Introduction
On August 26, 2025, the Nigerian Electricity Regulatory Commission (“NERC”), pursuant to Section 34 of the Electricity Act (the “Act”), issued the Order on the Mandatory Implementation of Free Governor Control (the “Order”), which took effect from September 1, 2025. In this Newsletter, we examine key highlights of the Order.
Purpose
According to NERC, the national grid had suffered eight (8) disturbances in 2024, comprising five (5) full system collapses and three (3) partial failures. The Transmission Company of Nigeria Plc identified non-compliance with the Grid Code by certain Generating Companies (“GenCos”) as a key contributing factor.
In response, the Order seeks to establish a structured framework to enhance reliability of power generation and, in turn, the stability of the national grid by mandating strict compliance with the Grid Code on the deployment and activation of Free Governor Control (“FGC”) in all generating units.
“Free Governor Control”
The stability of the national grid is critical to electricity supply in Nigeria. As discussed in our Mid-Year Report on the Nigerian Power Sector, under the Grid Code, the acceptable operational frequency range for the grid is ±0.5% from 50Hz (49.75Hz to 50.25Hz). Due to the fragility of the grid, any significant variation in frequency can lead to partial or total system collapse.
One of the key causes of frequency variation is the mismatch between generation and demand (i.e., higher generation with lower demand/load, or vice versa). The deployment of FGC seeks to address this risk. In simple terms, a governor is a control mechanism in a generator that automatically adjusts energy or fuel input to increase or reduce output, in response to changes in load. This helps balance supply with demand in real time, thereby supporting grid stability.
Although the deployment of the FGC is both global best practice and an explicit requirement under our Grid Code, prior to now, it was not strictly enforced. If only a few GenCos deploy FGC while others rely on manual adjustments to manage frequency deviations, the result would be inefficiency, excessive strain on compliant GenCos, higher mechanical wear, and significant financial burdens.[6] By mandating strict compliance across all GenCos, the Order ensures that this responsibility is evenly shared, ultimately improving efficiency and stability in the grid.
