The global infrastructure investment gap continues to widen, and public finances alone cannot fill it. Public-Private Partnership (PPP) is seen by many governments as a key tool, but in many economies, PPP project pipelines have long suffered from the dilemma of "many projects, few reaching financial close." The recent reform practices of Nigeria's Infrastructure Concession Regulatory Commission (ICRC) provide a valuable case for examining "how to make PPPs truly attract private capital." This article attempts to unpack the institutional logic behind its reforms and asks: What can investment promotion agencies learn from this?
1. Why are so many PPP projects "well-received but not landing"?
Infrastructure projects involve large capital outlays and long return cycles, making private investors naturally cautious. When evaluating a project, they look not only at the financial model but also at the institutional environment. If approval processes are opaque, rules are inconsistent, and contract standards are chaotic, even an economically viable project can be classified by investors into a higher-risk category—or abandoned altogether.
A common misconception is that governments treat PPP as a means of attracting investment, hoping to lure investors with tax incentives, land support, and other inducements. But experience shows that incentives only address marginal issues; they cannot replace institutional certainty. A PPP project from initiation to financial close often involves multiple government agencies: the sector authority, the finance ministry, land and environmental agencies, the central bank or foreign exchange regulator, and more. Unpredictability in any one link can derail the transaction.
This was exactly the case in Nigeria previously: individual government departments handled PPPs independently, with inconsistent standards and lengthy approval cycles, making it difficult for investors to form stable expectations. This was the background against which the ICRC's reforms took place.
2. Three key changes by Nigeria's ICRC
Under Ewalefoh's leadership, the ICRC's reforms have focused on three directions.
First, tiered approval to make authority visible
Under the new rules, projects valued at 20 billion naira or below are directly approved by the corresponding ministry; projects of 10 billion naira or below are approved by the subordinate agencies and relevant bureaus of the ministry; only projects exceeding the threshold or involving multiple ministries are submitted to the Federal Executive Council. This seemingly simple change is of significant substance. It transforms "vague high-level approval" into "clear tiered decision-making," enabling project sponsors to anticipate the review pathway from the start and reducing unnecessary delays.
Second, standardized contracts to reduce transaction costs
The ICRC has issued a Model PPP Agreement to provide a unified contract template for all ministries and agencies. Although transaction structures vary by project, standardized core clauses and risk allocation principles help investors grasp the contractual framework more quickly. For legal and financial advisers, this means fewer point-by-point negotiations and lower due diligence costs.
Third, a unified regulatory gateway to strengthen institutional credibilityThe presidential directive requires that all forms of PPP projects must be reviewed by the ICRC, regardless of whether the project is called a "concession," "joint venture," or "privatization." This measure closes the loophole of "circumventing oversight" and ensures that all projects are assessed under the same standards. For investors, it means that a responsible national institution is vetting projects for bankability, risk allocation, and value for public money, rather than facing entirely different rules across different departments.
Behind these three changes lies a shift in understanding of the nature of PPP. PPP is no longer seen as "another form of government procurement" but as "a form of transaction in the capital market," which must follow the language and discipline of the capital market.
III. A Reusable Methodological Framework from Nigeria’s Practice
For investment promotion agencies (IPAs) and relevant government departments, the Nigerian case provides a "three-phase" framework for diagnosing and improving the environment for promoting infrastructure projects.
Phase 1: Institutional Diagnosis and Transparency
Don’t rush to package projects. The first step is to map the entire process of a project from concept to financial close, marking every approval node, decision-making department, and time limit. Then make this flowchart public to the market. Investors are not afraid of long processes; they are afraid of processes that are unknowable. A transparent process itself sends a signal that "the government respects transactions."
Phase 2: Process Reengineering and Standards Development
On the basis of the diagnosis, promote tiered approval, standardized templates, and cross-departmental coordination mechanisms. Tiered approval must balance administrative efficiency with preventing risk from spiraling out of control. A permission matrix can be established based on dimensions such as amount, cross-departmental nature, and fiscal risk. Standardized templates should include core clauses on risk allocation, price adjustment mechanisms, dispute resolution, and early termination, while allowing deviations in special circumstances with regulatory approval.
Phase 3: Transaction Support Aimed at "Bankability"
Investment promotion agencies need to build a team familiar with project finance, or bring in external transaction advisors, to help the government design the project structure during the tender preparation phase in a form that financial institutions can understand and are willing to lend to. This includes: reasonable risk allocation, clear demand forecasts, explicit government support mechanisms, and independent review of the project pipeline. Bankability is not written into project documents; it is designed into the structure.
At the same time, three common pitfalls should be avoided:
- Tiered approval does not mean opening the door to rent-seeking; electronic approval tracking and regular audits are needed;
- Standardized contracts should not be applied mechanically; an application channel for "exception clauses" should be reserved;
- Unified regulation must not become a new bottleneck; internal service time limits and an appeal mechanism should be established.
IV. New Directions Worth Watching
Investment promotion for infrastructure projects is becoming intertwined with new technologies and global issues. The following directions deserve continued attention from practitioners.
1. Open Data and Digital Project ArchivesWhen making decisions, investors value data reliability above all. If the government can publish key project indicators, contract summaries, geographic information, environmental data, and historical performance in machine-readable formats, it will significantly enhance the credibility of the project pipeline. Digital project archives can even help investors conduct preliminary risk screening and reduce information asymmetry.
2. AI-Assisted Review and Risk Warning
AI can handle tasks such as contract consistency checks, approval deadline alerts, and historical project risk analysis. Regulators introduce AI not to replace professional staff, but to automate part of professional knowledge so that review speed can keep pace with the market.
3. ESG and Green Infrastructure Preferences
Global capital is accelerating its shift toward ESG (Environmental, Social, and Governance), and infrastructure investors are paying increasing attention to a project's impact on climate and communities. If PPP projects can incorporate green standards and social assessments at the early design stage, they are more likely to connect with long-term capital such as pension funds and sovereign wealth funds.
4. Multilateral Capital and Geopolitical Competition
Infrastructure development has become an important arena for international competition. Different countries and regions have their own funding instruments and project implementation standards. Investment promotion agencies need to understand the preferences and compliance requirements of capital from different sources in order to help local projects find the most suitable capital partners.
Conclusion
The reform of Nigeria's ICRC is still ongoing, and its true achievement will depend on how many projects can successfully reach financial close, be completed, and enter operation in the coming years. But the logic of the institutional design is already clear: in infrastructure investment promotion, "providing certainty" matters more than "offering incentives."
Every country and every city has its own institutional environment and cultural background, but the universal direction is the same—reduce uncertainty, lower transaction costs, and make capital willing to stay.
For global investment promotion practitioners, one question deserves repeated reflection: Are we marketing projects, or are we building a market where projects automatically attract capital? The answer determines long-term competitiveness.