Two Years of Reform at the FRC: Why Olowo’s “DOSE” Agenda Matters

By Abubakar Yusuf

When President Bola Ahmed Tinubu appointed Dr. Rabiu Onaolapo Olowo as Chief Executive Officer/Executive Secretary of the Financial Reporting Council of Nigeria (FRC) on October 24, 2023, many expected competence. Few anticipated the scale and speed of change that would follow. Two years on, the FRC has moved from a quiet regulator to a visible driver of corporate accountability, sustainability, and financial transparency—firmly aligned with the Renewed Hope Agenda.

What sets Olowo apart is not just his technocratic pedigree as a financial expert and former Lagos State Commissioner for Finance (2019–2023). It is the clarity with which he translated presidential policy into a practical, measurable programme—popularly framed as the “DOSE” agenda—backed by institutional restructuring, international partnerships, and a relentless emphasis on people, process, and performance.

Real reform starts with people. Olowo’s earliest moves focused on staff morale and institutional culture: clearing outstanding gratuities and severance, improving welfare and professional development, and engaging the workforce in decision-making. The result is tangible—over 60% staff engagement and an organisation better equipped, and more motivated, to enforce standards without fear or favour. A regulator that takes care of its people is far more likely to protect the public interest.

One of the least appreciated—but most consequential—shifts has been in actuarial development. Under Olowo, the FRC established the Nigerian Actuarial Development Programme (NADP) and a Technical Working Group to grow the profession locally. The Council adopted International Standards of Actuarial Practice (ISAPs 1–8) and initiated their localisation as Nigeria Standards of Actuarial Practice (NSAPs). It issued Nigeria’s first comprehensive Actuarial Practice Regulation (NAPR 2025) as an exposure draft.

This was not a paper exercise. Nationwide outreach engaged thousands of university and secondary school students, while select undergraduates received sponsorship for SOA examinations and an MSc in Actuarial Science. Strategic partnerships with NAICOM, PENCOM, NHIS, global actuarial bodies and regional peers deepened the pipeline. By moving actuarial capacity from aspiration to action, the FRC is laying the groundwork for more credible pricing of risk—and ultimately, a safer financial system.

Markets work when audits work. The FRC completed the first comprehensive practice reviews across 16 firms—including the Big Four—covering 143 engagements. It introduced the NOCLAR framework (FRC Rule 14), sharpening auditors’ responsibilities when confronted with non-compliance, and commenced implementation of internal controls over financial reporting (ICFR) guidance. The inaugural Leadership Summit for Auditors drew more than 700 practitioners, signalling a new era of engagement rather than mere enforcement by memo.

Internationally, the Council signed an MoU with The Gambia’s Financial Reporting Oversight Board, advanced the UK–Nigeria Enhanced Trade and Investment Partnership toward regulatory equivalence, and pursued mutual recognition with the FRC UK. Joint trainings brought in heavyweights like PCAOB (USA), IRBA (South Africa), and ICAG (Ghana). This is how credibility is built: through inspection, education, and peer benchmarking.

Regulation is most effective when it reflects local realities. The FRC developed two landmark codes—the Nigeria Public Sector Governance Code (NPSGC) and the Not-for-Profit Governance Code (NNFGC)—now awaiting ministerial approval. It convened critical stakeholders across the Judiciary, OAGF, AuGF, Head of Service and the Governors’ Forum, crafting a 2026–2029 roadmap that is already shaping behaviour.

Crucially, the Council completed and issued the Small and Medium Enterprises Corporate Governance Guidelines (SME-CGG) and promoted Business Integrity Certification (BIC), tying governance to resilience for smaller firms. Partnerships with the LCCI and Integrity Organisation have begun to translate principles into practice in the MSME space—where every naira of trust matters.

Under Olowo, sustainability reporting has shifted from marketing gloss to market discipline. With the support of President Tinubu and the former Minister of Industry, Trade and Investment, the FRC launched Nigeria’s roadmap for the ISSB’s IFRS S1 and S2. Early adoption by Access, Fidelity, MTN and Seplat Energy across the 2023 and 2024 cycles put Nigeria on the global map. By October 2025, voluntary adopters had grown from four to 35 entities.

This is not mere signalling. Through 32 sector engagements and two regulatory roundtables—most recently in August 2025—over 1,700 professionals and 200 institutions have been trained in disclosure practice. Strategic MoUs with NIRC, GIZ, FSDA, PAFA and the ISSB are building the technical backbone for consistent, comparable reporting. For investors, this means better pricing of climate and transition risk; for Nigeria, it means credibility in a world where capital follows quality information.

Valuation is where theory meets transaction. The FRC established a Technical Working Group, secured Nigeria’s membership of the International Valuation Standards Council (IVSC), and publicly exposed the country’s first Valuation Regulations. Trainings across four geopolitical zones reached over 200 professionals and 900+ stakeholders, alongside a nationwide Valuation Guide. These are foundational moves for fairer public asset management, sounder bank collateral, and cleaner capital markets.

Reform must be visible in systems. The FRC now runs a full complement of seven Directorates, with new Directorates for Valuation Standards and Actuarial Standards, plus a Sustainability Reporting Unit and an Islamic Financial Services Department for non-interest oversight. It integrated its database with the National Identification Number (NIN) system, deployed a Document Management System and a Learning Management System, and launched Nigeria’s first National Repository Portal for audited financial statements—a centralised database that lifts transparency and enables analytics.

Communication has kept pace: regular newsletters (ISSN: 3092-9520) and the new Journal of Financial Reporting and Corporate Governance position the Council as a genuine thought leader—not just a rule-issuer. The market has responded: in two years, 31,799 professionals, 715 firms, and 14,657 companies registered with the FRC, reflecting rising compliance and confidence.

Sceptics will ask whether all this can last. That depends on three things. First, sustained political backing for standard-setting and enforcement—especially for the public sector and not-for-profit codes—so that good policy is not stranded at the point of approval. Second, continued investment in people: actuaries, inspectors, analysts, and policy drafters who make standards live on the ground. Third, technology and data—because modern regulation is as much about timely information and analytics as it is about rules.

Yet it is hard to miss what has changed. In two years, the FRC has moved from reactive to proactive; from siloed to collaborative; from paper trails to digital rails. It has cleaned its own house, cared for its people, and raised expectations across the market. That is how public institutions earn trust: by delivering, consistently.

The FRC’s trajectory under Dr. Rabiu Olowo is not a miracle; it is management. It is also a message—to auditors, boards, CFOs, public officials, NGOs, and MSMEs—that the era of casual compliance is over. The “DOSE” agenda has given the market exactly what it needs: direction, order, standards, and execution.

If Nigeria is serious about unlocking investment, deepening capital markets, managing fiscal risks, and competing in a sustainability-conscious world, we must keep this momentum. Regulation should never be a roadblock to growth. Done right, as the FRC now shows, it is the road.

Abubakar Yusuf is a public affairs analyst. He can be reached at [email protected].