September 26, 2025
Daniel Akinyami

A Comparative Study of Secured Transactions Laws: Nigeria and Selected Jurisdictions

This comparative study evaluates the evolution and effectiveness of Nigeria's secured transactions framework, primarily the Secured Transactions in Movable Assets Act (STMA) 2017 and the Companies and Allied Matters Act (CAMA) 2020 against international benchmarks, including the U.S. Uniform Commercial Code Article 9, English floating charges, French specialised pledges, and the UNCITRAL Model Law. While the STMA has significantly broadened credit access by unlocking movable assets for small and medium-sized enterprises (SMEs), persistent challenges in implementation, notably the ambiguity created by the overlap between the National Collateral Registry and CAMA's registry, and protracted judicial enforcement timelines, deter creditor reliance.

The analysis highlights that the non-recognition of floating charges (unlike in England) and the lack of non-judicial remedies (unlike the U.S.) severely restrict financing flexibility for dynamic asset pools like inventory and receivables. Accordingly, the paper recommends actionable legislative reforms: expanding the STMA’s scope to include intangible assets, introducing a highly-regulated, self-help repossession mechanism, and harmonising the existing fragmented registry systems into a unified digital platform to unlock substantial capital for SMEs and foster sustainable economic development in Nigeria.

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