ARTICLE
8 October 2026

From Award To Accountability: Drill-or-Drop And Nigerian Acreage

UU
Udo Udoma & Belo-Osagie

Contributor

Founded in 1983, Udo Udoma & Belo-Osagie is a multi-specialisation full service corporate and commercial law firm with offices in Nigeria’s key commercial centres. The firm’s corporate practice is supported by a company secretarial department, Alsec Nominees Limited, which provides a full range of company secretarial services and our sub-firm, U-Law which caters exclusively to entrepreneurs, MSMEs, startups, and growth businesses across several industries, including the FinTech industry. It is designed as a one-stop-shop for all basic business-related legal needs, providing high-quality support in a simplified and straightforward manner at super competitive prices. We are privileged to work with diverse local and international clients to create and implement innovative practical solutions that facilitate business in Nigeria and beyond. When required, we are well-placed to work across Africa with a select network of leading African and international law firms with whom we enjoy established relationships.
Nigeria's upstream regulator has issued a critical enforcement circular targeting holders of Petroleum Prospecting Licences awarded in three recent licensing rounds. The circular activates drill-or-drop provisions under the Petroleum Industry Act 2021, creating immediate compliance obligations and potential forfeiture consequences for licensees who have not met their minimum work programme commitments.
Nigeria Energy and Natural Resources

WHY THE NUPRC’ S DRILL-OR-DROP CIRCULAR MATTERS FOR LICENCE RETENTION, REGULATORY ENGAGEMENT AND TRANSACTIONS INVOLVI NG AFFECTED ACREAGE

The Circular

On 14 September 2026, the NUPRC issued an enforcement Circular that every PPL holder must read carefully.

CIRCULAR REFERENCE NUPRC/1127/Vol. 13/55, dated 14 September 2026
FULL TITLE "Notice of Enforcement of the Drill-or-Drop Provisions of the Petroleum Industry Act 2021"
ADDRESSED TO All holders of PPLs awarded under the 2020 Marginal Field Bid Round, the 2022/2023 Mini Bid Round, and the 2024 Licensing Round
APPL COMPRISES The licence · General Licence Conditions · Concession Contract · Minimum Work Programme · Work Performance Security

Statutory Basis: Sections 77, 78, and 88 of the PIA 2021; default and revocation provisions of sections 96 and 97

KEY DETAILS

REFERENCE NUMBER

NUPRC/1127/Vol. 13/55 

DATE ISSUED

14 September 2026

INSTRUMENT

Circular (general advisory)

THREE LICENSING ROUNDS AFFECTED
2020 2022/2023 2024

THE LEGAL EFFECT

Advisory, Not Default: The Legal Effect of the Circular

The Circular is a general advisory - not a notice of default - but enforcement consequences are live and real.

"The Commission's objective is 'to increase production, not forfeiture.'"

NUPRC CIRCULAR - PARAGRAPH 7

PARAGRAPH 6 - EXPRESS DISCLAIMER

Paragraph 6 expressly states: the Circular is a general advisory without prejudice and does not constitute a notice of default under the PIA.

ENFORCEMENT CONSEQUENCES ON NOTICE (PARAGRAPH 5)

01 Refusing extension of a PPL 02 Requiring relinquishment of acreage
03 Calling in the Work Performance Security 04 Commencing revocation proceedings

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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.

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