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INTRODUCTION
On August 6, 2025, President Bola Ahmed Tinubu in a landmark effort to transform the Nigerian Insurance Sector signed the Nigerian Insurance Industry Reform Act (NIIRA), 2025. The NIIRA represents a comprehensive legal framework for the regulation and supervision of all insurance businesses in Nigeria, repealing and consolidating several previous insurance acts, including the Insurance Act, Marine Insurance Act, and Motor Vehicles (Third-Party Insurance) Act, among others. This new Act aims to develop the insurance sector, protect policyholders and other stakeholders, and foster a viable, competitive, and innovative industry. It achieves these objectives by setting suitability requirements for operators and their management, promoting prudent management and good corporate governance, and establishing effective mechanisms for dispute settlement. The Act generally applies to all insurance businesses and operators in Nigeria, with specific exemptions for friendly societies and certain foreign reinsurance transactions.
In this review, we aim to highlight some of the key provisions and core direct implications for businesses and relevant actors in the insurance industry below.
Key Provisions of the Act
Enhanced Regulatory Mandate of The National Insurance Commission (NAICOM)
Under the NIIRA 2025, the National Insurance Commission (referred to as 'NAICOM/the Commission') has been granted an expanded authority to oversee insurance regulation, encompassing areas such as licensing, capital requirements, product approvals, dispute resolution, and consumer protection, among others. The legislation enables NAICOM to supervise the insurance industry more effectively, positioning it as the primary enforcer of a cohesive insurance law and promoting the advancement of risk-based protection (RBP) in line with international best practices.
Enhanced Reporting and Filing Obligations
NIIRA establishes stricter reporting obligations for stakeholders within the insurance industry. Insurers must submit their audited financial statements, investment statements, and revenue accounts to NAICOM, on or before 30th June on an annual basis. Until NAICOM's approval, insurers may not hold annual general meetings or declare dividends. They must also file quarterly returns within 10 days of each quarter's end and, if operating both life and non-life business, submit an annual actuarial valuation and any other documents required by NAICOM. Brokers must also file audited statements and revenue accounts by 30 June or a later date set by the Commission, failing which they are exposed to the risk of having their license suspended. Similarly, loss adjusters are required to keep accurate records in a Commission-approved format, subject to inspection.
Strengthened Actuarial Oversight and Duties
In contrast to the limited provisions of the Insurance Act 2003, the NIIRA introduces more comprehensive regulations governing the role and responsibilities of actuaries. It strengthens their independence by empowering them to investigate the operations of insurers and reinsurers without undue influence. Under the new framework, actuaries may examine documents, request any information necessary to discharge their duties, and report directly to NAICOM if access is denied; an act that could attract penalties for the insurer and its officials. NIIRA also mandates an annual investigation by an actuary to assess the financial condition of each insurer, as well as an annual actuarial valuation conducted by the insurer's statutory actuary, who must prepare a report based on the findings.
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