The National Insurance Commission (NAICOM) has directed all insurance and reinsurance companies in Nigeria to submit their recapitalization plans by September 30, 2025.
The directive is part of the rollout of the Nigerian Insurance Industry Reform Act (NIIRA) 2025, which introduces new Minimum Capital Requirements (MCR) and ushers in a risk-based capital framework for the sector.
According to Section 12 of NAICOM’s draft guidelines, firms must present a detailed plan outlining how they intend to meet the new requirements. The submission must include a board resolution, the company’s capital position based on its 2024 audited financial statements and Q2 2025 returns, and a clear strategy for raising fresh capital—including amounts, sources, timelines, and deliverables.
Companies seeking to raise funds from capital markets will be allowed to file and use their plans, while those pursuing mergers or acquisitions must submit detailed proposals in line with existing laws. Composite insurers intending to exit a line of business are required to present either a portfolio transfer or a run-off plan.
Beyond the initial submission, all insurers and reinsurers will be required to file monthly Recapitalization Progress Reports, no later than five working days after month-end. These reports must show the company’s capital status using NAICOM’s template and outline progress toward meeting the recapitalization targets. Even after achieving compliance, firms will continue reporting until their new licenses are issued or the regulator directs otherwise.
The NIIRA 2025 raises the bar significantly, with new capital thresholds of ₦10 billion for life insurers, ₦15 billion for non-life insurers, ₦25 billion for composite insurers, and ₦35 billion for reinsurers. Full compliance with these requirements is expected by July 30, 2026.
