Between October 2024 and February 2026, something happened in Nigeria’s power sector that has received less attention than the well-documented grid collapses and the headline-grabbing debt figures, yet carries deeper long-term implications for how energy investment flows into the country. Fifteen state governments formally assumed regulatory control of their intrastate electricity markets, a process coordinated by the Nigerian Electricity Regulatory Commission (NERC) under the framework of the Electricity Act 2023. The states, cutting across multiple regions, include Enugu, Ekiti, and Ondo (October 2024), Imo (December 2024), Oyo and Edo (early 2025), Kogi (March 2025), Lagos (June 4, 2025), Ogun and Niger (mid-2025), Plateau (September 2025), Abia and Anambra (around the turn of 2026), with Nasarawa and Bayelsa completing their transitions in February 2026.
This is not a mere administrative reshuffle. It represents a structural redistribution of the authority to license operators, set tariffs, drive investment, and enforce consumer protection from a single federal body in Abuja to State Electricity Regulators (SERs) embedded in local economic and political realities. The Electricity Act 2023 removed electricity from the exclusive legislative list, enabling states to generate, transmit, and distribute electricity within their borders—a legal shift now being converted into operational reality at a pace that has surprised even close observers.
Why State-Level Regulation Changes Investment Arithmetic
Under the old federal monopoly, an off-grid developer, a mini-grid operator, or a commercial and industrial solar provider navigated one regulatory interface: NERC in Abuja. The Electricity Act 2023 has fractured that interface across multiple jurisdictions, each with its own regulatory commission, its own tariff-setting process, its own licensing timelines, and its own appetite for attracting energy investment. NERC retains oversight of interstate electricity activities, including generation, transmission, and multi-state distribution operations, but states with functional regulatory systems now exercise authority over intrastate electricity markets, embedded generation, and mini-grid development.
A recent PwC report noted that more than 15 states are now at different stages of activating electricity markets, and that their readiness provides early evidence that decentralisation is producing differentiated regulatory and commercial conditions across the federation[reference:3]. “At the same time, federal attention is concentrating on areas where failure would affect the entire market, regardless of state boundaries,” the report observed. “These include transmission performance, grid reliability, large-scale metering deployment, subsidy exposure, and technical capacity across the sector.”
What this means in practice is that the investment climate for energy projects is no longer a single national variable. It is now a state-by-state variable. A developer evaluating a 5 MW mini-grid project in Oyo deals with the Oyo State Electricity Regulatory Commission, not NERC. The timelines, fees, and engagement dynamics will differ from those in, say, Nasarawa or Lagos.
Nasarawa’s Open Invitation: A Model for State-Level Investment Attraction
Several states are already using their new regulatory authority to differentiate themselves as investment destinations. Nasarawa State, which completed its regulatory transition in February 2026, offers a case in point. The state government has introduced tax holidays and legal protections specifically designed to attract renewable energy investors, allocating 5% of State Internally Generated Revenue (IGR) to de-risk private energy investments and support enabling infrastructure such as roads, water, and power connections. Governor Abdullahi Sule’s administration has made clear that energy investment is a strategic priority, not a bureaucratic afterthought—a posture that would have been impossible under the old federal-only framework.
Lagos State, which transitioned on June 4, 2025, represents a different kind of signal: its status as Nigeria’s largest electricity market means that the Lagos State Electricity Regulatory Commission now oversees the most commercially significant intrastate electricity market in the country. For companies targeting commercial and industrial customers—factories, shopping malls, hospitality groups, data centres—the Lagos regulator is now the primary regulatory counterpart, not NERC. Understanding the priorities, processes, and personnel of that single state regulator is now more commercially valuable than a general understanding of federal electricity policy.
The Opportunities and the Frictions
Decentralisation creates genuine opportunities for companies that invest in local regulatory intelligence. States competing for energy investment are incentivised to streamline approvals, offer incentives, and build reputations as business-friendly jurisdictions. But the PwC report also flagged growing intergovernmental alignment challenges as the multi-tier market takes shape. “These frictions are a normal phase of reform, requiring clearer definition of regulatory roles, transitional reporting arrangements and dispute-resolution processes,” the report noted, cautioning that “without such clarity, unresolved issues around subsidies, tariff assumptions, levies and regulatory authority could create uncertainty for investors and distort emerging state electricity markets.”
The practical consequence is that companies cannot simply assume a uniform regulatory environment across Nigeria. They must track developments in each state where they intend to operate, build relationships with multiple State Electricity Regulators, and develop the capacity to engage with different licensing processes, tariff methodologies, and reporting requirements. The companies that invest in this capability will secure approvals faster, structure projects more efficiently, and avoid the delays that come from treating the Nigerian energy market as a single regulatory entity.
Where Policy Meets Business Development
Policy shifts of this scale create a specific, urgent demand among international energy companies: they need to understand how a specific state’s regulatory framework applies to their product category, target customer segment, and preferred commercial model. They need introductions to the right officials in the right State Electricity Regulators. They need visibility on the procurement pipelines that state-level regulatory autonomy is beginning to unlock—from mini-grid tenders to embedded generation licensing rounds to public-sector solarisation programmes.
The Nigeria International New Energy & Power Industry Expo (NNEPIE) 2026, scheduled for September 16–18 at the Landmark Centre in Lagos, is designed to serve this exact function. NNEPIE convenes the regulatory authorities driving this decentralisation—representatives from State Electricity Regulators, NERC, the Rural Electrification Agency, and the Federal Ministry of Power—alongside the equipment manufacturers, EPC contractors, project developers, and investors who need to engage with them directly. Structured B2B and B2G matchmaking sessions translate policy analysis into commercial introductions. For companies evaluating market entry strategies in a decentralising regulatory landscape, three days of concentrated engagement with the regulators who now hold licensing and tariff-setting authority across 15 states offers an efficiency that remote, state-by-state relationship-building would take months to replicate.
Visit www.nnepie.com for the full conference agenda, list of participating state regulators, and exhibitor prospectus.
NNEPIE 2026: Powering West Africa’s Sustainable Energy Future.
