- with readers working within the Media & Information industries
- within Insurance, Compliance and Employment and HR topic(s)
INTRODUCTION
On November 11, 2025, the Nigerian Upstream Petroleum Regulatory Commission ("NUPRC" or the "Commission") announced that Nigeria's Oil Licensing Round will commence on December 1, 2025. The announcement was made by the Commission's Chief Executive, Engineer Gbenga Komolafe at the MMBOPD Additional Production Investment Forum in London.1 This licensing round focuses on discovered but undeveloped fields, fallow assets, and natural gas development. Its primary objective is to fast-track upstream production from unexploited reserves, while simultaneously stimulating the midstream capacity required for evacuation, storage, and early production handling, in support of the government's target of adding an additional One Million Barrels of Oil Per Day (1MMBOPD) to national production capacity.2
In this newsletter, we highlight the policy and regulatory framework governing the licensing rounds, the eligibility requirements for participation, and key timelines in the bidding process.
POLICY AND REGULATORY FRAMEWORK
This exercise is governed by the Petroleum Industry Act ("PIA") 2021 and the Petroleum Licensing Round Regulations 2022 (the "Regulation"). The PIA sets out the core legal framework for the award of Petroleum Prospecting Licences ("PPLs") and Petroleum Mining Leases ("PMLs"), mandating that all licensing rounds be conducted through a 3 transparent and competitive bidding process.3 To operationalize the PIA, the Regulation prescribes in detail, procedures for conducting licensing rounds and expressly requires PPLs and PMLs be awarded only through a fair, transparent, and competitive bidding process in line with the PIA 4 and applicable guidelines issued for each round.4
In line with the Regulation, each licensing round must begin with a formal public announcement to guarantee openness and equal access to information.5 Pursuant to this requirement, the Commission has issued a press statement and published the commencement date as December 1, 2025, as stated above. Following this, and in subsequent weeks the Commission is expected to publish additional information regarding the bid timelines and schedules on its official website. Along s ide the s e announc ement s , the Commission must release the Licensing Round Guidelines, which will serve as the primary compliance document for interested bidders.6 Thereafter, the Commission is required to open the data room, an online repository containing geological, geophysical, and fiscal data relating to available blocks to enable participants conduct informed commercial and technical evaluations. Access to the data room is contingent upon the execution of a confidentiality agreement, reinforcing the integrity of proprietary data shared during the process.7
PRE-QUALIFICATION REQUIREMENTS TO PARTICIPATE
Participation in the licensing round is strictly limited to companies that have first undergone and successfully completed the pre-qualification process.8 Participants are required to satisfy the legal, financial, and technical criteria prescribed under the Regulation. Where the applicant is a consortium, all members must meet the legal and financial thresholds, while at least one member designated as the operator must satisfy all technical requirements.9 These requirements include providing incorporation documents in line with Nigerian law, audited financial statements covering the preceding three (3) years, evidence of financial good standing from a reputable bank, and technical records such as evidence of operating an oil and gas field for a minimum of three (3) years, and prior successful exploration or development projects among others.10
The Commission reserves the discretion to reject applications that contain unverifiable or incomplete information or where an applicant attempts to influence the evaluation process.11 Only applicants who successfully complete the pre-qualification process will be published by the Commission in the Pre-Qualified Bidders List. These pre-qualified bidders are then eligible to submit bids and are mandated to pay the prescribed bid administration fee,12 confirming their commitment and enabling formal evaluation.
BID SUBMISSION PROCESS AND PROCEDURE
Following pre-qualification, the Regulation outlines a transparent, multi-stage bid submission and evaluation procedure.
- Submission Timeline and Method:
The Commission determines the date, time, and place for the bid process, and this information is published on its website at least thirty (30) days prior to the submission deadline. Bidders are required to submit their bids both physically (delivered either by a duly authorized representative of the bidder or via registered courier) and electronically.13 The bid is required to be submitted in a sealed envelope, representing the bidder's offer for a license or lease as per the guidelines, alongside a guarantee (as to be stipulated in the yet to be released NUPRC guidelines) guaranteeing the bid. - Bids Opening and Evaluation
All bids are opened publicly in the presence of bidders and observers of relevant government ministries and bodies.14 The Commission verifies the validity of bid guarantees, and conducts an evaluation of the bid in three (3) stages:15- Stage 1: The envelopes containing the bid guarantees are opened, and the guarantees are examined for validity in accordance with the regulations and the Licensing Round Guidelines. Any bid that lacks a bid guarantee or contains an invalid guarantee is disqualified from further consideration.
- Stage 2: The envelopes containing the bid proposals are opened. The offers contained in each proposal are formally recorded and publicly announced, providing transparency and ensuring that all participants and observers are informed of the submitted bids.
- Stage 3: This stage determines the outcome of the bidding process. The bid with the highest value is announced as the winning bid, while the next highest bid is designated as the reserve bidder. All other bids are declared unsuccessful. Once the winning bid and reserve bidder have been established, the observers, including representatives from relevant government ministries and the Nigerian Extractives Industries Transparency Initiative issue a joint written statement authenticating the results of the bid opening.
- Bid Award
The Commission publishes the winning and reserve bidders on its website within the timeframe established in the licensing round guidelines and issues an offer letter to the winning bidder within seven (7) days.16 Where bids are tied, the Regulation mandates a follow-up round focused on increasing the signature bonus to determine a clear winner.17 The winning bidder must then, within ninety (90) days, satisfy all financial obligations including payment of the signature bonus, applicable fees, firstyear rent, and submission of the required guarantees and executed contracts before the Commission may recommend the grant of a PPL or PML to the Minister.18 Where the winning bidder is unable to meet these conditions, his bid shall be declared unsuccessful, and the Commission shall invite the reserve bidder to fulfill the obligations.
WHAT TO EXPECT?
In the coming weeks, the NUPRC is expected to release the full Licensing Round Guidelines and detailed schedules ahead of the commencement of the 2025 Licensing Round on December 1, 2026. These guidelines will outline the specific blocks on offer, the applicable pre-qualification criteria, the required documentation, fee structure, and the timelines governing data-room access, bid submission, and bid opening.
Prospective bidders are encouraged to closely monitor the Commission's official website and public notices, as these publications will form the primary compliance framework for participation in the round.
We look forward to providing an update once the guidelines are released.
Footnotes
1. President Tinubu approves Commencement of Licensing Round effective December 1, 2025. https://www.nuprc.gov.ng/president-tinubu-approves-commencement-of-licensing-round-effective-december-1-2025/ [accessed 24th November 2025]
2. FG unveils plan to boost oil production by 1m barrels per day in 24 months. https://businessday.ng/news/article/fg-unveils-plan-to-boost-oil-production-by-1m-barrels-per-day-in-24-months/?utm_source [accessed 24th November 2025]
3. Section 73 (1) Petroleum Industry Act, 2021
4. Paragraph 1 Petroleum Licensing Round Regulations 2022 Nigeria-Licensing-Round-Regulations-hamonized.pdf [accessed 24th November 2025] [4]
5. Paragraph 4
6. Paragraph 5
7. Paragraph 9(f) and 12
8. Paragraph 8(3)
9. Paragraph 8(1)
10. Paragraph 8(4)-(7)
11. Paragraph 8(8)
12. Up Additional information will be shared following NUPRC's publication of the official Licensing Round Guidelines.
13. Paragraph 10(1)(ii)
14. Paragraph 10(5). Including Federal Ministry of Finance, Federal Ministry of Petroleum Resources, and any interested member of the public.
15. Paragraph 10(6)©
16. Paragraph 20(4)
17. Paragraph 21(1)
To view original Tope Adebayo article, please click here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
