Data Governance in Nigeria’s Petroleum Sector: Legal Framework for Subsurface Data Management

This study examines the legal framework governing subsurface geological and geophysical data management in Nigeria's petroleum sector, assessing the adequacy of current data governance provisions under the PIA 2021 and NUPRC data management regulations. Petroleum subsurface data is a high-value national resource, and its proper governance has implications for exploration investment, regulatory oversight, and national energy planning. Using a doctrinal legal analysis methodology, the research critically reviews PIA 2021 Chapters 7 and 8 on data sovereignty and the NUPRC's Data Management and Storage Regulations. Comparative frameworks from Australia and Brazil, where national petroleum data agencies have been established, are also analysed. Findings indicate that Nigeria lacks a standalone petroleum data governance law, creating ambiguities regarding data licensing, sharing obligations, and third-party access rights. The study recommends establishing a National Petroleum Data Repository with clear legal authority for data custody, access, and commercial licensing. These findings are relevant to petroleum engineers, data scientists, and legal scholars engaged in digital governance of extractive resources. Keywords: data governance, subsurface data, PIA 2021, NUPRC, petroleum regulation.