The National Pension Commission (PenCom) and the National Insurance Commission (NAICOM) have jointly issued a strong directive requiring insurance companies and their vendors to fully comply with Nigeria’s pension and insurance regulations.
The move, outlined in a joint circular, was signed by Abdulrahaman Muhammad Saleem, Director of Surveillance at PenCom, and Talmiz Usman, Director of Legal, Enforcement and Market Development at NAICOM. It seeks to strengthen compliance with the Pension Reform Act (PRA) 2014 and the Nigerian Insurance Industry Reform Act (NIIRA) 2025.
Key Focus: CPS and Group Life Assurance Compliance
The circular emphasizes adherence to the Contributory Pension Scheme (CPS) and mandates that all employers maintain Group Life Assurance (GLA) coverage for employees.
Under Section 2 of PRA 2014, every employer in the public and private sectors must:
- Participate in the CPS
- Remit pension deductions within seven working days of salary payment
- Provide life insurance cover for employees
Despite ongoing engagements, audits, and sanctions, a significant number of employers—including some within the financial services sector—remain non-compliant. PenCom has deployed Recovery Agents to audit defaulting employers, impose sanctions, and pursue judicial recovery of unpaid contributions and penalties.
The persistence of non-compliance has prompted a joint enforcement strategy with NAICOM to safeguard the credibility and sustainability of the CPS.
New Compliance Requirements for Insurance Firms
Going forward, all Licensed Insurance Companies (LICs) must:
- Possess valid Pension Clearance Certificates (PCCs) from PenCom
- Hold Group Life Assurance Certificates compliant with NIIRA 2025
before engaging in any operational, investment, or business activity.
This requirement extends to:
- Vendors, service providers, and counterparties
- Investment transactions, including commercial papers, bonds, and bank placements
- Execution of a Compliance Attestation affirming that all vendors and service providers are also fully compliant
By cascading compliance requirements throughout the insurance ecosystem, PenCom and NAICOM aim to ensure legal adherence across the investment and operational value chain.
Integration into Corporate Governance
Insurance companies are now expected to:
- Embed compliance requirements into internal policies
- Include compliance checks in vendor selection and due diligence
- Incorporate PCC and GLA verification into investment risk assessments
Parent companies, subsidiaries, holding firms, and institutional shareholders must also demonstrate full compliance before any business dealings are approved.
Implementation Timeline
Recognizing the operational adjustments needed, PenCom and NAICOM have allowed a six-month transition period from the date of the circular. During this time, insurance companies are expected to:
- Align internal processes with the new requirements
- Communicate compliance expectations to all vendors
- Update governance frameworks to reflect the new mandates
This directive marks a major step toward ensuring accountability, transparency, and sustainability in Nigeria’s pension and insurance sectors.