The scope of the Financial Reporting Council of Nigeria (FRCN) powers and functions pursuant to sections 7 and 8 FRCN Act - and the applicability of its section 77 compliance requirements for “public interest entities” to file returns with the FRCN to privately held companies - was recently put to the test in Eko Hotels Limited v. FRCN. There, the Federal High Court (FHC, Abang J.) ruled that the FRCN can only regulate public interest entities and that its powers does not extend to private companies. He further stated that “Where a statute does not empower a statutory body to do certain things, such body cannot so act.”