Modernising Mobility: Assessing Nigeria’s 2025 Immigration Reforms And The Road Ahead

Introduction

Nigeria’s immigration landscape entered a transformative phase from April 2025 as the Federal Ministry of Interior (FMI), working in close collaboration with the Nigeria Immigration Service (NIS), introduced a series of reforms aimed at modernising mobility and strengthening national security.  These reforms marked a demonstration of the government’s commitment to digitising key immigration processes, improving expatriate administration, and aligning Nigeria with global migration management standards.

These initiatives, now known collectively as the Expatriate Administration System (EAS) are aimed at streamlining short and long‑term entry procedures, automating work and residence permit systems, promoting responsible migration, curbing abuse of the Expatriate Quota (EQ) policy, promoting knowledge transfer to Nigerians, ensuring better oversight of expatriate employment and ensuring that employers take financial responsibility for expatriate repatriation, where required.  These efforts mark a decisive step toward eliminating manual bottlenecks, increasing transparency, and providing a more predictable experience for travellers and employers of foreigners.

As with any large‑scale transformation, the rollout has achieved measurable progress but not without practical challenges.  Some systems have already improved efficiency and user experience, while other components require further refinement, coordination, and investment to deliver the full intended benefits.

This article evaluates how far the 2025 immigration reforms have advanced Nigeria’s mobility ecosystem and explores the opportunities that lie ahead for the FMI and NIS to strengthen implementation, boost stakeholder confidence and fully realise the vision of a modern, responsive, and globally competitive immigration system.

Key Features of the Nigeria Immigration Reforms 2025

Discontinuation of Visa on Arrival and Transition to e-Visa for Short Visits: The previous Visa-on-Arrival (VOA) application system was discontinued from 1 May 2025, and the e-Visa application system was rolled out immediately.  The e-Visa initiative covering thirteen (13) classes of short visit visas is available to business visitors, tourists and those visiting family members in Nigeria, eliminating the need for such travellers to obtain physical visa vignettes in their passports.  This has reduced overall processing timelines and improved administrative efficiency on an end-to-end basis, as approvals are expected to be issued via email within 48 hours of application submission.  It is important to note that electronic visas are not extendable.

Introduction of Expatriate Comprehensive Insurance Scheme: The FMI resolved to collaborate with private insurance companies to introduce insurance cover for expatriates. This development is geared towards shifting the significant financial burden of repatriating immigration offenders to employers of these foreigners which, according to the Minister, had been borne over the years by Nigerian taxpayers.  The premium for the annual policy cover depends on the duration of stay of expatriates and ranges from $400 to $1,000.  In the case of a three-month temporary work permit, the applicable insurance fee is $400 while for the long-term permit categories, the applicable insurance fee is $1,000.

Automation of Temporary Work Permit (TWP) and CERPAC processes:  The old TWP approval process relied heavily on the issuance of a pre-approval letter from the office of the Comptroller General of the NIS, before an applicant could approach a Nigerian mission abroad to obtain a TWP visa.  The TWP pre-approval application system was email based.  However, following the reforms, applicants who require TWP visas for short-term assignments up to three (3) months, can now submit their applications directly online, and obtain their electronic TWP visa/entry permit approvals at a fee of $200.

For resident expatriates or those taking up long term employment in Nigeria, the previous Combined Expatriate Residence Permit and Alien Card (CERPAC) scheme was transitioned into a digital process, with a renaming of the acronym to Electronic Comprehensive Expatriate Residence Permit and Automated Card (e-CERPAC).  Under the previous CERPAC regime, applicants or their employers needed to purchase a physical CERPAC form from the designated bank at $2,000. This form was to be filled and submitted to the immigration office alongside other application documents for further desk to desk processing before an endorsed temporary residence permit is issued and the residence permit card (Green Card), at a later time.

With the e-CERPAC initiative, residence permit applications are now exclusively submitted via a dedicated portal, subject to Expatriate Quota availability and confirmation by the Federal Ministry of Interior, where required. The applicant’s information and documents are uploaded, payment of the statutory CERPAC and insurance fees made, and upon completion of the vetting process, a link to book the mandatory biometrics appointment is released to the applicant. Once the biometrics is completed, the application is further processed for approval and barring any irregularities, the e-CERPAC approval is issued.

New Citizenship and Business Management Portal, Upward Review of Application Fees and Clarification of Expatriate Quota (EQ) Lifespan: As part of its efforts towards improving service delivery, the FMI announced its transition from the e-citibiz portal to a new Citizenship and Business Management platform – Home - Citizenship and Business Department, alongside the release of a schedule of increased fees associated with related applications, ranging from 35% to over 500% in May 2025.  These fees are required to be paid upfront with no guarantee of approvals.  The FMI has also pegged the lifespan of EQ slots to range from 4 to 10 years, depending on the EQ type, status and the organisation’s line of business. 

Digital Landing & Exit Cards: Foreigners intending to travel to Nigeria and those exiting the country are now required to complete digital landing and exit cards via a dedicated application portal. This initiative is intended to serve as an additional layer of national security by controlling entry, as well as enable the FMI and NIS to track the duration of stay of travellers, consequently identifying ‘overstayers’.  Previously, travellers were required to complete physical embarkation and disembarkation cards at Nigerian airports. The new system is synchronised with the visa processing centre to automatically apply penalties and visa bans, where applicable.

Stricter Penalties for Irregular Migrants: The penalties for visa overstay have been set at $15/day and travel bans lasting between five to ten years, and a potential life-time ban, depending on the duration of overstay from 1 September 2025. See details below:

• 3 months to 1 year: $15 per day and five-year entry ban
• 1 year and beyond: $15 per day and blacklisting (permanent entry ban)

The Promise and Ambition

The reforms were announced with a promise of transparency, process efficiency with a renewed focus on driving compliance, alignment with global best practices and improved national security.  The reform package, which includes e-Visas, automated gates and cards, online residence permits, and integrated data systems are deliberate efforts towards modernization and digitalisation, to meet global standards.

By eliminating manual application steps, the NIS and FMI aimed to reduce processing times, eliminate bottlenecks and create verifiable digital trails for every application.  For instance, the 48‑hour application decision target for e‑Visa requests illustrates this ambition.

The digitisation process is a welcome development that would ensure predictable timelines for corporate/global mobility, track identity management and overstayers, and drive enforcement of sanctions and critical measures to prevent process abuse.

Stakeholder Perspectives: Policy versus Practice

While the reforms promise a better working immigration system in Nigeria, stakeholders have raised concerns on areas requiring re-evaluation, such as:

• The Burden of Increased Costs on Employers amidst Uncertain Application Decisions: Prior to now, only visa and residence permit fees were required to be paid upfront, with EQ-related requests paid for after approval has been granted. However, the FMI announced increased service fees ranging from 35% to over 500% as part of the reforms with the EQ system being structured in a way that both statutory fees must be paid upfront, regardless of application outcome.  While this measure may help the FMI manage the quality of applications received, as requestors need to pay extra attention to the quality of information/documentation provided during the submission process, it also places stakeholders in a dilemma of cost management.  What this means is that when a request for an EQ slot is rejected, the fees paid by the requestor are lost without a refund process in place.  
  In addition, the lifespan of EQ slots with Permanent until Reviewed (PUR) status have been capped to 10 years from being previously open-ended until the FMI calls for a revalidation, despite the significant increase in statutory fees.  This limit deviates from the initial logic behind creating the PUR EQ category.  EQ slots with PUR status are typically obtained by organisations on the basis that certain top management roles, especially those protecting investors interests, are continuously required for business functionality. The FMI’s approach of treating the EQ system like a visa application system needs to be re-evaluated.
• Duplication of Processes and Resultant Burden of Compliance: While this may have been unintentional, the existing mandatory Migrant e-Registration, and the new e-CERPAC and e-TWP biometrics process may pose an unnecessary compliance burden on foreigners and their employers. The NIS needs to evaluate the continuous existence of the Migrant e-Registration process in light of the new reforms.
• Readiness and Training Gaps of Officials: The request for additional documentation / requirements by Missions abroad despite applications going through a vetting/confirmation process before the biometrics’ booking link is released to applicants, needs to be looked into. While Missions/Embassies are empowered to request more information to support any application, it is best practice for this process to have been concluded at the document vetting/review stage done by the NIS, to further enhance applicant experience during their appointments.
  Stakeholders have also experienced misevaluation of applications by reviewing officers due to semantics of job roles/titles versus academic qualifications without consideration for relevant on-the-job experience gained by applicants over the years.  In todays’ world, most people have pivoted from the field of study of their first degrees towards experience-driven specialisation, except in regulated fields such as medicine, engineering, etc.  

Opportunities for Refinement

While the progress recorded so far has been commendable, additional refinements such as improving system stability, enhancing coordination between agencies, defining timelines for all application categories, expanding training, and publishing comprehensive policy documentation would strengthen the implementation process.  

As stakeholders adjust to the reality of the new cost of obtaining immigration facilities in Nigeria, the promise of a new dawn in the immigration space in Nigeria will be fulfilled by:

• Better Coordination and Synergy between the FMI, NIS and Missions abroad: The fast-paced implementation of the provisions of the reforms appears to have outpaced alignment between the regulatory agencies and the Missions abroad. Applicants and employers of foreigners have experienced instances where missions requested additional documents outside the application documents that have been certified sufficient on the e-CERPAC/e-TWP portal by the NIS.  Based on the old system, where any Mission had specific application requirements outside the general ones, this information was typically published on their websites or the NIS’ third-party service providers’, making them easily accessible to applicants, even though now outdated.  
  However, since the implementation of the new system, there have been instances where Missions request additional documentation not publicly stated, even though applications have gone through the vetting/screening process at the NIS Headquarters.  It is also important to note that the biometrics booking confirmation email sent to applicants after the vetting process is completed reiterates that the applicants attend their appointments with copies of the same documents uploaded on the portal.  It then becomes a bottleneck and a taint on user experience when Missions request documents outside those that the NIS had deemed satisfactory.
  There have also been situations where applicants are required to pay “administrative fees” to the Missions at the time of attending their appointments.  While the Missions are permitted to set such fees to cover operating and administrative costs, the main challenge faced by applicants is the non-availability of this information before attending such appointments.  Most Mission websites have not been updated post-implementation of the reforms and applicants have to deal with the consequential unplanned additional cost burden, apart from the statutory visa/e-CERPAC and insurance fees that had been paid, upfront.
  On EQ related matters, the FMI typically insists that applications for the renewal of EQ slots with more than six (6) months validity will not be treated, as it is considered as too early.   Meanwhile, the e-CERPAC application portal does not accept residence permit applications for EQ slots with less than six (6) months validity.  This disparity could result in unnecessary exposures and delays for foreigners and their employers as the validity of EQ positions and residence permit do not always align. In most cases, residence permits of individuals may be set to expire way ahead of the six (6) months mark, while the EQ is still valid.
  Furthermore, the FMI should consider adopting a more structured framework that will facilitate effective knowledge transfer from expatriates to Nigerians.  The FMI may also collaborate with the Ministry of Labour to develop a comprehensive critical skills list that clearly delineates positions for which expatriate engagement is permissible, taking into consideration Nigeria’s unemployment statistics.
• Improving System Stability: While the application portals have since gone live, staged integrations, deployment and capacity constraints have resulted in intermittent downtimes, slow responses and uneven user experience. For instance, residence permit application categories such as Change of Employment and Change of Status are yet to be distinctly available on the e-CERPAC portal.  Travelers have also constantly experienced glitches with the e-visa and landing/exit card portals.  In some instances, travellers’ landing and exit QR codes are not scanned, thereby resulting in delays during their subsequent trips in and out of the country.  There have also been cases of e-visa applications not being received by the processing centre, even after travellers have submitted their applications and made the necessary payments.  By eliminating the challenge of limited infrastructure and minimising technical glitches, the process improvement goal of the FMI and NIS will be fully achieved.
• Defining Standard Application Timelines: While the NIS has been able to maintain a standard decision timeline of 48 - 72 hours for e-Visa applications, barring any technical glitches, there are no specific timelines for other visas, residence permit and the EQ application categories. This leaves stakeholders in limbo and without knowledge of the timeframes to work with, which in turn affects mobility planning and seamless progression of international assignments to Nigeria. Standard timelines are critical to ensuring transparency and foster stakeholder trust in the reforms.
• Training and Retraining of Personnel: Training and re-training of Immigration officials on new systems associated with the policy reforms is essential for achieving a faster, more transparent, and more reliable immigration process. When officers fully understand updated procedures, digital tools, and compliance requirements, they can process applications with greater accuracy and reduced delays.  Well‑trained staff are also better equipped to identify and resolve issues quickly, minimising bottlenecks and improving overall workflow.  Equipping officials with the right knowledge enhances consistency in decision‑making, reduces errors linked to outdated practices, promotes adaptation of global best practices and adherence to international standards in a manner that supports national security objectives while delivering a smoother experience for migrants and stakeholders.
• Codification of the 2025 Visa Policy: It is important that the entire body of laws/regulations and operational procedures that now guide immigration processes in Nigeria are wholistically reviewed and consolidated into one policy document to ensure that stakeholders have access to the right information to guide them in making mobility decisions. The NIS needs to also evaluate and decide on what becomes of the visa extension policy in view of the changes brought on by the reforms.

Conclusion

Nigeria’s 2025 immigration reforms represent a forward-looking effort to modernise the nation’s immigration system.  In addition to the noted areas for improvement in this article, the FMI and NIS should evaluate the implementation of the reforms so far with intentional, deep stakeholder engagement to provide end-user perspectives, for a better immigration system in Nigeria. These agencies should also drive monitoring and feedback mechanisms to collate user experience to further make these reforms efficient. With continued collaboration between government agencies and stakeholders, these reforms can significantly improve Nigeria’s global competitiveness and economic growth.

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.