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      GMS Flash Alert 2025-058

      Nigeria – Reviewing Approving Authority for Expatriate Quota and Citizenship Applications

      GMS Flash Alert 2025-058 | 12 March 2025

      Nigeria’s Federal Ministry of Interior (FMI) has announced a review of the approving authority for Expatriate Quota (EQ) and Citizenship applications.  The announcement is contained in a circular dated 12 February 2025 and signed by the Permanent Secretary, Ministry of Interior, Dr. Magdalene Ajani.1  

      According to the Circular, the review is in line with the FMI’s commitment to enhance transparency, accountability, and operational efficiency in the administration of EQ and Citizenship applications. In addition, the revised approval framework is expected to address concerns related to potential abuse and irregularities within the system.

      The framework outlines the approving authority for EQ- and Citizenship-related applications submitted to the Ministry.  Based on the new framework, exclusive approval rights have been granted to the Honourable Minister and the Permanent Secretary within specified thresholds, while approval rights have been removed from the Director cadre.

      WHY THIS MATTERS

      There are concerns that the implementation of the new framework may prolong the processing timelines for applications submitted to the FMI by businesses, investors, and expatriates to facilitate employment and residence in Nigeria. 

      Therefore, businesses that utilise EQ approvals for their operations may face some challenges due to potential delays in the issuance of approvals.

      KPMG INSIGHTS

      Previously, the ‘Director Level’ played a key role in granting approvals for renewal or addition of EQ positions within a particular threshold, which facilitated the efficient processing of applications.  The removal of the approval rights from the ‘Director Level’ may delay the processing of EQ applications, as all applications will now require higher-level review prior to approval.

      While this change may strengthen oversight, it places additional responsibility on the Minister and the Permanent Secretary, and the increased volume of applications requiring their approval may put a strain on resources and extend lead times.

      To mitigate the impact of the issues, organisations with expatriates in their employment may wish to proactively review their EQ portfolios and submit EQ-related requests well in advance. 

      Additionally, they may wish to consider alternative approaches with respect to staffing strategies, such as hiring local talent or temporary expatriate assignments to manage operational needs as efficiently as possible during the transition period.  Organisations with questions or concerns about how the provisions of the Circular could impact them, should consult with their usual immigration counsel or a member of the People Services team with KPMG in Nigeria (see the Contacts section).

      FOOTNOTE:

      1  To access, click here.

      Contacts

      adenike-yomi-faseun
      Adenike Yomi-Faseun

      Partner & Head, Managed Services Group

      KPMG in Nigeria

      Disclaimer

      * Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

      The information contained in this newsletter was submitted by the KPMG International member firm in Nigeria.

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