Christian Denton
City Law Associates, Lagos
Denton@citylaw.ng

Immigration rules around the globe have recently become more restrictive and my jurisdiction, Nigeria, is no exception. Following major overhauls by the Federal Government of Nigeria, the country has shifted to stricter border control, heavier financial penalties for visa overstayers and increased enforcement on unauthorised foreign workers.^[1]

The shift has been marked by the following key measures:

• stricter overstay penalties;
• the end of ‘visa on arrival’;
• mandatory travel documentation;
• expatriate quota reforms;
• stricter enforcement of immigration policies;
• mandatory expatriate insurance; and
• higher fees for immigration and citizenship services.

This article will outline each of the changes and what they mean for foreign nationals and employers.

Overstaying penalties

Foreign nationals traveling to Nigeria for business, tourism or other purposes should note that overstaying your visa in Nigeria has consequences. On 31 March 2025, the Nigerian Minister of Interior, Olubunmi Tunjii-Ojo disclosed that more than 840,000 foreign nationals were overstaying their visa in Nigeria.^[2]

As of 1 August 2025, a daily $15 fine and a five-year entry ban would be issued if a foreign national, who is not a member of the Economic Organization of West African States, overstays by six months. A permanent ban will be issued if a foreign national overstays by one year or more.^[3]

There was a five-month amnesty period that was granted to visa-overstayers by the Nigerian government which lasted from 1 May to 30 September 2025.^[4] These people were encouraged to regularise their stay during the period to avoid penalties.

Once the amnesty had expired, enforcement actions to remove all foreign nationals who overstayed their visas became effective from 1 October 2025. The enforcement exercise targeted holders of expired 'visas on arrival', expired single and multiple-entry short visit or business visas, and individuals with expired Comprehensive Expatriate Resident Permits and Automated Cards (CERPAC).^[5]

End of ‘visa on arrival’ policy

The government’s visa on arrival policy was discontinued and replaced by the e-Visa programme. The e-Visa application system has introduced 13 short-visit visa types for eligible foreign travelers to legally enter and remain in Nigeria for the duration of their visas.^[6] The types of short-visit visas that could be obtained by foreign travellers to Nigeria include: Visitor visa, Business visa-single entry, Business visa-multiple entry, Transit visa, Tourism visa, Sports visa, Creative arts visa, Study tour visa and International cultural visa.^[7]

This policy aims to streamline the application timeline for foreigners, strengthen Nigeria’s borders and ensure that visas are not overstayed. The introduction of penalties is to ensure that visas are not abused, with any violation attracting severe repercussions such as a temporary or permanent visa ban.^[8]

Mandatory travel documentation

The Nigerian Immigration Service, Nigeria’s primary agency responsible for border security and issuance of travel documents, has made it compulsory for all foreign travelers to Nigeria to have to complete a mandatory landing and exit card before entering or leaving Nigeria.^[9]

This form of documentation has replaced the traditional manual paper forms of documentation and applies to all foreign nationals. It is a digital card that is intended to monitor the duration of stay for all travellers, identify overstays and automatically trigger applicable penalties, including visa bans.^[10] Foreign travelers must also produce a certificate in order to prove that they are vaccinated against yellow fever.^[11] It is also compulsory to fill in an online Nigeria Health Declaration Form when entering Nigeria.

Expatriate quota reforms

The Nigerian government is currently enforcing stricter expatriate controls regarding expatriate quota approvals and the hiring of foreign nationals by employers based in Nigeria. The Ministry of Interior (MoI) has overhauled its administration system (the Expatriate Administrative System or EAS) to combat abuse and protect local employment.

According to Nigeria’s Minister of Interior, Olubunmi Tunji-Ojo, there was widespread abuse of the country’s expatriate quota and residence permit system which led to the reforms by the government through the MoI to improve the process of bringing in expatriates into the country.^[12]

Investigations carried out by the MoI during the expatriate quota reform process uncovered extensive irregularities in the administration of expatriate quotas and residence permits, including the circulation of fraudulent documents by unauthorised agents and intermediaries.^[13] Currently, Nigeria is estimated to have only 50,000 expatriates on its official record on corrupt practices.^[14]

The Minister further stated that the MoI and the Nigerian Immigration Service have now deployed an integrated digital platform that directly links expatriate quota approvals with residence permit processing, eliminating duplication and enabling real-time verification.^[15]

Under the new arrangement quota approvals granted by the MoI are automatically accessible to immigration authorities, ensuring that residence permits can only be issued against valid and verifiable quotas.

The expatriate reforms were designed to return control of immigration processes to employers by allowing companies to manage applications directly through an online platform without relying on third-party agents.^[16]

Stricter enforcement on undocumented foreign nationals

The government is actively cracking down on undocumented foreign nationals. Once the amnesty programme was terminated on 1 October 2025, Nigeria’s border authorities increased surveillance and operations at major points of entry to intercept and penalise violators.^[17]

The government enforced the crackdown via the following methods: daily fines, deportation, entry bans and business repercussions.^[18]

Mandatory expatriate insurance

The MoI implemented a new Expatriate Comprehensive Insurance that employers in Nigeria must pay when hiring an expatriate in Nigeria under the Expatriate Quota, CERPAC or Temporary Work Permits (TWP) category.^[19] The new insurance is part of the MoI’s new immigration reforms for employers to cover costs associated with hiring foreign nationals employees.^[20] The expatriate insurance policy is designed to fund medical emergencies, security incidents, personal liabilities and deportation or repatriation costs.

Higher fees for immigration and citizenship services

In May 2025, the MoI published a revised schedule of fees for most visa categories for foreign nationals who intend to come to Nigeria for work, tourism, business and other purposes.^[21]

The cost of business permits has risen to a maximum NGN 1.5m; expatriate quota establishment and renewals now costs between NGN 250,000 and NGN 1m; and upgrades to Permanent Until Reviewed quota has risen to NGN20m.^[22] Foreign nationals who want to acquire Nigerian citizenship by naturalisation or registration will have to pay NGN 15m.^[23]

Foreign nationals who intend to work temporarily in Nigeria via the TWP will have to pay $600 for a three-month work permit and $1,100 for a six-month work permit.^[24] Companies will now have to pay $500 for mandatory expatriate insurance for their expatriate staff, lasting for the duration of 90-180 days, and $1,000 for the duration of one year.^[25]

Conclusion

Thus, it could be argued that Nigeria, like other jurisdictions, is moving towards more restrictive immigration rules by prioritising stronger border controls, enforcing stiff penalties on visa overstayers, increasing the cost of fees for business permits, expatriate quotas and citizenship for foreign nationals and overhauling the visa system thereby making it compulsory that foreign nationals apply for electronic visas in order to travel to the country.