Legal Insights on Nigeria’s New Expatriate Administration System and Visa Policy 2025

Introduction
In 2025, Nigeria introduced reforms to its immigration, visa, and expatriate permit regime through the launch of the Expatriate Administration System (EAS). These reforms were designed to modernise the regulatory framework, improve transparency, and enhance the government’s ability to track expatriates in the country. They also aim to ensure that the engagement of foreign workers complements, rather than displaces, local talent. The new framework also carries important compliance obligations for employers and expatriates.

Some Challenges under the Old Regime
Prior to these reforms, several challenges were identified, which include;

a) Visa-on-arrival regimes and manual processes that were vulnerable to corruption and also created loopholes that fostered irregular migration and abuse of expatriate quotas.
b) Poor tracking of expatriates and unreliable data on the number of foreigners legally in Nigeria created blind spots.
c) Foreigners overstaying and weak enforcement mechanisms lead to irregular migration and security concerns.
d) Misuse of the Expatriate Quota system, where employers request foreign workers even when local capacity exists.

Overview of the New Expatriate Administration System (EAS)
The EAS is a comprehensive framework introduced by the Federal Ministry of Interior, coordinated with the Nigeria Immigration Service (NIS), to address the previous regime’s shortcomings. It comprises several core elements, which include:

1. Electronic Visa System (e-Visa): from May 1, 2025, Nigeria replaced its visa-on-arrival policy with a fully digital visa application system. Applications are to be processed online, documents uploaded, fees paid online, and the outcome delivered, including QR code visa documents via email.
2. Automated Landing and Exit Cards (Digital Arrival/Departure): travelers will now fill in landing and exit cards online (in advance of travel), rather than manually at airports or on arrival. This helps with tracking entries/exits and data collection.
3. Combined Expatriate Resident Permit and Aliens Card (CERPAC), upgraded to e-CERPAC: This permit, which allows residence and work, will now be processed online, with the aim of eliminating lobbying and delays.
4. Expatriate Comprehensive Insurance: expatriates will be required to carry insurance that covers costs such as repatriation. The idea is to shift some financial responsibility away from the state.
5. Temporary Resident Visa & Work Permit, along with revised Expatriate Quota System: the quota system will be more strictly enforced. Temporary work permits and residence visas will need to comply with the new rules. Employers requesting expatriate quotas will need stronger justification, especially on the availability of local expertise.

Major Changes in the Visa Policy, Penalties and Enforcement

1. The new system of applying for visas through the online portal is designed to process applications within 48 hours, while under the old regime, processing time could take longer because it was a manual process.
2. Overstay penalties have become more stringent. A daily fine of fifteen dollars applies from the day a visa expires. Individuals who overstay for six months face a five-year entry ban, while overstays exceeding one year attract a ten-year ban. The government also announced a three-month grace period, from May 1 to August 1, 2025, during which expatriates can regularise their status before the strict enforcement of penalties begins.
3. Visa extensions are now more restricted and, in most cases, must be initiated outside Nigeria. Employers are expected to comply strictly with the revised expatriate quota system, as misuse or abuse of quotas will attract sanctions.
4. Employers who aid or ignore violations may also be sanctioned. The Ministry further directed immigration officers to intensify inspections and data verification to identify irregular migrants. These measures are intended to promote accountability and safeguard national security.

Implications for Expatriates and Employers
The new framework carries both opportunities and obligations for expatriates and their employers.

For expatriates, visa types and durations must be carefully reviewed before travel. Awareness of the overstay penalties is also critical, as the new system allows little flexibility. The digital process makes applications easier, but it also enables the automatic detection of non-compliance.

For employers, it means Companies must demonstrate that no qualified Nigerians are available before seeking foreign expertise. They are also required to monitor the visa validity of their foreign employees and ensure that all necessary insurance and permits are maintained. Non-compliance may result in reputational damage, fines, or suspension of quotas.

Legal and Compliance Tips

From a legal standpoint, these changes require a proactive compliance strategy. Employers should review employment and secondment agreements with expatriates to include clauses on visa validity, repatriation responsibilities, and insurance coverage. Maintaining accurate immigration records and tracking visa expiration dates is equally important. Where uncertainties arise, it is advisable to seek legal guidance to navigate potential grey areas, especially on appeals or discretionary extensions.

It is also important to develop internal immigration compliance policies to ensure that organisations maintain a verifiable record of expatriate documentation and avoid inadvertent breaches.

Conclusion
Nigeria’s 2025 Expatriate Administration System and Visa Policy is a decisive move toward transparency, digital efficiency, and local capacity protection. These reforms introduce stricter rules and penalties, and they create a more predictable and accountable system. For expatriates, the new policy emphasises compliance and forward planning, while for employers, it reinforces the importance of lawful recruitment and responsible immigration management. Ultimately, these reforms mark an important step in balancing Nigeria’s economic openness with its commitment to national security and fair employment practices.