NCC’s Zero-Rating Education Data Plan Could Avoid Mistakes Made During South Africa and Kenya’s Pandemic-Era Rollouts

Nigeria is not the first country to attempt zero-rated access to educational platforms. It is, in fact, arriving relatively late to a policy conversation that much of the world had, for better and worse, already conducted under crisis conditions years earlier.

That lateness, however, may turn out to be Nigeria’s advantage.

South Africa

The COVID-19 Precedent: South Africa’s Rushed but Instructive Experiment

South Africa offers the most directly comparable case study, and its experience is worth examining closely because Nigeria’s Joint Committee appears to have absorbed several of its lessons.

In 2020, South Africa’s communications regulator required electronic communications licensees to provide zero-rated access to local educational content websites.

The Internet Service Providers’ Association of South Africa maintained a continuously updated authorized list of nearly 1,000 zero-rated websites covering resources from government departments, universities, and colleges.

The programme was widely described as the world’s largest intervention of its kind, negotiated directly between the government and mobile network operators in response to the pandemic’s abrupt shift to remote learning. But South Africa’s programme, born of emergency rather than deliberate design, ran into precisely the kinds of operational problems Nigeria’s consultation paper is now trying to pre-empt.

A key documented weakness was insufficient information dissemination; parents, learners, and teachers frequently did not know which sites were actually pre-approved for zero-rating, undermining uptake regardless of how generous the underlying policy was.

Technical complications also surfaced: embedded content like videos on institutional websites was sometimes blocked, and at least one South African university lost its zero-rating facility entirely after migrating its learning management system to a cloud-based version hosted outside the country.

Nigeria’s consultation paper directly addresses both failure points. Its proposed monitoring framework explicitly tracks platform diversity and complaint/redress mechanisms, a direct response to the awareness gap that hampered South Africa’s rollout.

Furthermore, its definitional debate over .edu domains versus curated platform registries reflects an awareness that hosting and platform migration issues need to be resolved before launch, not discovered after.

Kenya

…the Partnership-Led Model

Kenya’s most recent zero-rating initiative offers a different structural template. In October 2025, Airtel Kenya activated free access to the Kenya Education Cloud and the Elimika teacher-development platform, built on Airtel Africa’s five-year, 57-million-dollar partnership with UNICEF spanning 13 countries. That programme operates alongside a parallel data-support initiative providing participating public primary schools with 300 GB of monthly data allocation for digital learning, scaling up from an initial pilot of 30 schools.

The Kenyan model is narrower in scope than what Nigeria is contemplating; it zero-rates a small number of named platforms rather than establishing a broad approval or portal framework. However, it benefits from a defined, well-resourced funding partner in UNICEF, sidestepping the sustainability question that dominates Nigeria’s consultation paper. Nigeria’s Joint Committee, by contrast, is attempting to design a self-sustaining, multi-stakeholder funding model from the outset, a more ambitious but considerably harder problem to solve.

UNICEF’s broader involvement across Kenya extends to the Giga School Connectivity Programme, which has supported the zero-rating of educational platforms alongside direct school connectivity investment.

This illustrates a pattern across much of Sub-Saharan Africa in which zero-rating is paired with parallel infrastructure investment rather than treated as a standalone intervention.

Beyond Kenya, the UNESCO-coordinated Global Education Coalition has supported similar zero-rated access arrangements through operators including Orange across Burkina Faso, Guinea, Mali, and the Democratic Republic of Congo, with extensions planned for Botswana, Cameroon, C?te d’Ivoire, Liberia, and Madagascar.

India

The Cautionary Case: India’s Outright Rejection of Zero-Rating

The most important comparative case for Nigeria’s Committee to study closely is not an African one; it is India’s, and it points toward the most serious unresolved risk in Nigeria’s current framework.

In 2016, India’s telecom regulator, TRAI, effectively banned Facebook’s Free Basics zero-rating programme on net neutrality grounds, ruling that allowing price differentiation based on the type of content being accessed would undermine the fundamental basis on which the internet had developed.

The decision followed sustained public mobilisation against what critics characterised as a two-tier internet that handed gatekeeper control over accessible content to a single company.

TRAI’s resulting regulation, the Prohibition of Discriminatory Tariffs for Data Services, barred any service provider from charging discriminatory tariffs for data services based on content, with penalties of up to roughly 50,000 rupees per day for violations.

The distinction India’s regulator drew matters enormously for Nigeria’s current consultation. Free Basics was a commercially motivated zero-rating arrangement between a private platform and telecom operators, structured to drive user acquisition for Facebook. Nigeria’s proposed programme is government-initiated, education-specific, and explicitly time-bound.

That distinction is precisely why the Joint Committee’s consultation paper devotes an entire section to the net neutrality question rather than treating it as settled. The Committee appears acutely aware that an improperly designed programme could attract exactly the kind of regulatory and civil society backlash that killed Free Basics in India.

South Africa’s own net neutrality analysts noted that the absence of clear regulatory guardrails around its educational platform registry created uncertainty for ISPs about the scope of coverage and placed pressure on network bandwidth, precisely the ambiguity Nigeria’s Committee is trying to resolve before launch rather than after.

The Market Distortion Risk Other Countries Have Not Fully Solved

Kenya’s earlier experience with zero-rating, including Safaricom’s Wikipedia Zero and Airtel’s Internet.org suite, operated for years with no formal net neutrality regulation and no national regulator decision on whether zero-rating was permitted or merely tolerated. That regulatory vacuum allowed the practice to proliferate without the competitive safeguards Nigeria’s Committee is now explicitly trying to build in from the start, specifically, the risk that dominant operators could zero-rate proprietary content to entrench market share at the expense of smaller competitors and education technology startups.

This is a problem few examined jurisdictions have solved cleanly. Regulatory analysts in South Africa pointed to Brazil and Chile as comparative examples of countries that have built net neutrality regulation explicitly permitting zero-rated services deemed to be in the public interest.

This is a regulatory architecture closer to what Nigeria’s NCC Code of Internet Practice already provides for, but one that still requires the kind of competitive safeguard design Nigeria’s Committee has flagged as unresolved.

Where Nigeria’s Design Appears More Sophisticated

Three elements of Nigeria’s proposed framework stand out as more rigorous than the precedents reviewed:

The time-bound transition model: A defined 12-month zero-rated pilot with bi-annual reviews, followed by a planned transition to subsidised paid bundles, is more disciplined than South Africa’s open-ended pandemic response or Kenya’s partnership-dependent model, both of which lack a clearly engineered sunset or transition mechanism.

This design explicitly aims to avoid what the Committee calls perpetual access obligations while preserving incentives for continued network investment, a sustainability safeguard largely absent from the comparative cases examined.

The explicit multi-stakeholder funding architecture: Spanning USPF subsidisation, government funding, development partner financing, and a bring what you sell?participatory model across the communications and education value chain, this framework is more structurally ambitious than the single-partner funding models seen in Kenya’s UNICEF-Airtel arrangement or the donor-coalition model UNESCO has coordinated elsewhere in West Africa.

The monitoring framework: Proposed by Nigeria’s Committee, the framework tracks exam performance correlation, gender inclusivity, abuse indicators, and market distortion alongside basic usage metrics, making it considerably more comprehensive than the largely informal, post-hoc evaluation that characterised South Africa’s emergency rollout.

The Unresolved Risk

What no comparative case fully resolves, and what Nigeria’s Committee has correctly identified as requiring fresh stakeholder input rather than precedent-borrowing, is the eligibility scope question.

No African zero-rating programme examined has attempted to extend free educational access to all students and teachers across all levels, public and private, without some form of segmentation.

Most successful implementations have been narrowly targeted, partnership-funded, and platform-specific rather than broadly registered for free access.

If Nigeria’s Committee ultimately selects one of its more expansive eligibility or structural options without a correspondingly robust funding mechanism in place, it risks repeating the central failure of pandemic-era zero-rating elsewhere: ambitious policy design that outpaces sustainable execution.

The Verdict

We believe that Nigeria’s consultation paper reflects a level of structural caution that most comparative zero-rating programmes, designed in crisis, donor-dependent, or commercially motivated, did not have the luxury or the discipline to build in.

Whether that caution translates into a programme that actually reaches Nigeria’s most digitally excluded students will depend on choices the Joint Committee has not yet made, choices on which the public consultation closing July 9, 2026, is now formally seeking the country’s input.

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