17/08/2026
POSITION OF THE CHURCH AND SOCIETY AGENCY ON THE FOREIGN AID (REGULATION, TRANSPARENCY AND DISCLOSURE) BILL, 2026 (SB. 1034).
*1.0 INTRODUCTION*
1.1 The Church and Society Agency of the United Methodist Church – Nigeria Episcopal Area has carefully reviewed the provisions of the Foreign Aid (Regulation, Transparency and Disclosure) Bill, 2026 (SB. 1034).
1.2 We affirm the legitimate objectives of the Bill to promote transparency, accountability, and responsible utilisation of foreign assistance in Nigeria.
1.3 However, we are concerned that several provisions, particularly those relating to the establishment and powers of the proposed Foreign Aid Regulatory Commission (FARC), may have unintended consequences for religious organisations, faith-based institutions, charitable bodies, and civil society organisations.
1.4 Accordingly, the Church and Society Agency respectfully submits that *SB. 1034 should not be passed in its present form*.
Our position is not an objection to accountability. It is a call for a regulatory framework that ensures accountability without unduly restricting the legitimate religious, humanitarian, charitable, and developmental work of organisations operating in Nigeria.
*2.0 THE VITAL ROLE OF RELIGIOUS ORGANISATIONS IN NATIONAL DEVELOPMENT*
2.1 Religious organisations are critical partners in nation-building. Beyond worship, they contribute significantly to moral formation and social wellbeing.
2.2 The United Methodist Church, through its ministries and institutions, is actively involved in:
- Moral and ethical formation
- Education and skills development
- Healthcare and humanitarian assistance
- Poverty alleviation and livelihood support
- Youth and children development
- Care for vulnerable persons
- Peacebuilding and reconciliation
- Community development
- Advocacy for justice, human dignity and responsible citizenship
2.3 Any legislation regulating the finances of religious institutions must therefore recognise, respect, and protect this indispensable role.
*3.0 CONCERN OVER OVERBROAD APPLICATION*
3.1 Section 2 of the Bill applies to “NGOs, CSOs and private entities receiving foreign aid.” This definition is broad and could inadvertently capture religious and faith-based organisations receiving legitimate donations, grants, or technical assistance for religious, humanitarian, and community development purposes.
3.2 Religious and charitable institutions should not be subjected to excessive regulatory requirements simply because they receive lawful support from international partners.
3.3 A clear distinction must be made between organisations engaged in commercial or high-risk financial activities and genuine religious, humanitarian, and charitable institutions.
*4.0 NO JUSTIFICATION FOR ANOTHER REGULATORY AGENCY*
4.1 The proposed Foreign Aid Regulatory Commission (FARC) will duplicate existing mandates.
4.2 Institutions such as the Office of the Auditor-General, Accountant-General, EFCC, ICPC, NFIU, CBN, and CAC already have statutory powers over financial accountability, auditing, anti-corruption, and organisational regulation.
4.3 Creating FARC will lead to: duplication of functions, overlapping mandates, unnecessary bureaucracy, increased public expenditure, regulatory conflicts, and additional compliance burdens.
4.4 We recommend that Government strengthen coordination and capacity of existing institutions instead.
*5.0 PROTECTION OF CONSTITUTIONAL FREEDOMS*
5.1 The Agency is concerned that excessive governmental oversight may infringe on constitutional rights to freedom of religion, conscience, expression, and association.
5.2 While Government has a duty to prevent fraud and diversion, such regulation must not result in unwarranted interference with legitimate religious and charitable activities.
*6.0 POTENTIAL IMPACT ON HUMANITARIAN AND DEVELOPMENT PROGRAMMES*
6.1 Foreign grants and donations fund critical interventions in education, healthcare, relief, poverty alleviation, and support for vulnerable populations.
6.2 Excessive registration, reporting, inspection, and audit requirements will cause delays, increase costs, and ultimately affect the communities who depend on these services.
*7.0 CONCERNS ON PUBLIC DISCLOSURE*
7.1 While we support transparency, the proposed National Foreign Aid Register must balance openness with safeguards for privacy, confidentiality, and security of donors, partners, and beneficiaries.
7.2 Sensitive information should be protected to avoid exposing organisations and individuals to risk.
*8.0 DISPROPORTIONATE PENALTIES*
8.1 Section 13 proposes a minimum fine of *₦5,000,000* for individuals, *₦20,000,000* for organisations, imprisonment of up to 5 years, and possible suspension of operations.
8.2 These penalties are excessive for administrative or technical breaches. The law should differentiate between deliberate fraud and inadvertent errors.
8.3 A graduated enforcement approach — warnings, corrective notices, and reasonable compliance periods — is more just and effective.
*9.0 RISK OF DISCOURAGING LEGITIMATE PARTNERSHIPS*
9.1 Nigeria still requires international partnerships in health, education, humanitarian response, and poverty reduction.
9.2 An overly restrictive regime will discourage donors and development partners, thereby hurting the very communities the Bill seeks to help.
*10.0 OUR RECOMMENDED APPROACH*
10.1 Rather than create a new Commission, Government should:
1. Strengthen coordination among existing regulatory agencies
2. Establish a centralised information-sharing portal within an existing agency
3. Adopt uniform, risk-based and proportionate reporting standards
4. Improve monitoring of donor-funded projects
5. Explicitly safeguard religious and humanitarian activities
6. Apply proportionate sanctions with right of appeal
*11.0 RECOMMENDATIONS*
The Church and Society Agency respectfully recommends that:
1. *SB. 1034 should not be passed in its present form.*
2. *The proposed FARC should not be established.*
3. The objectives of the Bill be pursued through existing institutions.
4. Future legislation must contain explicit safeguards for religious, faith-based, and humanitarian organisations.
5. Religious and faith-based organisations must be meaningfully consulted before enactment.
6. Regulatory requirements must be proportionate, risk-based, and subject to due process.
*12.0 CONCLUSION*
12.1 The Church and Society Agency affirms the need for transparency and accountability in the management of foreign assistance.
12.2 However, accountability must not come at the expense of religious freedom or the vital work of faith-based organisations that are partners in promoting morality, peace, justice, compassion, and human dignity.
12.3 We therefore respectfully urge the National Assembly to *reject SB. 1034 in its present form* and undertake broad consultations with religious organisations, CSOs, and development partners before enacting any new framework on foreign aid.
Submitted for and on behalf of the
*Church and Society Agency*
United Methodist Church – Nigeria Episcopal Area
Mrs Serostina Phillip Johnson
Coordinator/Director
Church and Society Agency
UMC Nigeria Episcopal Area
