ΕλληνικάCERPAC stands for Combined Expatriate Residence Permit and Aliens Card. It is the document that allows a foreign national to live and work lawfully in Nigeria, and for most expatriates it is the single most important piece of paper they hold. Between 2025 and 2026 the system around it was rebuilt: applications moved online, the permit is now issued before arrival rather than after it, and enforcement has become considerably firmer. This article explains what the permit is, who needs it, how the process now runs, and where the new penalties bite.
The legal basis
The framework is statutory. Sections 37, 38 and 39 of the Immigration Act 2015 govern residence, employment and the revocation of residence permits, and the Nigeria Immigration Service derives its authority from section 2 of the same Act. Sections 11 to 14 of the Immigration Regulations 2017 empower the Service to issue residence cards to foreign nationals seeking employment or residence in Nigeria. The Nigeria Visa Policy 2020 sits alongside them and governs the visa classes through which an expatriate enters.
This matters because CERPAC is often described as an administrative formality. It is not. It is a permit granted under statute, revocable under statute, and its absence renders residence and employment unlawful for both the individual and the employer.
The permit classes
CERPAC is not a single document but a family of permits, and the class determines the requirements.
| Class | Who it covers |
| R2A | Expatriate employees of companies and their dependents, issued on the basis of an approved expatriate quota position. This is the standard corporate route. |
| R3A | Expatriates employed by companies operating in Free Trade Zones, and their dependents |
| R4A | Expatriates employed by government as government officials, and their dependents |
| R5A | Expatriates employed by international non-governmental organizations, and their dependents |
| N1A | Spouses of Nigerian citizens, a class of permanent residence permit granted under section 37(10) of the Immigration Act 2015 |
Students, dependents and retirees aged sixty-five and above who wish to reside in Nigeria after their working years also fall within the residence-permit framework, under their own requirements.
The expatriate quota: the step before the permit
For corporate employment, the permit is the second step, not the first. The expatriate quota is an approval granted by the Federal Ministry of Interior to a Nigerian-registered company, authorizing it to fill a defined number of named positions with foreign nationals. The quota belongs to the company, not to the individual. Only once a quota position exists can a foreign national be sponsored into it.
Two forms exist in practice. A quota granted on a permanent-until-reviewed basis is typically reserved for a top management position such as chairman or managing director, which spares that role the cycle of periodic renewal. Ordinary quota positions are granted for defined periods for directors and other employees. The consequence that catches companies out is straightforward: if an expatriate changes employer, the new company needs its own approved position. The permit does not travel with the person.
The quota exists to balance foreign expertise against local workforce development, and it carries the understudy obligation, namely the requirement to train Nigerian staff into the role over time. That obligation has moved from theory to enforcement, as set out below.
What changed in 2025 and 2026
On 1 May 2025 the Federal Ministry of Interior, with the Nigeria Immigration Service, launched the Expatriate Administration System. Quota applications, business permit requests and CERPAC applications now run entirely online through that platform, with supporting documents uploaded rather than lodged physically. Employers upload certificates of incorporation, tax clearance certificates and organizational charts among other material.
The most consequential change is to sequence. Under the previous system an expatriate entered Nigeria on a Subject to Regularization visa, valid for ninety days, and then applied to regularize residence and obtain the permit after arrival. The Immigration Service states that e-CERPAC is processed and issued before the expatriate enters the country, removing post-arrival regularization. Anyone planning a move on the old assumption, arrive first, regularize afterwards, is planning against a process that no longer works that way.
Alongside this, visa-on-arrival was replaced by a fully digital e-Visa platform covering individual, group and family applications; all visa decisions are now issued centrally by Immigration headquarters in Abuja even where applications are lodged at embassies or consulates; and all travelers entering or leaving Nigeria complete digital landing and exit forms.
Enforcement: the part that now costs money
| Measure | What it means |
| Overstay fine | A daily fine of US$15 applies, running from the exit date stated on the visa. A grace period ran from 1 May to 30 September 2025; enforcement began on 1 October 2025. |
| Re-entry bans | Longer overstays can attract re-entry bans in addition to the financial penalty |
| Sponsor consequences | Companies linked to defaulters risk losing the right to sponsor expatriates at all, a corporate consequence of an individual lapse |
| Renewal timing | A permit is treated as expired once renewal runs more than thirty days past the expiry date. Renewal applications should be made electronically at least thirty days before expiry. |
| Quota scrutiny | Applications now require compelling justification for each position, including evidence that qualified Nigerian talent is unavailable |
| Understudy audits | The Ministry audits compliance with the understudy requirement, expecting demonstrable milestones and outcomes in skill transfer |
| Repatriation insurance | Expatriate insurance is payable when CERPACs are purchased |
The renewal rule deserves particular attention because it is counter-intuitive. A permit does not merely become overdue after expiry. Once thirty days pass it is treated as expired, with the consequences that follow from unlawful residence. A diary entry ninety days before expiry is not excessive.
Costs
The Ministry of Interior’s published schedule lists e-CERPAC at US$2,000, expatriate insurance at US$1,000 for a year or US$500 for a period of ninety to one hundred and eighty days, and a business permit for a company limited by shares at ₦1,500,000. These figures are drawn from secondary reporting of the Ministry’s schedule and should be confirmed against the current official schedule before they are relied upon. [Figures to be verified against the Ministry of Interior schedule before publication.]
To the official charges must be added the cost of assembling corporate documents, authentication and translation where documents originate abroad, and professional fees. None of these can be fixed responsibly before the permit class, the quota position and the family composition are known.
A note on validity periods
Published sources differ on how long a CERPAC runs. The Immigration Service describes the permit as allowing residence and work for an extended period, usually one year and above, subject to renewal, while a number of practitioner sources refer to a two-year validity. The period granted in a particular case depends on the permit class and on the underlying quota position and employment contract, and should be read from the permit itself rather than assumed from general guidance.
Who does not need a CERPAC
Nationals of ECOWAS member states are exempt from the visa requirement and do not follow this route. They obtain an ECOWAS Residence Card and register with the Nigeria Immigration Service in their place of residence once resident. Citizens of countries with which Nigeria has visa abolition agreements are likewise exempt from the visa requirement. A business visa, it should be added, is strictly for business purposes and does not permit employment or remuneration in Nigeria.
What employers should audit now
| Step | What it involves |
| Map the workforce | List every expatriate, their permit class, expiry date and the quota position each occupies |
| Check quota alignment | Confirm that every expatriate sits against an approved position and that nobody has changed role or employer without a corresponding approval |
| Diarise renewals | Set reminders at ninety and sixty days before each expiry, given the thirty-day rule |
| Evidence the understudy programme | Document training milestones and role transition for each quota position, in a form that would survive an audit |
| Budget for insurance | Allocate for expatriate insurance payable on CERPAC purchase |
| Review the entry sequence | Ensure recruitment and relocation planning reflects pre-arrival processing rather than post-arrival regularization |
| Close historic gaps | Identify anyone whose status lapsed and address it before enforcement does |
Conclusion
Nigeria has not made it harder to bring expatriates in; it has made it harder to be careless about it. The process is faster and more transparent than the one it replaced, and pre-arrival issue of the permit is a genuine improvement for anyone who plans properly. The risk has shifted to those who do not: to the company that assumes the old sequence still applies, that lets a renewal drift past thirty days, or that cannot evidence its understudy programme when the Ministry asks. Each of those is avoidable, and each is cheaper to fix before it is found.
Frequently asked questions
What does CERPAC stand for?
Combined Expatriate Residence Permit and Aliens Card. It is the residence permit that allows a foreign national to live and work lawfully in Nigeria.
What is the legal basis for it?
Sections 37, 38 and 39 of the Immigration Act 2015, together with sections 11 to 14 of the Immigration Regulations 2017, which empower the Nigeria Immigration Service to issue residence cards.
Do I need an expatriate quota as well?
For corporate employment, yes. The quota is granted to the Nigerian company and authorizes named positions; a foreign national can only be sponsored into an approved position. The quota belongs to the company, not the individual.
What changed with e-CERPAC?
The permit is now processed and issued before arrival, which removes the previous post-arrival regularization step. Applications run through the Expatriate Administration System online.
When should I renew?
Electronically, at least thirty days before expiry. Once renewal runs more than thirty days past the expiry date the permit is treated as expired.
What happens if someone overstays?
A daily fine of US$15 applies from the exit date stated on the visa, enforced since 1 October 2025, with possible re-entry bans. Companies linked to defaulters risk losing the ability to sponsor expatriates.
Do ECOWAS nationals need a CERPAC?
No. They obtain an ECOWAS Residence Card and register with the Immigration Service in their place of residence.
How we work on Nigerian matters
OIKONOMAKIS LAW coordinates international investments, cross-border transactions and multi-jurisdictional matters involving Nigeria through its international platform and local professional-services structure. Nigerian-law advice, reserved legal work, filings and representation before Nigerian authorities are undertaken independently by locally admitted Nigerian network counsel, under their own professional responsibility.
For an international employer, that means the coordination of a multi-country mobility programme, the employment and tax questions arising in the home jurisdiction and the management of the overall project sit with the firm, while the quota application, the permit filings and any engagement with the Nigeria Immigration Service are handled by counsel admitted in Nigeria.
Contact
Email: leads@oikonomakislaw.com
WhatsApp: +44 20 3769 4973
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Disclaimer
This article is provided for information, reflects the position as at the legal review date stated above and does not constitute legal advice on any particular matter. Fees, processing arrangements and administrative practice change, and should be confirmed with the Nigeria Immigration Service or the Federal Ministry of Interior at the time of application.
Sources
Nigeria Immigration Service, Combined Expatriate Residence Permit and Aliens Card, https://immigration.gov.ng/combined-expatriate-residence-permit-and-aliens-card-cerpac/
Nigeria Immigration Service, e-CERPAC portal and permit classes, https://cerpac.immigration.gov.ng/
Nigeria Immigration Service, e-CERPAC, pre-arrival processing, https://immigration.gov.ng/e-cerpac-combined-expatriate-residence-permit-and-aliens-card/
Immigration Act 2015, sections 2, 37, 38, 39 and 37(10)
Immigration Regulations 2017, sections 11 to 14
Nigeria Visa Policy 2020
Federal Ministry of Interior, Expatriate Administration System, launched 1 May 2025
Prepared by OIKONOMAKIS LAW with Independent Local Network Counsel in Nigeria