The Socio-Economic Rights and Accountability Project (SERAP) has given President Bola Tinubu seven days to order an independent forensic investigation into suspected AI-generated photographs and alleged manipulation of voters’ records by officials of the Independent National Electoral Commission (INEC).
SERAP warned that it would consider legal action if the Federal Government failed to direct the Nigeria Data Protection Commission (NDPC) to investigate the reported irregularities ahead of the 2027 general elections.
The organisation made the demand in a letter dated October 31, 2026, and signed by its Deputy Director, Kolawole Oluwadare.
It asked Tinubu to direct the NDPC Chief Executive Officer, Vincent Olatunji, to establish the extent of the suspected alterations, identify those responsible and determine whether the commission breached the Nigeria Data Protection Act 2023.
The demand follows INEC's acknowledgement of questionable registration records and suspected AI-generated photographs discovered during the nationwide display of the preliminary Register of Voters between October 9 and 15.
In a statement on October 27, the electoral commission said it had flagged suspicious records for further examination and commenced corrective measures.
INEC also disclosed that it was investigating the circumstances surrounding the photographs, including possible technical and procedural lapses.
The commission said the preliminary register was not the final certified document, promising to complete its verification and data-cleanup exercises before certifying the final register on December 15, 2026.
However, SERAP argued that INEC's internal review was insufficient, insisting that the NDPC must independently investigate the incident because of its responsibility for protecting Nigerians' personal information.
“The reported irregularities raise serious concerns about the security and integrity of Nigerians’ personal data and the reliability of the voter register ahead of the 2027 general elections,” the organisation said.
It urged the data protection commission to conduct a forensic examination of INEC's affected database and systems to determine whether personal information was unlawfully accessed or altered.
SERAP also raised concerns about the possible misuse of authorised access credentials by voter registration officers, saying the investigation should establish whether officials introduced questionable records into the database.
The organisation said the NDPC should determine whether the incident constituted a personal data breach under Section 65 of the Nigeria Data Protection Act and whether INEC fulfilled its notification and record-keeping obligations.
Under Section 40 of the Act, data controllers are required to notify the NDPC of a breach likely to pose risks to individuals' rights and freedoms within 72 hours of becoming aware of it.
SERAP further asked the commission to establish the number and geographical distribution of affected records, when the alterations occurred and the individuals or institutions responsible.
It called for corrective measures, stronger security safeguards and accessible procedures allowing affected Nigerians to verify and correct their details without being unfairly excluded from the electoral process.
The organisation also urged the NDPC to publish its findings and recommendations, subject to lawful protections, and ensure accountability where wrongdoing was established.
SERAP warned that failure to investigate the allegations could undermine public confidence in the electoral process and expose eligible voters to wrongful exclusion.
“We would be grateful if the requested measures are taken within seven days of the receipt and/or publication of this letter. If we have not heard from you by then, SERAP shall consider appropriate legal actions and other lawful measures,” it said.
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