undermine the spirit of federalism.

These implementation challenges underscore the importance of the Finance Bill 2027 as a corrective mechanism. The Federal Ministry of Finance opened public consultations in August 2026, inviting businesses, professional bodies, civil society organisations, academics and other stakeholders to submit practical, evidence-based legislative recommendations by 11 September 2026. The Ministry specifically called for proposals identifying gaps, ambiguities, inconsistencies and implementation difficulties in existing laws, with priority given to evidence-based recommendations. Critically, contributors were advised to go beyond general observations by identifying the specific law and provision requiring amendment and, where possible, providing proposed drafting language, a framework that the proposals below directly respond to.

 

The Proposals: What the Finance Bill 2027 Should Achieve

 

The Finance Bill 2027 proposal outlines several critical reforms designed to address both the structural and trust-related challenges of the fiscal reform process.

A central pillar is the introduction of CPI-indexed Personal Income Tax (PIT) bands. This measure would automatically adjust tax brackets for inflation, preventing ‘fiscal drag’, where rising wages push low- and middle-income earners into higher tax brackets without a real increase in purchasing power. This directly protects disposable income and enhances the fairness of the tax system. This is particularly urgent, given that Nigeria's headline inflation has remained in double digits for eight consecutive years, averaging over 18 per cent between 2022 and 2025.

For small businesses, the proposal introduces a transitional company regime. This creates a ‘glide path’ for companies graduating from the small-company tax rate to the standard rate, smoothing the ‘growth cliff’ that can discourage expansion and encourage artificial fragmentation. This is coupled with an anti-fragmentation rule to protect government revenue.

Furthermore, the proposal seeks to embed fairness in tax administration. This includes:

  • A proportionality clause for penalties, ensuring they are proportionate to the tax at risk and the taxpayer's circumstances, with a focus on compliance notices for first-time, non-revenue-losing defaults by small businesses. This is especially important given that the new Nigeria Tax Administration Act 2025 introduced substantial monthly penalties for filing defaults, which the organised private sector has criticised as strangulating SMEs during the first quarter of 2026.
  • Safeguards on security deposits for tax appeals, ensuring access to justice for taxpayers with limited liquidity. This responds directly to concerns that gazetted provisions, including a mandatory 20 per cent deposit for appeals, were introduced without legislative approval, potentially restricting access to the Tax Appeal Tribunal.
  • A robust digital-search safeguard to protect privacy and legal privilege during tax investigations, balancing enforcement powers with constitutional protections.
  • Increased transparency for tax incentives and remissions, requiring published statements of legal basis, cost and distributional impact, and ensuring they expire unless renewed by the National Assembly. This addresses the call from the Financing for Development (FFD) Forum 2026 for Nigeria to engage seriously on tax expenditures, recognising that revenue foregone is just as important as revenue collected.

The advocacy efforts are backed by a coalition of partners, including economic and social rights organisations and tax justice advocates, who bring expertise in fiscal policy, human rights law and public finance to the table. Through strategic collaboration, the campaign aims to build a broad consensus for these reforms, highlighting their potential to reduce inequality and spur sustainable economic development.

 

Conclusion

 

As the campaign gains momentum, it underscores the importance of collective action in addressing Nigeria's fiscal challenges. With a diverse coalition of partners and a clear objective in sight, the advocacy initiative is poised to make significant strides towards a more just and prosperous Nigeria.

The reforms underway are not merely technical adjustments; they are a test of whether Nigeria's political and institutional environment can translate higher revenue into national development rather than deeper public resentment. The Finance Bill 2027 represents a critical opportunity to course-correct, addressing implementation gaps, restoring public confidence and ensuring that the tax system serves as a foundation for development rather than a source of extraction. As the Joint Revenue Board itself acknowledged after reviewing the first year of reform, the second year must focus on translating legislative reforms into effective administrative transformation and delivering measurable outcomes for taxpayers.

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Climate and Environmental Justice

We have advanced rights-based and gender-transformative transition frameworks through research that centres the lived experiences of women and marginalised communities on the frontlines of extractive energy policies, promoting climate and energy frameworks attentive to the social and care-related impacts of transition pathways. We have developed a clear vision for a gender-just transition, firmly rooted in gender and human rights norms, establishing both the legal basis and the direction for the transformative changes our planet and societies urgently need. In particular, the ‘Guiding Principles for Gender Equality and Human Rights in the Energy Transition’, a collective effort built through online consultations, an in-person workshop and multiple rounds of revision with activists, practitioners and experts from around the world, outline a transformative vision for reshaping global energy systems through a human rights and gender equality lens.

Our work recognises that the climate emergency is both an existential threat and an opportunity to reimagine societies built on social, gender, economic and environmental justice. We ground our advocacy in feminist and intersectional principles, prioritising the agency and perspectives of communities in the Global South who have contributed the least to the climate emergency yet face its most devastating consequences. Central to our approach is the understanding that energy is not merely a commodity but a fundamental human right; essential for dignity, health, education, work and the realisation of countless other rights. We challenge approaches to the energy transition that risk replicating the harmful patterns of fossil fuel extraction and, instead, advocate for transformative policies that ensure human rights and gender equality as central to building climate-resilient societies rooted in dignity, justice and planetary well-being.

What's next?

We will continue to challenge approaches that treat energy transition as merely a technical shift, instead positioning it as an opportunity to reimagine economies and societies rooted in dignity for all, with particular attention to communities in the Global South who have contributed least to the climate emergency yet are most exposed to its worst effects.

We will connect community-level evidence and the lived experiences of those on the frontlines of extractive policies to national reform and global norm-setting, breaking down silos between human rights, gender, and climate movements, and advancing a shared vision that recognises just transitions as not only fundamental to achieving climate-resilient and sustainable societies, but as transformative pathways that advance social and gender equality, redistribute power and resources equitably, and ensure that energy systems serve the public good rather than profit.

We will mainstream rights-based and genderjust transition priorities in key multilateral spaces (particularly, within the Just Transition Work Programme and the to-be-developed Just Transition Mechanism, within the UNFCCC) to guarantee that just transitions are advanced at all levels.

We will also translate our work, through strategic advocacy, into at least two concrete policy wins, whether promoted, adopted, implemented, or scaled, in priority countries (Argentina, Brazil, Chile, Mexico, Colombia, South Africa, or Kenya), ensuring these policies align with human rights standards, centre gender equality, and reflect the needs and views of affected communities.

We will build momentum for the progressive recognition of the right to sustainable energy to shift dominant narratives away from purely extractive solutions that sideline gendered impacts, community participation, and Global South perspectives.

Economic Justice and Climate Finance

Our work has transformed the global discussion on fiscal policy in a more just, emancipatory and sustainable direction. Our approach has combined both high-level, expert contributions within decisionmaking circles, with bold, impactful work on narrative change with the general public.

We have been instrumental in the inclusion of human rights as a guiding principle of the future United Nations Framework Convention on International Tax Cooperation, a multilateral instrument with the potential of raising approx. USD 492 billion per year in public revenues currently foregone to global tax abuse. In the process leading to the ‘Compromiso de Sevilla’ decided at FfD4, we proposed and succeeded in creating a specific human rights workstream within the Civil Society Financing for Development Mechanism, which was critical to ensure that explicit commitments on the matter were included in the negotiating outcome. In a context of cutbacks in multilateral institutions, we have amplified the capacities of technical experts, providing rigorous technical support and leveraging our influence to ensure the enactments of groundbreaking standard-setting instruments, such as the 2025 UN Committee on Economic, Social and Cultural Rights Statement on Fiscal Policy and Human Rights, and the first ex oficio hearing on the Inter-American Commission of Human Rights on Fiscal and Economic Policies to Address Poverty and Structural Inequality, leading to an upcoming thematic resolution on the matter. We have also bridged the silos between multilateral tax discussions and climate finance debates, promoting ambitious financing commitments to increase international and domestic resource mobilisation during COP 28, 29 and 30.

At the regional level, our engagement with fiscal cooperation platforms such as the Platform for Fiscal Cooperation of Latin America and the Caribbean (PTLAC), where we are member of its Civil Society Consultative Council, and the African Anti-IFFs Policy Tracker, for which we participated in the pilot mission in Ivory Coast together with Tax Justice Network Africa (TJNA), have been critical in cementing a growing engagement between tax administrations and ministries of finance with international legal experts, exploring actionable and transformative initiatives, such as the taxation of high-net-worth individuals, beneficial ownership registries and corporate countryby-country reports, to be implemented at the international level.

At the local level, our interventions in fiscal reform debates in Chile, Brazil, Colombia and Nigeria have contributed to shaping legislative outcomes in a more progressive, rights-compliant direction.

As for our leadership in narrative change, we have a measurable track record in delivering tailored, innovative campaigns which have decisively expanded economic justice constituencies by appealing to a broader tent. In Latin America and the Caribbean, we created the ‘Date Cuenta’ campaign, coordinating over 40 organisations across civil society to deliver plain language, innovative messaging connecting progressive fiscal reforms to the financing of health, education and social protection. ‘Date Cuenta’ generated over 55 original campaign messages that were tailored to the realities of seven priority countries (Argentina, Chile, Colombia, Mexico, Paraguay, Peru and Honduras) and disseminated in Spanish, Portuguese and English. In doing so, we convened more than 65 online co-creation workshops with partners, coordinating a unified communications strategy which combined digital outreach, press and media coverage, and collaboration with influencers. Ultimately, ‘Date Cuenta’ resulted in more than 60,000 interactions on social media, coverage in major regional and international media outlets, including El País, Deutsche Welle, Bloomberg and France 24, and the participation of at least 63 social media influencers through 58 dedicated publications. In collaboration with Fundación Gabo and the Friedrich Ebert Stiftung, we also organised a two-day workshop in Bogota with 20 journalists from 13 countries, building a regional network trained in a human rights-based approach to fiscal policy that has since generated published media coverage on outlets such as La Diaria, Ciper, El Diario Ar and Milenio. Through ‘Date Cuenta’ and our regional advocacy, we strengthened civil society engagement in key processes, including the Financing for Development track and FfD4, co-organised highlevel dialogues with states and civil society from Latin America and Africa.

What's next?

We will shape the UN Tax Convention and its Protocols so they embed human rights principles, and we will stay engaged through follow-up processes (including the expected Conference of the Parties) to support effective implementation. We will keep linking tax and climate finance so that new resources mobilised through fiscal cooperation are channelled to adaptation, mitigation, and loss and damage, in line with UNFCCC commitments.

Public Services for Care Societies

We have translated participatory research into accountability and policy outcomes.

In Ivory Coast, our work with Mouvement Ivoirien des Droits Humains and affected communities since 2023 exposed how privatisation and lack of accountability restrict access to quality healthcare. It contributed to the closure of 1,022 illegal private health centres, an executive instrument strengthening the regulation of private hospitals across the country, and the creation of a permanent complaints management committee in healthcare through a bylaw issued by the prefect of Gagnoa. Partners engaged through this process also advanced concrete improvements at facility level: members of the Gagnoa Midwives Association who took part in the participatory action research pooled resources to renovate the neonatal unit of the Regional Hospital, and the Director of the Gagnoa General Hospital launched an action plan to expand services and improve patient reception, with the facility receiving the award for best hospital in the country in 2025.

In Kenya, our research with the Mathare Education Taskforce documented the absence of public schools and the expansion of private provision, evidencing impacts on households and caregivers and strengthening demands for free, quality public education. This work contributed to stronger community agency and collective organisation, alongside ongoing strategies ranging from communications to litigation to secure a public school in the area, some involving GI-ESCR and others led independently.

Across Africa, this work is complemented by a multi-country study examining the human rights implications of austerity in education and health, including how regressive fiscal policies, rising debt burdens and persistent underinvestment undermine the financing and delivery of public services.

In Latin America, from 29 November to 2 December 2021, over a thousand representatives from over one hundred countries, from grassroots movements, advocacy, human rights, and development organisations, feminist movements, trade unions, and other civil society organisations, met in Santiago, Chile, and virtually, to discuss the critical role of public services for our future. Following the meeting, the Santiago Declaration on Public Services was adopted to demand universal access to quality, gender-transformative and equitable public services as the foundation of a fair and just society.

We are currently advancing work on care systems, linking public services and fiscal justice through integrated research, advocacy and communications, including a regional campaign framing care as a collective responsibility requiring sustained public investment.

What's next?

In Ivory Coast, we will evaluate and strengthen the complaints management committee and position it as a replicable model for other health facilities. In Kenya, we will support the Mathare community to co-design a model public school for Mabatini and Ngei wards, grounded in human rights standards. Building on our multi-country austerity study, we will drive national advocacy on financing for education and health: advancing reforms in Ghana; launching a fiscal policy and public services financing agenda in Kenya through the CESCR process and targeted coalition work; and, in Nigeria, using the new tax acts in force since 1 January 2026 to catalyse a national accountability campaign for adequately funded, quality public services. In Latin America, we will amplify locally led care pilots across 8 countries and turn lessons into influence—advancing care policies that strengthen care organisations, protect care workers’ rights, support unpaid caregivers, include disability and family networks, and redistribute care more equitably.