What is the reminder? The Nigerian Content Development and Monitoring Board continues to conduct audits of oil and gas companies to enforce compliance with expatriate quotas. Employers should note that the board has historically focused on the accuracy of succession plans when measuring compliance.

  • Implementation time frame: Ongoing.
  • Who is affected: Oil and gas companies that employ foreign workers. 
  • Next steps: Employers are encouraged to maintain accurate and up-to-date succession plans, documents such as registration on the board’s portal and a list of expatriate positions that have been approved by the board. During audits, the monitoring team may request additional documents as it deems fit.   

Background: The Nigerian Content Development and Monitoring Board has been increasingly concerned with noncompliant deployment of expatriates on oil and gas projects. In March, the board released a Public Notice on Consequences of Non-Compliance to oil and gas companies, which listed recurring compliance violations seen by the board. Since its creation in 2010, the board has been monitoring the oil and gas industry, but since the release of the notice in March, it has increased the number of audits that it is conducting.

Analysis & Comments: Companies operating in the oil and gas sector should take measures to ensure that their records are properly reviewed and validated with the Nigerian Content Development and Monitoring Board.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, for purposes London EC4A 3HQ, United Kingdom.