Mastercard’s AI in Africa white paper provides an opportunity to clarify Africa’s AI governance and inclusion challenges, to highlight progress in emerging hubs like Nigeria, and to outline a practical roadmap of interventions that can shift the country and the region from passive adoption toward responsible AI creation.

This commentary reflects the perspective of its authors and does not represent the official position of iARAi or any other organisation mentioned. It is based on a close reading of Mastercard’s AI in Africa white paper (2025), alongside Nigeria’s recent policy frameworks and African Union strategies. No funding or support was received from Mastercard or any of the organizations referenced in this commentary.

Summary

AI has the potential to reshape Africa’s development trajectory, creating new opportunities for economic growth and millions of digital jobs, if deployed responsibly and inclusively.

Nigeria, Africa’s largest economy and home to its most populous youth demographic, is strategically positioned to lead the continent’s responsible AI transition. With the launch of the National Artificial Intelligence Strategy (NAIS 2024), the Nigeria Data Protection Act (2023), and the establishment of the National Centre for AI and Robotics (NCAIR), the country has laid a policy and institutional framework for innovation. Yet its progress is uneven: Nigeria recorded a score of 43.33 on the Government AI Readiness Index 2024, placing it within Africa’s top 15 but still trailing leaders such as Egypt, Mauritius, South Africa, and Rwanda. Yet Nigeria also faces significant obstacles, including limited digital infrastructure, fragmented data ecosystems, and the underrepresentation of local languages in AI models. 

This commentary examines Mastercard’s analysis through a Nigeria-first, AU-aligned lens. It identifies governance gaps and outlines four feasible policy moves:

• A National African Languages AI Programme;
• A Nigeria–AU AI Alignment Tracker;
• Sectoral Data Collaboratives in finance, agriculture, and health;
• Responsible AI procurement and sandbox reforms.

Together, these interventions would enable Nigeria to shift from being a consumer of imported models to a creator of inclusive, responsible, and sovereign AI systems that align with the African Union’s Continental AI Strategy (AU, 2024) and the Africa Declaration on Artificial Intelligence adopted in Kigali on the 4 April, 2025. 

Context: Mastercard’s Framing of AI in Africa

Mastercard’s AI in Africa report positions artificial intelligence as both an opportunity and a challenge for the continent’s economic and social development. On the opportunity side, the report notes that Africa’s youthful demographics, mobile-first digital infrastructure, and expanding entrepreneurial ecosystem provide fertile ground for AI adoption. The technology is already transforming sectors such as financial services, agriculture, education, energy, and healthcare, with applications ranging from digital payments to AI-driven farm advisory platforms.

The report estimates that the African AI market, valued at approximately USD 4.5 billion in 2025, could expand to over USD 16.5 billion by 2030 if barriers are addressed. It further highlights the potential for job creation, predicting that AI could contribute to as many as 230 million digital jobs across sub-Saharan Africa by the end of the decade.

At the same time, Mastercard underscores several risks. Infrastructure deficits remain acute: Africa accounts for less than one per cent of global colocation data centres, with a disproportionate concentration in South Africa. Data ecosystems are fragmented, with many government and institutional datasets siloed, outdated, or available only in inaccessible formats. Policy incoherence across 54 countries risks undermining regional integration. Finally, the exclusion of African languages from large-scale models perpetuates bias and limits accessibility, particularly for rural and marginalised populations. 

To address these gaps, Mastercard advocates principles-based, flexible regulation, built around values of transparency, fairness, accountability, inclusivity, privacy, and human oversight. It further recommends targeted investments in digital infrastructure, language resources, literacy, and data-sharing mechanisms to ensure that AI becomes a driver of inclusive growth.

Context: Nigeria 

Nigeria is profiled in Mastercard’s AI in Africa report as a leading hub for AI development on the continent. The country has taken important institutional steps, including the establishment of the NCAIR and the release of the NAIS in 2024, which sets out a vision for positioning Nigeria as a global leader in ethical and inclusive AI.

Nigeria has also attracted significant investment. In 2023, it secured USD 218 million in AI-focused venture capital, reflecting strong private-sector interest in generative and applied AI startups. Multinational actors are contributing to ecosystem growth: Google committed NGN 2.8 billion to support AI talent, while the government’s 3 Million Technical Talent (3MTT) programme aims to train 150,000 young Nigerians in digital skills as part of its first phase. Adoption is widespread, with Mastercard noting that 70% of Nigerians already use generative AI tools in some form, particularly in financial services. 

Despite these advances, systemic challenges persist. Nigeria ranks low on cloud and data infrastructure capacity, restricting local model training and compute sovereignty. The country’s data governance environment remains fragmented, even with the passage of the Nigeria Data Protection Act (2023), as datasets are often inaccessible or siloed. Moreover, heavy reliance on imported algorithms risks embedding bias and excluding Nigeria’s linguistic and cultural diversity.

In this context, Nigeria represents both the promise and the vulnerability of AI adoption in Africa: a fast-growing hub with policy ambition, but one that must close infrastructure, governance, and inclusion gaps to fulfil its potential.

Policy Gaps

While Mastercard’s AI in Africa report identifies Nigeria as a frontrunner in AI adoption, it also highlights governance and structural gaps that could undermine sustainable progress. Three interrelated issues stand out.

First, over-reliance on private sector innovation risks creating uneven outcomes. Much of Nigeria’s AI activity is driven by global technology firms and venture-backed startups, with insufficient mechanisms for public accountability or equitable access. Without robust state capacity to regulate and audit systems, sensitive domains such as financial services and healthcare could risk exacerbating inequality. Evidence shows that uneven regulatory capacity in Africa threatens equitable AI adoption and risks widening socio-economic divides. Globally too, the regulation of healthcare AI is still in its infancy and regulators are playing catch-up, since existing frameworks were never designed for a fast-evolving technology like AI, a warning sign for Nigeria.

Second, weak institutional mechanisms for AI oversight remain a challenge. Although the Nigeria Data Protection Act (2023) has created a legal foundation for data governance, there are limited pathways for conducting algorithmic audits, bias testing, or ensuring explainability in deployed systems. This gap is particularly concerning in areas such as credit scoring, fraud detection, and social service delivery, where opaque models may disproportionately disadvantage vulnerable groups.

Third, the exclusion of local languages and communities continues to constrain inclusivity. Mastercard emphasises that most large-scale AI models used in Nigeria are trained primarily on English and foreign datasets, leaving indigenous languages underrepresented. This not only limits accessibility for non-English speakers but also risks embedding systemic cultural bias into Nigeria’s AI ecosystem.

Together, these gaps underscore the need for Nigeria to complement private-sector dynamism with public-interest safeguards, ensuring AI adoption advances both innovation and equity.

Feasible Policy Moves

To address the gaps outlined above, Nigeria can adopt four policy interventions that are both achievable and aligned with Mastercard’s recommendations, while also building on existing African Union frameworks such as the Continental AI Strategy (AU, 2024) and the Kigali Declaration on Responsible AI (AU, 2024). Each move is grounded in Nigeria’s institutional capacity and leverages proven partners already active in Africa’s AI ecosystem.

National African Languages AI Programme (NALA)

Mastercard stresses that Africa’s linguistic diversity must be reflected in AI development, warning that imported models trained primarily on English or French risk excluding large populations. For Nigeria, where Yorùbá, Hausa, Igbo, and Naijá are widely spoken, language inclusion is both a democratic and developmental imperative.

NALA could be launched to create speech and text datasets, lexicons, and open benchmarks for local languages. Phase I would focus on the three major languages and Naijá, with later expansion to minority languages.

Feasibility is supported by existing capacity:

• Masakhane, a Pan-African natural language processing (NLP) network, has developed open-source translation and speech recognition models for African languages.
• Mozilla Common Voice has already collected Yorùbá and Hausa datasets, with active Nigerian contributors.
• Lanfrica curates a catalogue of African NLP datasets and models, enabling discoverability.
• Data Science Nigeria (DSN) has produced NaijaNER and runs grassroots AI training for youth.
• Funding mechanisms such as the AI4D Africa programme and the Lacuna Fund have supported dataset development in low-resource African languages.

This programme would align with AU’s Continental AI Strategy, which explicitly calls for strengthening datasets and ensuring inclusivity.

Nigeria–AU AI Alignment Tracker

Fragmented policies across Africa risk undermining coherence. Mastercard recommends regional coordination, and the AU has already set continental principles through the Continental AI Strategy (2024) and the Africa Declaration on Artificial Intelligence adopted in Kigali (2025).

To advance alignment, Nigeria could develop a public AI alignment tracker mapping delivery of NAIS 2024 against AU-level commitments. Such a dashboard would monitor indicators including:

• enforcement of the Nigeria Data Protection Act (2023),
• number of datasets made accessible,
• African language resources produced,
• AI pilots tested in sandboxes,
• procurement compliance with responsible AI guidelines.

This tracker would create transparency, reduce duplication, and demonstrate Nigeria’s commitment to continental harmonisation.

Partners for implementation could include:

• Paradigm Initiative (PIN), a Nigerian civil society organisation active in digital rights and AI policy.
• CIPIT (Strathmore Law School, Kenya), which has conducted AU strategy analysis.
• NDPC (Nigeria Data Protection Commission), which could supply enforcement metrics.

Such a tool would operationalise AU frameworks at the national level, offering a model for other member states.

Sectoral Data Collaboratives

Mastercard highlights fragmented data ecosystems as a barrier to innovation. Nigeria can pioneer sectoral data collaboratives that pool anonymised datasets across stakeholders for public-interest applications.

• Finance: Using the Central Bank of Nigeria’s Open Banking framework, banks and fintechs could share consented customer data for credit inclusion. This would allow thin-file borrowers to access credit scoring models without exposing sensitive information.
• Agriculture: Collaboration with Farmerline’s Darli AI, which currently provides farm advisory services in over 27 languages, could support Nigerian farmers with weather, pricing, and extension advice.
• Health: Drawing from Jacaranda Health’s UlizaLlama project in East Africa, Nigeria could pilot maternal and primary healthcare chatbots in local languages, ensuring safe triage and education functions.

These collaboratives would be governed under the NDPA (2023) to ensure privacy compliance, while delivering clear public value in financial inclusion, food security, and healthcare access.

Responsible AI in Procurement and Sandboxes

Mastercard urges governments to adopt balanced, principles-based regulation rather than prescriptive rules. In Nigeria, this can be achieved through procurement reform and sandbox adjustments.

• Public Procurement: The Bureau of Public Procurement (BPP) could update standard bidding documents to require Responsible AI Impact Assessments (RAIAs) for all AI-enabled contracts. These assessments would cover bias testing, explainability, data protection compliance, and audit rights.
• Regulatory Sandboxes: Agencies such as the Central Bank of Nigeria, the National Information Technology Development Agency, and the NDPC could integrate explicit AI model testing tracks in their sandboxes. These would ensure that algorithms used in credit scoring, fraud detection, or customer service meet responsible AI standards before full deployment.

Nigeria’s emerging data centre infrastructure, including Rack Centre and MDXi/Equinix facilities, provides the capacity to support compliance-friendly hosting for these systems, reducing reliance on offshore compute.

Summary of Feasibility

These four moves are achievable with current capacity. They build on Mastercard’s emphasis on infrastructure, data ecosystems, and responsible AI, while aligning Nigeria with AU’s inclusive governance agenda. By leveraging existing organisations such as Masakhane, Farmerline, and Jacaranda, and embedding responsible AI into procurement, Nigeria can transform principles into practice.

Recommendations

Nigeria’s AI trajectory should prioritise interventions that are both actionable and regionally coherent. Four recommendations follow directly from Mastercard’s analysis and AU frameworks:

1. Launch a National African Languages AI Programme in partnership with Masakhane, Mozilla Common Voice, Lanfrica, AI4D/Lacuna Fund, and Data Science Nigeria.
2. Develop a Nigeria–AU AI Alignment Tracker to map national delivery against AU commitments.
3. Operationalise sectoral data collaboratives in finance, agriculture, and health, ensuring compliance with the NDPA (2023).
4. Embed Responsible AI Impact Assessments in procurement and sandbox frameworks, mandating fairness, transparency, and oversight.

Together, these interventions would align Nigeria’s AI policies with continental strategies while advancing domestic inclusion and innovation. 

Conclusion

Mastercard’s AI in Africa report emphasises that the continent’s AI future depends on principles of inclusivity, fairness, and accountability, underpinned by investments in infrastructure, skills, and data ecosystems. Nigeria, with its policy frameworks and growing AI ecosystem, is positioned to lead this transformation. Yet to move from being an adopter of external technologies to a creator of Africa-fit AI systems, the country must anchor its policies in continental strategies such as the Continental AI Strategy and the Kigali Declaration. By advancing feasible interventions in languages, alignment, data, and procurement, Nigeria can demonstrate how responsible AI governance drives both sovereignty and inclusive growth.