Labels used on this page: Law / regulation statute, gazetted regulation or binding guideline · Commercial procedure a seller's contract terms or tender rules · Industry practice customary but not required · Unverified claim we could not confirm it from an official source.
The framework in one view
The Petroleum Industry Act 2021 is the governing statute. It created the Nigerian Upstream Petroleum Regulatory Commission (NUPRC) as upstream regulator, with power to issue certificates of quality and quantity to crude exporters and to regulate export terminals, and it incorporated NNPC Limited as a commercial company.1 Law / regulation Beneath the Act sit gazetted regulations. Two matter most to an export cargo: the Advance Cargo Declaration Regulations 2024 and the Production Curtailment and Domestic Crude Oil Supply Obligation Regulations 2023. Both appeared on the regulator's register of gazetted regulations, without amendment, when we checked in September 2026.2
A change of leadership at the regulator in December 2025 did not, so far as we can establish from its registers, alter any of the export instruments described here.2
Advance Cargo Declaration and the UIN
The Advance Cargo Declaration Regulations were made in March 2024 and gazetted in April 2024.3 Law / regulation Their stated purpose is to ensure that only certified production is exported and to prevent theft and under-declaration. They require that:
- every export is preceded by a declaration stating the producer, the exporter, the consignee, the terminal, the vessel's flag, tonnage and IMO number, its expected arrival, the nominated quantity and the destination, accompanied by a copy of the export permit;
- the declaration is made at least five days before the vessel's expected arrival, with an administrative charge for late filing;
- no petroleum is exported without a Unique Identification Number, issued after the regulator has verified the declaration and cleared the vessel, and imprinted on the certificate of quantity and quality, the bill of lading and other export documents; and
- false information attracts a fine of up to US$20,000, and exporting without a UIN a fine of up to US$1,000,000.
Guidelines approved on 17 June 2025 put the regime into operation.4 The sequence is: export permit → application for vessel clearance on the declaration portal → validation by the regulator that the applicant holds the permit for that crude stream and that the volume is within it → clearance notification to the terminal operator carrying the UIN → loading → certificate of quantity and quality → the UIN recorded on the bill of lading, certificate of origin, manifest and vessel documents. The guidelines set a vessel-clearance fee of US$0.03 per barrel. Two leading Nigerian law firms have published consistent summaries.56
A genuine Nigerian cargo loaded since mid-2025 should carry a regulator-issued UIN on its bill of lading, certificate of origin and manifest, and the consignee and vessel will have been declared at least five days before arrival. The absence of a UIN on such documents is a serious warning sign. We have found no public tool for checking a UIN, so its presence alone proves nothing; treat it as one check among several in the verification centre.
The export permit
Both the regulations and the guidelines define the export permit as one issued by the Federal Ministry of Industry, Trade and Investment; the upstream regulator processes and endorses the application, sizes the permitted volume on the producer's entitlement net of any domestic supply obligation, and ensures that exports do not breach that obligation.37 Law / regulation Applications are made through the regulator's online portal, whose public page states an application fee of US$1,000; that page is undated and we have not confirmed that the fee is current.8
The important point for an international buyer is who holds the permit: the producer or exporter — the parties described in who can lawfully sell Nigerian crude. A foreign buyer does not obtain a Nigerian export permit and should be wary of anyone offering to procure one for a fee.
The domestic crude supply obligation
The Act provides that crude is supplied to the domestic market on a willing-supplier, willing-buyer basis, but empowers the regulator to impose a supply obligation; crude under the obligation may be sold only to licensed operating refineries, at commercially negotiated prices having regard to international prices, payable in US dollars or naira as agreed.1 Law / regulation
The 2023 regulations implement this.7 Law / regulation The regulator publishes refinery requirements, producers respond to requests for quotation, and where supply is not agreed the regulator may impose an obligation. Where a producer's quarterly output is below its quota, domestic supply must be satisfied before export is permitted. Law-firm commentary records penalties for non-compliance, and an amendment proposed in 2024 remained a draft on the regulator's register in 2026.9102
Press reports in February 2025 described a letter from the regulator stating that it would refuse export permits for cargoes designated for domestic refining.11 We have not located the letter itself on the regulator's website. On the reporting, this is a targeted restriction on designated cargoes — not a general ban on crude exports.
Separately, a government policy introduced on 1 October 2024 has NNPC selling crude to domestic refineries in naira; the Ministry of Finance confirmed in April 2025 that it is a standing policy.12 It reduces the volume available for export but does not change how export cargoes are sold. See the Dangote refinery profile.
Documents in a Nigerian crude export
Most Nigerian crude is sold FOB, so these documents are generated at the load port; how responsibilities divide between seller and buyer is covered in FOB and CIF explained, and the loading points themselves in the export terminal database.
| Document or step | Issued or filed by | Status | Notes |
|---|---|---|---|
| Export permit | Federal Ministry of Industry, Trade and Investment; processed and endorsed by the upstream regulator through its online portal | Law / regulation | Held by the producer or exporter — never by the foreign buyer. Sized to the producer's entitlement net of domestic supply obligations.378 |
| Advance cargo declaration | Filed by the exporter on the regulator's portal at least five days before the vessel's arrival | Law / regulation | Names the producer, exporter, consignee, terminal, vessel flag and IMO number, quantity and destination.3 |
| Vessel clearance and Unique Identification Number (UIN) | Upstream regulator | Law / regulation | No petroleum may be exported without a UIN. Fine of up to US$1 million for exporting without one.34 |
| Certificate of quantity and quality | Issued by the upstream regulator after loading | Law / regulation | Must carry the UIN. Reports by an inspector appointed by the buyer are industry practice, in addition.14 |
| Bill of lading | Carrier, at the terminal | Commercial procedure | The UIN requirement is law; the bill of lading date also starts the pricing and payment clocks under NNPC's contract.313 |
| Certificate of origin; cargo manifest | Seller / terminal | Commercial procedure | Must carry the UIN under the 2025 guidelines.4 |
| Form NXP and repatriation of proceeds | Exporter, through an authorised dealer bank | Law / regulation | An exporter-side requirement: the Act provides for a prescribed export form, administered under central bank rules that also govern repatriation of proceeds. We have not read the central bank's primary circulars.14 |
| Pre-shipment inspection (Clean Certificate of Inspection) | Government-appointed inspection agent | Law / regulation | Required by the Pre-Shipment Inspection of Exports Act, which covers oil exports. We have not verified the current appointed agents or levy rate.14 |
| Letter of credit and commercial invoice | Buyer's bank / seller | Commercial procedure | NNPC's terms require an irrevocable documentary credit under UCP 600. Other sellers' terms vary.13 |
Vessel-side clearances from port, maritime and naval authorities are handled by the ship's agent; we have not identified the legal instruments behind each and do not describe them here. Unverified claim
We searched the Act, the regulations, the guidelines and NNPC's tender and contract templates. None of them mentions an ICPO, FCO, ATV, ATS, ATB, TTO, TTM, "NNPC allocation number", "seller's mandate" or "proof of product by dip test on a loaded vessel". These are not legal requirements or NNPC procedures.1341513
International compliance for buyers
- Sanctions. The US Treasury's list of sanctions programmes contained no Nigeria country programme when we checked on 18 September 2026, so exposure is list-based: the seller, its owners, the vessel, banks and intermediaries must each be screened.16
- Financial-crime status. Nigeria was placed on the Financial Action Task Force's list of jurisdictions under increased monitoring in February 2023 and removed in October 2025.17 Later plenary outcomes should be checked on the FATF website. Removal does not end risk-based due diligence by banks financing Nigerian oil trades.
- Destination controls. NNPC's contract restricts destinations and allows it to demand proof of discharge; the destination is also declared to the regulator before loading.133 Commercial procedure
- Know-your-customer. NNPC's own tender requires disclosure of beneficial owners and anti-corruption undertakings; bank-industry principles require understanding of counterparties, goods and flows.1518 Our buyer centre lists what to prepare.
What we could not verify
In the interests of transparency: we have not located NNPC's tender documents for contract cycles after 2021–2023; the current export-permit fee and validity period; the text of the regulator's February 2025 letter on domestic supply; the central bank's primary circulars on export proceeds; or the current pre-shipment inspection agents for oil exports. Where these matter to a transaction, take advice from a Nigerian law firm. This page is general information, not legal advice.