Introduction
The Minister of Interior, Dr. Olubunmi Tunji-Ojo, at a stakeholders' sensitisation forum organised by the Nigeria Employers' Consultative Association (NECA) on 11 April 2025, announced the launch of major reforms in expatriate administration and visa policy in Nigeria.
According to the Minister, the expatriate administration reforms, also referred to as "Expatriate Administration System" (EAS), are mainly, focused on addressing the incidence of abuse of the Expatriate Quota (EQ) policy in Nigeria, enforcing knowledge transfer to Nigerians and shifting the burden of repatriation costs from taxpayers to expatriates.
In addition, a revised visa policy tagged Nigeria Visa Policy (NVP) 2025 will be implemented from 1 May 2025. The Minister stated that the revised visa policy would be targeted at further automation of visa application and approval processes, to facilitate seamless issuance of visas to foreigners seeking to travel to Nigeria for business and other purposes.
Key Highlights of the Reforms
Stricter Enforcement of Guidelines on Business Permit (BP) and Expatriate Quota (EQ) Issuance
The Federal Ministry of Interior (FMI) would be stricter with reviewing BP and EQ applications and checks would be conducted to ascertain the credibility of requests from companies. This is in line with the Ministry's view that the essence of EQ is to accommodate employment of foreigners into roles where there are no qualified Nigerians with the required skills.
The expatriate understudy policy will also be strictly monitored and enforced. For every occupied EQ position, the Ministry requires that at least two (2) Nigerians with minimum qualification of Bachelor's degree or Higher National Diploma are assigned to understudy the expatriate employee, for the purpose of knowledge transfer. This is expected to position the Nigerian(s) to take over the role upon the expiration of the lifespan of the EQ slot (usually between 4 and 7 years, depending on the organisation's industry. Based on this, requests for EQ approvals from the Ministry must be reasonable and justifiable.
Review of Fees
The Ministry will implement an upward review of the fees for BP and EQ approvals as the Minister is of the view that the current fees are not sustainable to enable the Ministry to properly carry out site visits and checks, as part of the BP and EQ application process. The new fees will be communicated in due course. Enforcement of Penalties for Irregular Migrants
With effect from 1 August 2025, appropriate penalties will be imposed on irregular migrants. The Ministry has therefore given all individuals in this category until 1 August 2025 to regularise their documentation or risk being sanctioned in line with the extant immigration rules and regulations.
Automation of Residence Permit Application Process
The residence permit application process would be automated to enable applicants obtain their Combined Expatriate Residence Permit and Aliens Card (CERPAC) form online. After obtaining the forms, applicants can submit their applications via the designated portal of the Nigeria Immigration Service (NIS) and upon initial verification, an electronic copy of the CERPAC form will be issued to them. Following the completion of the whole process, a physical card would be dispatched to the registered business address of the expatriate's host/ employer.
This new system is expected to replace the current residence permit application process which involves several manual interventions from the initial purchase of the CERPAC form from the designated bank to physical submission of documents for processing at the relevant immigration offices.
Introduction of Expatriate Personal Liability Insurance
Given the significant financial burden for repatriating expatriates which, according to the Minister, has been borne by Nigerian taxpayers, the Ministry has resolved to collaborate with the private sector to introduce repatriation insurance cover for expatriates. This will ensure that Nigerian taxpayers are not made to bear the repatriation costs of immigration defaulters. The annual policy cover premium will depend on the duration of stay of individuals and will range from $500 to $1,000.
Discontinuation of Visa on Arrival and Introduction of Electronic Visa (e-Visa)
The current Visa-on-Arrival (VOA) application system will be discontinued from 1 May 2025 while the e-Visa application system will commence. Travelers who hold VOA pre-approval letters that were issued before 1 May 2025 will still be allowed to travel to Nigeria within the 2- week validity period indicated on such approval letters. For example, an approval letter issued on 30 April 2025 can still be used till 13 May 2025. Any approval issued after 30 April 2025 will be considered fake and will not be honored.
The e-visa solution will allow travelers submit group and family applications. Applicants, who require Temporary Work Permit (TWP) visas for three (3) months and six (6) months, can also submit their applications online and obtain their visa approvals at a pro-rated fee. The visa fee for a three-month TWP visa is set at $600, while that of a six month TWP visa is $1,100.
The introduction of the e-visa solution is aimed at reducing processing timelines and improving administrative efficiency. With the e-visa platform, travelers can apply online and receive visa approvals via email within 48 hours, thereby eliminating the requirement for a physical visa sticker. This system should enable the NIS to streamline visa applications and automate the inflow of travelers into Nigeria. However, the electronic visas are not extendable.
Approval of Visa Applications
Approval of visa applications will now be made at the visa processing centre situated at the NIS' headquarters in Abuja. This removes sole approving powers from the immigration attachés in Nigerian missions abroad and seeks to promote foreign direct investment and tourism by providing a simplified, seamless, and secure online visa process.
Regular visa services for issuance of Subject to Regularisation (STR) visas, business visas, among others will remain available at the Nigerian Missions abroad. However, applications will first be reviewed at the NIS headquarters, before the outcome is communicated to applicants by the Nigerian Missions. The estimated timeline for regular visa services is ten (10) working days.
Introduction of Online Landing and Exit Cards
Individuals intending to travel to Nigeria and those exiting the country will now be required to complete online application for 'landing and exit cards'. This feature is intended to enable the NIS to monitor the duration of stay of travelers and track 'overstayers'.
Penalties for Overstay
The penalties for visa overstay will range from $15/day to travel bans of five years, ten years, and a potential life-time ban, depending on the duration of overstay.
Commentary
The Ministry's move towards stricter enforcement of EQ guidelines is commendable, given the need to protect the nation's interest and address the alleged abuse of the system. However, the Ministry needs to consider attrition rates and emigration concerns within organisations in its enforcement of the understudy policy. Several organisations in Nigeria are daily faced with the japa-syndrome or employees' quest for new opportunities within the country that may serve as a clog in the wheel of knowledge transfer and Nigerianisation of certain roles, as intended by the Ministry. Therefore, the Ministry should consider a review system that will evaluate an organisation's investment in local manpower while utilising expatriate employees to address specific gaps, in enforcing compliance.
The digitalization of the residence permit application process is a welcome development which should address delays in the process of obtaining residence permits in Nigeria. However, there are still questions around the readiness of the NIS to commence implementation given the infrastructure deficit that exists in many immigration offices across the nation. Hopefully, the Ministry will continue to invest in the required infrastructure and manpower upskilling that will aid the digitization efforts of the government.
Furthermore, more information needs to be provided on the repatriation insurance cover for expatriates as there is still no clarity on how this will be implemented. The Ministry also needs to clarify how the current e-PASS visa extension policy will work in view of its position that visas obtained electronically are not extendable.
While the commencement date of the reforms is set as 1 May 2025, the Minister confirmed that imposition of penalties would only commence on 1 August 2025, giving a grace period of three (3) months to all stakeholders concerned, to adjust where they might have irregularities. To ensure a seamless transition and enable stakeholders take full advantage of the grace period, the Ministry needs to document the EAS and make this available along with the revised Nigeria Visa Policy document. This will grant stakeholders, and other users access to detailed information and clarity on operational guidelines of the reforms.
The Ministry also needs to work with the organised private sector to hold periodic interactive post-implementation sessions, to enable stakeholders present concerns and challenges that may arise and work with the government to resolve them.
Stakeholders are advised to stay informed of these developments and seek expert guidance to ensure compliance and effectively navigate the new reforms. KPMG is well positioned to provide the necessary guidance and support.
The opinion expressed in this article is solely personal and does not represent the views of any organization or association to which the authors belong.
