batch-1794409657 1794409657 Global Insights Law Journal publisher@gilawjournal.com Global Insights Law Journal Global Insights Law Journal 3141-5717 2026 1 3 Tony Francis Beauty Obuh This article examines the legal and institutional challenges confronting foreign direct investment in Nigeria and draws comparative lessons from China and the United States. Despite an extensive body of investment legislation and institutional machinery, Nigeria's FDI performance remains volatile and heavily concentrated in extractive sectors, while established multinational investors continue to exit the market. The article identifies six structural problems, namely: regulatory volatility and institutional overlap; frequent legislative amendment and policy reversal, particularly in foreign exchange administration; the complications of federalism and uneven state capacity; systemic corruption and weak accountability institutions; gaps in intellectual property enforcement; and the constraints imposed on land-based transactions by the Land Use Act 1978. Drawing on China's negative-list liberalisation, and the United States of America's Committee on Foreign Investment regime, the article argues that predictability and consistent enforcement matter as much as the substantive content of investment law. It concludes that Nigeria's investment framework suffers less from a deficiency of legislation than from fragmentation, weak institutional coordination, and enforcement gaps, and recommends consolidation of the legal framework, a rebalancing of investor protection against the State's regulatory space, strengthened institutional coordination, and targeted sectoral reform, particularly of land administration and foreign exchange regulation. 2026 11 10 10.67588/0015 https://gilawjournal.com/article/foreign-direct-investment-in-nigeria-challenges-comparative-lessons-and-the-path-to-reform Nigeria Foreign Direct Investment Investment Law Land Use Act Regulatory Framework CFIUS China Foreign Investment Law