Two Federal High Court judgments in Abuja, on 27 January and in early May 2026, stopped the Nigerian Bar Association from making CPD for lawyers a condition of practice. In Ghana, a 12-hour yearly requirement stands but its link to licence renewal is disputed. For CPD providers, the open question is the same in both countries: who can prove that the learning happened?
Key facts
- On 27 January 2026, Justice M.G. Umar of the Federal High Court, Abuja (suit FHC/ABJ/CS/1238/2025), restrained the NBA from enforcing its 2025 CPD rules as a condition for appearing in court.
- A second Abuja judgment, reported on 8 May 2026, voided Rules 11 and 12 of the Rules of Professional Conduct and the NBA’s CPD policy as a whole.
- Ghana’s Legal Profession (Professional Conduct and Etiquette) Rules 2020 (L.I. 2423) require at least 12 hours of continuing professional development per calendar year.
- NBA President Mazi Afam Osigwe SAN told the association’s National Executive Council it would keep promoting CPD through incentive-based mechanisms.
What did the Nigerian courts actually strike down?
The NBA’s National Executive Council approved the Mandatory Continuing Professional Development (MCPD) Rules on 6 February 2025. They set a floor of five hours a year for every lawyer, replacing an older ladder of 24, 18 and 12 hours based on years since call. The sanction was heavy. A lawyer who fell short would miss the Annual Practising List and could not sign or file documents.
Victor Ozioma Nwadike challenged that link. In January, Justice Umar held that the rules were invalid “insofar as they impose extra conditions on a lawyer’s right of audience,” according to the summary published by the Council on Licensure, Enforcement and Regulation (CLEAR). A report by TheNigeriaLawyer reads the reasoning narrowly: the problem is the absence of statutory backing in the Legal Practitioners Act, not continuing education as a policy.
The May ruling by Justice B.F.M. Nyako went further. On 9 May the NBA’s General Secretary, Dr. Mobolaji Ojibara, defended the stamp and seal regime but offered no separate defence of CPD.
Ghana: a rule on paper, a fight over enforcement
Ghana’s position is different. Rule 84 of L.I. 2423 already obliges licensed lawyers to complete twelve hours a year and report them to the General Legal Council. In May 2023, then Chief Justice Kwasi Anin Yeboah told 196 newly enrolled lawyers in Accra that the hours would become a condition for licence renewal, as the Daily Graphic reported. A Ghana Bar Association communiqué of 2 January 2024 demanded proof for 2025 renewals, though The Law Platform noted that Rule 84 itself does not tie renewal to attendance.
| Nigeria | Ghana | |
|---|---|---|
| Rule | NBA MCPD Rules 2025 | L.I. 2423, Rule 84 (2020) |
| Annual minimum | 5 hours | 12 hours |
| Link to practice | Voided by Federal High Court, 2026 | Asserted by the bar, contested |
| Likely next step | Voluntary or incentive-based CPD, or amendment of the Act | Legal Profession Bill |
Why voluntary CPD needs better records, not fewer
Once compliance is voluntary, the evidence has to persuade. An incentive scheme only works if a firm, a client or a court registry can check a claim quickly. Paper certificates handed out at a seminar in Lagos or Kumasi rarely pass that test.
This is the gap BBadges is built for. BBadges is the skills vertical of LutinX, whose technology is owned by Lutin Technologies Inc. and commercialised by 8ID Ltd. Its first market is continuing legal education in English-speaking Africa, with Ghana, Nigeria and Ethiopia in focus. According to the company, every organisation that issues a BBadge passes identity checks (KYC/KYB) and follows EdVerso guidelines, so there are no anonymous issuers. Each badge is anchored on a blockchain and has a public verification page, and event attendance can be checked in with a QR code in seconds.
Lawyers keep their records in “The Booklet,” which is free for people and theirs for life. It can import Open Badges 3.0 and W3C Verifiable Credentials from other providers, and holders who verify their identity get a blue “verified” check. The model already runs at scale in schools: Campus Editore and its Salone dello Studente fairs in Italy issued around 500,000 BBadges in the 2025/26 school year.
A verified badge does not settle the dispute in Abuja. It does give a lawyer a record that survives the next rule change.
What this means for CPD providers and trainers
- Issue per session. A badge for each accredited hour or seminar is easier to audit than a single annual letter.
- State the content. Name the topic, the trainer, the date and the hours on every credential, so a reviewer in another jurisdiction can read it without calling you.
- Check who issues. Accreditation of the issuer matters as much as the badge. Ask whether your platform verifies institutions or just email addresses.
Earlier coverage on credential trust: Why Trust in Degrees Is Becoming the Quiet Crisis of Global Education and Blockchain Credentials Redefine Lifelong Learning.
FAQ
Is CPD for lawyers still required in Nigeria?
Two 2026 Federal High Court judgments stopped the NBA from enforcing CPD as a condition of practice. The NBA has said it will promote CPD through incentives; an appeal had not been reported at the time of writing.
How many CPD hours do Ghanaian lawyers need?
L.I. 2423 sets a minimum of twelve hours per calendar year, reported to the General Legal Council.
Can BBadges import existing certificates?
The Booklet imports Open Badges 3.0 and W3C Verifiable Credentials, and only KYC-verified organisations can issue new BBadges.
Sources: NBA-ICLE statement on MCPD Rules; CLEAR: Nigeria ruling on lawyer CPD; TheNigeriaLawyer: analysis of FHC/ABJ/CS/1238/2025; TheNigeriaLawyer: second judgment; NBA statement, 9 May 2026; Daily Graphic; The Law Platform; BBadges.
