By: Khadijat Akewushola – Legal Consultant
With effect from 1 January 2026, the Nigeria Revenue Service (NRS) has taken over the collection of mineral royalties from mining operators across the country, marking a clear shift from the Ministry of Solid Minerals Development, which previously served as the sector’s primary revenue collector.
This is in line with the provisions of the new tax acts, which consolidate the administration of federally collectable revenue under the NRS, leaving the relevant Ministries and agencies to focus on policy design and coordination in their respective sectors.
The Policy Rationale: A Single Window for Federal Revenue
The consolidation of mineral royalty collection under the NRS is part of a broader government objective to create a single administrative window for all federally collectable revenue. Previously, a mining operator would interact with both the Ministry of Solid Minerals (for royalties) and the NRS (for corporate income tax, VAT, and other obligations). That fragmentation created room for leakages and made it difficult to reconcile compliance across agencies.
Under the new framework, all revenue obligations, royalties, CIT, and VAT flow through the NRS. This means a mining operator’s full tax profile now sits in one place, simplifying the process for obtaining Tax Clearance Certificates (TCCs) and reducing the administrative burden on operators who previously had to manage compliance across multiple agencies.
Division of Roles: NRS and the Ministry of Solid Minerals
While the NRS now handles revenue, filings, payments, and royalty accounting, the Ministry of Solid Minerals retains its technical and regulatory role, issuing and managing mining licences, providing geological data, setting official mineral pricing benchmarks used in computing royalties, and coordinating sectoral policy.
Operators will still deal with the Ministry for their licences and technical matters. But all royalty payments now go to the NRS.
The Statutory Basis: Section 20, NTAA 2025
Section 20 of the Nigerian Tax Administration Act 2025 (NTAA) provides that every person engaged in the trade or business of mining shall, upon the commencement of the Act or upon the start of operations, file a monthly self-assessment return of minerals royalty with the Service. The return must be submitted in the prescribed form, and the royalty due on minerals sold or used must be paid at the prescribed rate.
The applicable rates are prescribed under the Ninth Schedule to the Nigeria Tax Act 2025.
How Royalties Are Computed
Under the Ninth Schedule to the Nigeria Tax Act 2025, solid mineral royalties are computed on an ad valorem basis, meaning they are calculated as a percentage of the value of the solid mineral resource extracted. The value of each mineral is determined using either the official selling price set by the Federal Ministry of Solid Minerals or the ruling prices on an international trading platform or market for solid minerals.
The table below sets out the prescribed rates for all listed mineral as provided under the Nigeria Tax Act
| S/N | Mineral | Ad Valorem Rate (%) |
| 1 | Antimony Ore | 7.5 |
| 2 | Amethyst | 10 |
| 3 | Aquamarine | 10 |
| 4 | Barytes | 10 |
| 5 | Bauxite | 7.5 |
| 6 | Bentonite | 10 |
| 7 | Beryllium | 10 |
| 8 | Bismuth | 7.5 |
| 9 | Bitumen / Tar Sand | 7.5 |
| 10 | Chalcopyrite | 7.5 |
| 11 | Chromite | 10 |
| 12 | Clay | 10 |
| 13 | Coal | 7.5 |
| 14 | Columbite Ore (<10% Nb2O5) | 7.5 |
| 15 | Columbite Concentrate (>10% Nb2O5) | 7.5 |
| 16 | Copper Ore | 7.5 |
| 17 | Corundum | 10 |
| 18 | Crystal Quartz | 10 |
| 19 | Diatomite | 10 |
| 20 | Dolomite | 10 |
| 21 | Emerald | 10 |
| 22 | Feldspar | 10 |
| 23 | Flourite | 10 |
| 24 | Garnet | 10 |
| 25 | Gold Concentrate | 15 |
| 26 | Granite Blocks | 10 |
| 27 | Granite Aggregates | 10 |
| 28 | Granite Dust | 10 |
| 29 | Graphite | 10 |
| 30 | Gypsum | 10 |
| 31 | Ilmenite | 7.5 |
| 32 | Industrial Quartz | 10 |
| 33 | Iron Ore | 7.5 |
| 34 | Kaolin (Crude) | 10 |
| 35 | Kaolin (Pulverized) | 10 |
| 36 | Laterite | 10 |
| 37 | Lead/Zinc Ore (<55% Pb, <30% Zn) | 7.5 |
| 38 | Lead/Zinc Concentrate (>55% Pb, >30% Zn) | 7.5 |
| 39 | Limestone (Crude) | 10 |
| 40 | Lithium Ore | 10 |
| 41 | Magnesite | 7.5 |
| 42 | Marble Aggregates | 10 |
| 43 | Marble Blocks | 10 |
| 44 | Manganese | 7.5 |
| 45 | Molybdenum | 7.5 |
| 46 | Monazite | 10 |
| 47 | Mica | 10 |
| 48 | Nickel | 10 |
| 49 | Phosphate | 10 |
| 50 | Pyrite | 7.5 |
| 51 | Ruby | 10 |
| 52 | Rutile | 7.5 |
| 53 | Salt | 10 |
| 54 | Sand | 10 |
| 55 | Sapphire | 10 |
| 56 | Shale | 10 |
| 57 | Silica Sand | 10 |
| 58 | Silver Ore | 7.5 |
| 59 | Soda Ash / Trona | 10 |
| 60 | Spodumene | 10 |
| 61 | Talc | 10 |
| 62 | Tantalite (Crude) (<30% Ta2O5) | 7.5 |
| 63 | Tantalite Concentrate (>30% Ta2O5) | 7.5 |
| 64 | Tin Ore (<50% Sn) | 7.5 |
| 65 | Tin Concentrate (>50% Sn) | 7.5 |
| 66 | Topaz | 10 |
| 67 | Tourmaline (Green) | 10 |
| 68 | Tourmaline (Pink & Blue) | 10 |
| 69 | Wolframite | 7.5 |
| 70 | Zircon | 10 |
| 71 | Zircon Sand | 10 |
| 72 | Moganite | 10 |
| 73 | Any Other Mineral | 10 |
Filing Obligations and Deadlines
Section 20 of the NTAA further provides that rturns of royalty for each month must be filed on or before the 21st day of the following month. Each return must be accompanied by the following:
- registered number of quarrying or mining licences
- type of mineral and weight
- location and labour used
- quarriable minerals in metric tons or cubic metres
- quantity of mineral won, sold, used and left on hand
- buyers of minerals
- computation of royalty payable on the mineral won, used or sold
- duly completed royalty self-assessment form
- evidence of payment of royalty due
- a declaration signed by an authorised officer of the company, stating that the returns, schedules, statements, and other information given are correct and complete
- such other information as may be required from time to time by the Service
Review and Reassessment
The NRS will review the royalty returns filed and may, where necessary, reassess the royalty payable. Any additional royalty arising from such reassessment must be paid within 30 days of the service of the notice of assessment. The provisions of the NTAA on notice of assessment, additional assessment, appeals, and other proceedings apply to any assessment or additional assessment made under this section.
What Mining Operators Should Do Now
Given that the new framework is already in effect, operators should take the following steps without delay:
- Verify your TIN classification. Confirm that your Tax Identification Number (TIN) is active with the NRS and correctly categorised under the mining or extractive industry. Misclassification can create filing errors and delays.
- Update your internal filing workflows. Royalty payments that were previously directed to the Ministry of Solid Minerals must now be routed through the NRS. Update your finance and compliance processes accordingly. Filing on old Ministry channels after the transition may attract penalties.
- Reconcile your TCC records. Since royalties will now be captured alongside your CIT and VAT records at the NRS, operators seeking Tax Clearance Certificates should ensure there are no outstanding liabilities on any of these fronts. Gaps in royalty payment history may affect TCC issuance going forward.
- Seek professional advice on pending assessments. Operators with royalty disputes or pending reassessments under the old Ministry arrangement should obtain legal and tax advisory guidance on how those matters will be treated under the new regime and how to generally approach the transition.