SERAP Asks Tinubu To Order Probe Into Suspected AI-Generated Voter Photos

The Socio-Economic Rights and Accountability Project (SERAP) has urged President Bola Tinubu to direct the National Commissioner and Chief Executive Officer of the Nigeria Data Protection Commission (NDPC), Vincent Olatunji, to investigate suspected artificial intelligence (AI)-generated photographs and other questionable records in the preliminary Register of Voters published by the Independent National Electoral Commission (INEC).

SERAP also wants the NDPC to determine whether personal data were unlawfully altered or accessed and whether the incidents constitute a breach of the Nigeria Data Protection Act 2023.

The call follows INEC’s publication of the preliminary Register of Voters and its subsequent acknowledgement of suspected AI-generated photographs and questionable registration records identified during the nationwide display of the register from October 9 to 15, 2026.

In a letter dated October 31, 2026, and signed by its Deputy Director, Kolawole Oluwadare, SERAP urged Tinubu to ensure that the NDPC establishes the nature and extent of the irregularities, identifies those responsible and provides affected Nigerians with an opportunity to verify and correct their records without being unfairly excluded from the electoral process.

“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.

SERAP added that “the security and accuracy of the voter register are fundamental to the protection of Nigerians’ personal data and their right to participate in public affairs.”

“Nigerians should not have to worry that their personal information could be altered, manipulated or accessed without proper safeguards,” it said.

The organisation said INEC’s acknowledgement of questionable records and suspected AI-generated photographs made an independent investigation particularly important.

“The public needs to know what happened, whether the law was breached and what measures are being taken to prevent a recurrence,” SERAP said.

It called for an independent forensic examination of the affected database and systems to determine whether personal data were unlawfully accessed or altered and whether INEC complied with the Nigeria Data Protection Act.

SERAP also urged the NDPC to establish whether the incidents constituted a personal data breach under Section 65 of the Act and whether INEC complied with its applicable notification and record-keeping obligations.

The organisation said the investigation should establish the number and geographical distribution of affected records, when and how they were created or altered, and the individuals or institutions responsible.

It further raised concerns about possible misuse of authorised access credentials by registration officers and alleged failures to protect the accuracy, integrity and security of personal data held by INEC.

“An internal review by INEC cannot substitute for the NDPC’s independent exercise of its statutory data-protection mandate,” SERAP said.

The organisation added that the reported irregularities were particularly concerning because INEC’s database contains the personal data of millions of Nigerians and is fundamental to the exercise of their constitutional and democratic rights.

“Any unlawful alteration, manipulation or compromise of this information could undermine public confidence in the electoral process, compromise the accuracy and reliability of the voters’ register, and expose eligible voters to the risk of wrongful exclusion,” it said.

SERAP called for corrective measures, including stronger security safeguards and accessible procedures through which affected voters could verify and correct their records without wrongful exclusion.

It also urged the NDPC to publish its findings and recommendations, subject to lawful protections, and ensure accountability where wrongdoing was established.

According to INEC’s statement of October 27, 2026, the commission acknowledged public concerns over “suspected AI-generated photographs appearing in the Preliminary Register of Voters” published on its website.

INEC said that during the nationwide physical display of the register from October 9 to 15, “a number of questionable registration records were identified and flagged for further examination”.

The commission said it had commenced a review and was taking “appropriate corrective action”.

It also acknowledged that the online publication “does not reflect all ongoing data-cleanup activities” and that it was “examining the circumstances surrounding the suspicious photographs, including possible technical or procedural lapses”.

INEC maintained that the preliminary register was not the final certified version and said it would complete the necessary verification, adjudication and data-cleanup processes before certifying the final Register of Voters on December 15, 2026.

SERAP said the Nigeria Data Protection Act gives the NDPC powers to investigate possible violations, obtain relevant information and documents, and require compliance by data controllers and processors.

It cited Sections 24 and 39 of the Act, which require personal data to be processed accurately and securely and protected against unlawful alteration, loss or unauthorised access.

The organisation also referenced Section 40, which requires data controllers to notify the NDPC of a personal data breach likely to pose a risk to individuals’ rights and freedoms within 72 hours of becoming aware of it.

SERAP further cited Section 37 of the Nigerian Constitution, which guarantees the right to privacy, as well as provisions of the African Charter on Human and Peoples’ Rights and the International Covenant on Civil and Political Rights protecting citizens’ rights to participate in government and vote in genuine elections.

It urged Tinubu to ensure that the requested measures were taken within seven days of the receipt or publication of its letter.

“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,” it warned.

The organisation said the reported irregularities must be independently investigated and addressed before the final register is certified, adding that Nigerians must be able to trust that the register on which the 2027 general elections will be conducted is accurate, reliable and adequately protected against manipulation.

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