Did Nigeria’s states protect their communities — or just sign paperwork? An Exclusive Investigation by KEHINDE ADEGOKE.
The Federal Government of Nigeria has published the Terms of Reference for the engagement of an independent social audit firm to investigate large-scale agricultural land investments in approximately 20 states — a process that will directly determine whether billions of naira in World Bank-backed performance payments flow to those states before the end of 2026.
Investigation by TheDiggerNews reveals that the consultancy is scheduled to begin in March 2026 and run for twelve months, concluding in March 2027. This schedule marks it as one of the most consequential aspects of Nigeria’s $750 million (≈ ₦1.04 trillion) State Action on Business Enabling Reforms (SABER) programme, now in its fourth and final year.
What The Audit Covers
The audit, officially described as a Social Audit under Disbursement Linked Indicator 1.2.2 of the SABER programme, will assess whether states that have piloted agricultural land investments under the Framework for Responsible as well as Inclusive Land-Intensive Agriculture — known as FRILIA — have done so in genuine compliance with binding principles on community consultation, environmental protection, resettlement, compensation, and grievance redress.
The Terms of Reference document, published by the Home Finance Department of the Federal Ministry of Finance, sets out two core tasks for the firm to be hired. The first requires the auditors to determine the extent to which investors and state government institutions actually complied with the FRILIA framework in approved pilot investments, and to assess whether affected communities received any measurable benefit.
The second — broader in scope — requires the firm to examine whether state laws adequately protect land rights, specifically the land and natural resource rights of women, and whether state agencies are properly mandated to enforce the framework.
The document states that each state subject to the audit must have established a grievance mechanism, developed a multi-stakeholder monitoring committee, and completed an environmental and social management plan as conditions of a valid pilot investment. The audit will verify whether any of this actually happened in practice.
The Timeline: This Month
Section 8 of the document specifies: “The consultancy will begin in March 2026 and will be conducted continuously over a 12-month period, expected to end by March 2027.” This sets clear start and end points for the audit process.
This means that, as of today, the Federal Ministry of Finance’s Programme Coordinating Unit — housed in the Home Finance Department and led by its Director, who serves as the National Programme Coordinator — is either in the final stages of selecting the audit firm or has already done so. The selection is governed by the World Bank’s Procurement Regulations for IPF Borrowers, using the Consultant Qualification Selection Method under an Open Market Approach.
The document confirms that only states with at least one confirmed pilot investment, as verified by the Programme Coordinating Unit, will be subject to the social audit — currently estimated at 20 out of the 36 states and FCT eligible for the programme.
₦1.04 Trillion Rides On The Outcome
The SABER programme, originally designed as a three-year initiative running from 2023 to 2025, was extended by one additional year to 2026 following a joint agreement between the Federal Government and the World Bank. The programme consists of a $730 million (≈ ₦1.01 trillion) Program-for-Results component — under which states are paid for achieving verified reform results — and a $20 million (≈ ₦27.7 billion) technical assistance component that funds the audit firm itself.
The payment structure for the social audit firm reflects the financial weight placed on its findings. According to the Terms of Reference, 15% of the contract value is payable on submission of an inception report and the completion of a kick-off workshop. A further 70% — the bulk of the contract — is paid upon submission and acceptance of the individual social audit reports for the twenty states, on a prorated basis. The final 15% is paid on a final report comparing findings across states.
Critically, the document states that all audit reports will be subjected to technical review by the Programme Coordinating Unit in collaboration with the World Bank, and that this review may include calls for reassessment by the audit firm. This means the body commissioning the audit retains the power to send findings back for revision before disbursement decisions are made.
Who Is Being Hired — And What They Must Do
The Terms of Reference set demanding qualification requirements for the firm to be selected. It must be a top-tier audit or consulting firm — or a consortium of up to three firms — with at least 10 years of operational existence and at least 2 similar assignments completed within the last 7 years. The firm must have demonstrated expertise in social audits, land tenure, land administration, and sustainable land-intensive agricultural investment, expressly within Nigeria.
The document requires the firm to field a minimum of six key experts: a Senior Land Policy expert, a Senior Investment Policy expert specialising in agriculture, a Senior Social Audit expert, a Gender expert with specific knowledge of land tenure gender issues, an Environmental and Social Impact Assessment expert, and a Land Law expert with experience in Nigerian land law. All must hold master’s degrees and have at least eight years of relevant professional experience each.
The firm must additionally have physical representatives in both the North and South of Nigeria. The scope of work requires the firm to administer surveys, conduct desk-based reviews, conduct key informant interviews, and conduct physical field visits in each state being audited. The document confirms that the firm will travel to states to conduct on-the-ground audits.
PEBEC’s Undisclosed Role
The Terms of Reference also confirm a dimension of the Presidential Enabling Business Environment Council’s role that its public communications have not addressed. While PEBEC has this week been publicly presenting its 90-Day Business Environment Enhancement Programme Accelerator — engaging agencies including NOTAP — the SABER document confirms that the PEBEC Secretariat is itself a listed implementing agency under the $750 million programme, delivering technical assistance to states alongside the Debt Management Office.
The Nigeria Governors Forum is also identified in the document as a formal implementing partner, engaged by the Federal Ministry of Finance’s Home Finance Department Programme Coordinating Unit. The nature and terms of that engagement have not been openly disclosed by either the NGF or the Federal Government.
The Community Gap
A review of the full Terms of Reference shows a considerable structural silence: while the audit is expressly designed to assess community benefits, grievance mechanisms, and the extent of stakeholder comprehension and backing for the FRILIA framework, the document contains no requirement that affected communities be formally notified that an audit of the land investment on their territory is taking place.
The document defines “stakeholders” broadly — including the investor, affected land rights holders, the wider affected community (including women, men, and youth), and the government authorities that assessed and approved the investment.
Yet the mechanism for reaching those communities is left entirely to the firm’s discretion, within a timetable set by the Programme Coordinating Unit. Land rights specialists have long argued that social audits only carry legitimacy when the communities being audited are active participants in the process — not simply subjects of it.
