Adopting the FAIR Guidelines—that data should be Findable, Accessible, Interoperable and Reusable (FAIR)—in the health data system in Nigeria will help protect data against use by unauthorised parties, while also making data more accessible to legitimate users. However, little is known about the FAIR Guidelines and their compatibility with data and health laws and policies in Nigeria. This study assesses the governance framework for digital and health/eHealth policies in Nigeria and explores the possibility of a policy window opening for the FAIR Guidelines to be adopted and implemented in Nigeria's eHealth sector. Ten Nigerian policy documents were examined for mention of the FAIR Guidelines (or FAIR Equivalent terminology) and the 15 sub-criteria or facets. The analysis found that although the FAIR Guidelines are not explicitly mentioned, 70% of the documents contain FAIR Equivalent terminology. The Nigeria Data Protection Regulation contained the most FAIR Equivalent principles (73%) and some of the remaining nine documents also contained some FAIR Equivalent principles (between 0–60%). Accordingly, it can be concluded that a policy window is open for the FAIR Guidelines to be adopted and implemented in Nigeria's eHealth sector.