The National Pension Commission (PENCOM) has extended the deadline for Pension Fund Administrators (PFAs) and Pension Fund Custodians (PFCs) to comply with its revised minimum capital requirements, granting operators six additional months to meet the new standards.
In an addendum to its earlier circular of 26 September 2025 (Ref: PenCom/INSP/Surv/2025/1255), released this week, the Commission confirmed that the compliance deadline has now been shifted from 31 December 2026 to 30 June 2027. The document, signed by A.M. Saleem, Director of the Surveillance Department, also offered fresh clarifications to guide operators ahead of the new deadline.
The addendum introduces significant updates aimed at easing compliance pressure and improving transparency in capital computation. These include:
• Inclusion of Statutory Reserve Fund (SRF):
The SRF will now count as part of Shareholders’ Funds across all PFA categories (A, B and C). The move is expected to strengthen operators’ capital positions and reduce the immediate burden of raising fresh capital.
• Refinement of AUM-Based Surcharge for Category A PFAs:
Certain funds will now be excluded from the calculation of the 1% capital surcharge tied to Assets Under Management (AUM). These include:
– Fund V (Personal Pension Plan)
– Fund VII (Foreign Currency Fund)
– Approved Existing Schemes
– Additional Benefit Schemes
The exclusions aim to ensure a more accurate representation of risk exposure in the capital framework.
PENCOM reaffirmed that compliance will continue to be monitored biannually through audited financial statements. Any identified shortfalls must be addressed within 90 days of notification.
The Commission stressed that while existing operators have been granted an extension, the revised capital requirements remain effective immediately for new licences, reinforcing its commitment to safeguarding financial stability within the pension sector.
The extension provides much-needed relief to PFAs and PFCs navigating the sector’s most significant regulatory overhaul in more than 20 years. By allowing the SRF as part of capital and adjusting AUM calculations, PENCOM appears to be striking a balance between regulatory discipline and operational flexibility.
Operators seeking clarification have been advised to contact the Commission’s Surveillance Department.
In September, PENCOM introduced a sweeping review of capital requirements for PFAs and PFCs, raising the minimum capital for PFAs to ₦20 billion. PFAs with AUM of ₦500 billion and above must now maintain ₦20 billion plus 1% of excess AUM, while those below the threshold must meet a flat ₦20 billion minimum.
Special-purpose PFAs, including NPF Pensions Limited, are required to maintain ₦30 billion, while the Nigerian University Pension Management Company Limited must hold ₦20 billion.
The reforms are designed to bolster resilience in the pension industry, which now manages assets exceeding ₦18 trillion, and to ensure operators remain financially sound amid a rapidly expanding retirement savings market.













