The Socio-Economic Rights and Accountability Project (SERAP) has given President Bola Tinubu seven days to order an independent investigation into suspected AI-generated photographs and alleged manipulation of personal data in the Independent National Electoral Commission’s (INEC) preliminary Register of Voters.
In a letter dated October 31, 2026, and signed by its Deputy Director, Kolawole Oluwadare, the organisation urged the President to direct the National Data Protection Commission (NDPC) to probe the irregularities, determine whether they breach the Nigeria Data Protection Act 2023, and identify those responsible.
SERAP warned that the reported irregularities raised serious concerns about the security of Nigerians’ personal data and the reliability of the voter register.
“The NDPC should exercise its statutory powers independently and without delay. Any investigation must establish the facts, protect affected voters and ensure that those responsible for any unlawful conduct are held accountable,” the organisation said.
It threatened legal action if the demand is ignored. “If we have not heard from you by then, SERAP shall consider appropriate legal actions and other lawful measures to compel your government, the NDPC, INEC and other relevant authorities to comply with our requests in the public interest,” the letter stated.
INEC’s admission
The demand followed INEC’s acknowledgement of suspected AI-generated photographs and questionable registration records, which were identified during the nationwide display of the preliminary register from October 9 to 15, 2026.
In a statement issued on October 27, the commission said the flagged records were being examined further. It also acknowledged concerns about suspected AI-generated photographs in the preliminary register published on its website.
According to SERAP, INEC said it had begun a review and was taking corrective action, including examining possible technical or procedural lapses. The commission reportedly added that the online publication did not reflect all ongoing data-cleanup activities and that the preliminary register was not the final certified version.
INEC said it would complete verification, adjudication and data-cleanup before certifying the final Register of Voters on December 15, 2026.
‘Internal review not enough’
SERAP, however, insisted that only an independent investigation by the NDPC could establish the full circumstances and ensure accountability.
“An internal review by INEC cannot substitute for the NDPC’s independent exercise of its statutory data-protection mandate,” it said.
The organisation asked the NDPC to:
- conduct an independent forensic examination of the affected database and systems to determine whether personal data was unlawfully accessed or altered, and whether INEC complied with the Nigeria Data Protection Act 2023;
- establish the number and geographical distribution of affected records, when and how they were created or altered, and who is responsible;
- determine whether the incidents amount to a personal data breach under Section 65 of the Act, and whether INEC met its notification and record-keeping obligations; and
- publish its findings and recommendations, subject to lawful protections.
SERAP also expressed concern that the irregularities could involve unlawful alteration or processing of personal data, misuse of authorised access credentials, and inadequate safeguards against unauthorised access or manipulation.
Call for corrective measures
The group called for stronger security safeguards and accessible procedures that would allow affected Nigerians to verify and correct their records without being wrongfully excluded ahead of the 2027 general elections.
It cited Section 37 of the Nigerian Constitution, which guarantees the right to privacy, as well as Article 13 of the African Charter on Human and Peoples’ Rights and Article 25 of the International Covenant on Civil and Political Rights, which protect citizens’ right to take part in government and vote in genuine elections.
SERAP warned that any unlawful alteration or compromise of the voter database could erode public confidence in the electoral process, affect the accuracy of the register and expose eligible voters to wrongful exclusion.
It added that failure to investigate before the final register is certified could jeopardise eligible voters’ participation in the 2027 general elections.
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