In 2012 Nigeria issued a consultation paper on amendments to the Copyright Act, including a scheme for suspension of subscriber accounts after three warning notices from right holders. The subscriber is entitled to challenge a right holder notice by means of a counter-notice. In the event of dispute as to the counter-notice, the matter is to be referred to the Nigerian Copyright Commission, which may appoint an independent adjudicator to determine the validity of the challenge. It appears that the ISP is subject to action by the right holder for an injunction, in case it fails to operate the scheme.
On 30 October 2015, the Copyright Commission published a draft Copyright Bill for comments. Unlike the 2012 proposal, the Bill is a complete new copyright code. The proposed graduated response system has been retained (Clause 47 of the Bill). The consultation remains open until 5 January 2016 and comments can be submitted via a dedicated web site at http://reform.copyright.gov.ng/.