On 5 May 2025, the Nigerian Upstream Petroleum Regulatory Commission (the NUPRC or the Commission), further to its powers under the Petroleum Industry Act 2021 (the PIA), issued the Nigerian Upstream Petroleum (Commercial) Regulations 2025 (the Regulations). The Regulations provide a framework for regulatory approval and oversight of commercial activities in upstream petroleum operations, specifically as it relates to field development plan and annual work programme.
These Regulations set out new requirements for the approval of Field Development Plans (FDPs), Phase Development Plans (PDPs), and Annual Work Programmes (AWPs), including commercial viability tests, cost benchmarks, and stricter reporting standards.
Operators must now meet rigorous approval thresholds for project planning and execution, backed by financial modelling, risk forecasting, and ROI analysis. The framework aims to improve cost efficiency, ensure compliance, and attract sustained investment in Nigeria’s oil and gas sector.
In this newsletter, we outline the key provisions of the Regulations and their implications for stakeholders. Read the full newsletter to explore the key compliance triggers, penalty regime, and strategic insights for navigating the new regulatory landscape.
