The Code of Corporate Governance for Banks and Discount Houses was released by the Central Bank of Nigeria (CBN) in 2014 to regulate Banks and Discount Houses (“The 2014 Code”). Subsequently, in 2018, the CBN released the Code of Corporate Governance for other Financial Institutions in Nigeria (“The 2018 Code”). The 2014 and 2018 Codes set out guidelines to enhance Corporate Governance practices for Banks and Financial institutions in Nigeria and were in operation until 2019 when the Financial Reporting Council (FRC) of Nigeria issued the Nigerian Code of Corporate Governance, 2018 (“NCCG 2018”) as the single corporate governance code regulating private and public entities in Nigeria. NCCG 2018 replaced all sectoral codes in Nigeria including the 2014 and the 2018 Codes.

Consequently, on July 13, 2023, the CBN released Corporate Governance Guidelines for Commercial, Merchant, Non-Interest and Payment Service Banks in Nigeria (“the Guidelines”) . The Guidelines were developed in line with the Principles and Recommendations of NCCG 2018, and supersedes all previous codes, circulars, and related directives on corporate governance issued by the CBN.

This paper will analyse the key provisions of the Code vis a vis the 2014 Code, and discuss some of the legal and governance implications for the banking industry in Nigeria.