Author: Lateef Bamidele

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FOUR YEARS ON: HAS THE PIA DELIVERED ON ITS PROMISE?

Energy Practice Team

Introduction

On 16 August 2025, the Petroleum Industry Act, 2021 (“PIA”) turns four, enacted after nearly two decades in development, the PIA marked a pivotal moment in Nigeria’s energy landscape, aiming to overhaul a sector long constrained by outdated legislation, weak regulatory structures, and underwhelming investment. It aimed to drive economic growth, enhance governance, foster competition, and align Nigeria’s petroleum industry with global standards. The PIA promised improved fiscal terms, stronger oversight, and tangible benefits for host communities. With Nigeria securing only 4% of Africa’s $70 billion oil and gas investments between 2015 and 2019[1] despite having one of the continent’s largest reserves and production capacity, the urgency for reform was evident. Yet, its passage coincided with a global shift toward cleaner energy, raising questions about its timeliness and relevance.  Four years on, this article evaluates the PIA’s impact and explores its implications for Nigeria’s energy future in a rapidly evolving global market.

The Promise of the PIA

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FUELING CHANGE: REFLECTING ON TWO YEARS OF PETROLEUM INDUSTRY ACT

by Dr. Adeoye Adefulu & Lateef Bamidele

It’s hard to believe that August 16, 2021, is now two years behind us, signifying the momentous occasion when the Petroleum Industry Act 2021 (“Act” or “PIA”) was enacted into law. Over the past two years, the industry has been navigating and adjusting to the new legislative landscape. While opinions on the progress achieved during this period may differ within the industry, one undeniable fact is the array of significant activities that have unfolded, leaving an indelible mark on the industry’s current trajectory.

In commemorating the first anniversary of the Act, we examined the spectrum of implementation activities that transpired within the initial twelve months following the Act’s enactment. Likewise, we published a newsletter titled Petroleum Industry Act; Implementation Developments and Regulatory Compliance Issues ahead of the eighteen months anniversary. That paper further scrutinized these implementation activities while underscoring the pertinent compliance concerns for the industry. For this edition of our newsletter, we will focus on fresh developments witnessed in the last six months.

As we observe the second anniversary of the Act, our attention now shifts to the novel activities spearheaded by the two industry regulators, the Nigerian Upstream Petroleum Regulatory Commission (“Commission”) and the Nigerian Midstream and Downstream Petroleum Regulatory Authority (“Authority”). These activities shed light on the evolving landscape of the petroleum industry in Nigeria.

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PETROLEUM INDUSTRY ACT; IMPLEMENTATION DEVELOPMENTS AND REGULATORY COMPLIANCE ISSUES!

by Oludamola Awobokun & Lateef Bamidele

We are well into the second year of implementation of the Petroleum Industry Act 2021 (“Act”), and regulatory activities within the walls of the two regulators – the Nigerian Upstream Petroleum Regulatory Commission (“Commission”) and the Nigerian Midstream and Downstream Petroleum Regulatory Authority (“Authority”) (jointly referred to as the “Regulators”) have accelerated.

In our newsletter titled Implementing the Petroleum Industry Act 2021: One Year After, we considered some of the implementation activities that were undertaken within a year of the passage of the Act. In another newsletter, titled Critical Deadlines in the Petroleum Industry Act 2021, we examined some of the possible factors that may impact compliance with the relevant timelines for certain regulatory activities under the Act. As we approach another critical milestone in the implementation of the Act, this newsletter seeks to provide new implementation updates as well as key timelines that the industry must be aware of.

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HOW MARGINAL ARE THE MARGINAL FIELDS’ PROVISIONS UNDER THE PETROLEUM INDUCTRY ACT 2021?

by Adeoye Adefulu & Lateef Bamidele

The Petroleum Industry Act 2021 (“PIA” or “Act”) introduced changes across the Nigerian petroleum industry, and one of such changes is the overhaul of the administration of marginal field assets. The Act set a deadline of 18 months (February 15, 2023) for the transition of the existing marginal field assets into the PIA terms[1] and put an end to the regime[2] which has hitherto enabled small and indigenous players to participate in the industry for about two decades. This article examines the transition mechanisms for this category of assets and what it portends for the industry operators.

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Nigeria begins implementation of the Petroleum Industry Act 2021

Since the passage of the Petroleum Industry Act (“PIA”) on August 16, 2021, several noteworthy developments have taken place, which we highlight below.

  • The Federal Government sets up PIA Implementation Committee
  • NNPC becomes a limited liability company
  • The President and Minister of Petroleum Resources constitutes board of the Regulatory Institutions
  • The President seeks to amend the PIA

The Federal Government sets up PIA Implementation Committee

On Thursday, 19th of August 2021, the Federal Government inaugurated the steering committee for the implementation of the PIA, headed by the Minister of State for Petroleum Resources, Chief Timipre Sylva. The implementation structure is made up of the Steering Committee to be supported by an Implementation Working Group/Coordinating Secretariat (“IWGCS”) for effective and timely implementation of the PIA during the transition to the new petroleum industry regime.

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