The National Pension Commission (PENCOM) has granted licensed pension fund administrators (PFAs) and pension fund custodians (PFCs) an extended deadline to meet the regulator’s updated minimum capital requirements. With this extension, the new compliance cut-off is now 30 June 2027, replacing the earlier deadline of 31 December 2026.
In a recent addendum to its earlier circular dated 26 September 2025 (Ref: PenCom/INSP/Surv/2025/1255), the Commission described the shift as providing additional clarifications to the revised regulatory capital requirements. Key among the clarifications is the decision to include the Statutory Reserve Fund (SRF) as part of shareholders’ funds when assessing the capital base for all PFA categories A, B and C. This inclusion is intended to ease the pressure on PFAs to raise fresh capital.
Another adjustment is the exclusion, when calculating the 1 % capital surcharge based on assets under management (AUM), of certain funds held by Category A PFAs. Specifically excluded are Fund V (Personal Pension Plan), Fund VII (Foreign Currency Fund), Approved Existing Schemes and Additional Benefit Schemes. These exclusions aim to refine the calculation of risk exposure and make the surcharge more precise.
PENCOM stressed that the revised capital requirements apply immediately for new licences, while existing operators receive the extended window to comply. The regulator also reaffirmed that it will monitor compliance on a bi-annual basis via audited financial statements, and requires any shortfall to be resolved within 90 days of notification.
For the industry, this extension offers a welcome breathing space. Many PFAs and PFCs had been struggling with the earlier timeline amid the heightened threshold. By giving the extra six months (to mid-2027), PENCOM appears to be recognising implementation challenges while still pressing for stronger capital buffers.
Previously in September, PENCOM had announced sweeping revisions to its minimum capital requirements: PFAs with AUM of N500 billion or more now face a capital base requirement of N20 billion plus 1 % of excess AUM beyond N500 billion; those under N500 billion are also required to hold at least N20 billion. Special-purpose PFAs such as the Nigerian University Pension Management Company Limited are subject to similar high thresholds.
The extended timeline helps stabilise the pension services sector by reducing the immediate capital-raising burden on PFAs and PFCs. This may preserve employment and investment continuity in Nigeria’s pensions ecosystem, supporting the broader economy through steadier fund flows and financial-sector confidence amid regulatory tightening.




