Expatriate Employment Levy: Where Things Stand in 2026 and How Employers Should Prepare

The Federal Executive Council approved the Expatriate Employment Levy regulation in May 2023. The Federal Ministry of Interior then issued the EEL Handbook on 27 February 2024, setting out registration and payment procedures via an online portal, with implementation due to start on 15 March 2024.

• Applies to expatriate directors and employees employed for at least 183 days in a fiscal year (diplomatic and government personnel are excluded).
• Annual levy: USD 15,000 per expatriate director and USD 10,000 per other expatriate employee — payable in naira at the prevailing daily exchange rate.
• Registration: via the online EEL portal, with employers required to keep records (salary details, work permits) and report changes in expatriate employment.
• Penalties (under the Handbook): ₦3,000,000 for failing to apply within 30 days, and a further ₦3,000,000 for failing to register new employees within 30 days.

Implementation was suspended on 8 March 2024 — before it even took effect — following pushback from employers and business groups such as NACCIMA, to allow further stakeholder consultation. As of our last review, the levy remains suspended with no confirmed reinstatement date, and the matter has also drawn court attention, with reports of a court summoning the relevant minister and the Attorney‑General over implementation questions. This is a genuinely fluid situation — confirm the current status with us or check the official portal before assuming either that the levy applies or that it has been permanently scrapped.

• The underlying portal (eel.interior.gov.ng) and Handbook still exist — suspension is not repeal.
• If reinstated, the Handbook's short 30‑day registration windows and steep flat penalties mean employers who aren't ready could face fines quickly.
• Good expatriate‑employee record‑keeping (salary, work permits, tenure) is good practice independent of the EEL, and supports quota, STR/TWP and CERPAC compliance too.

1. Maintain an up‑to‑date register of expatriate directors and employees, including salary and permit details.
2. Build a contingency budget line for the levy (USD 15,000/USD 10,000 per head, as last proposed) in case it is reinstated.
3. Assign someone to monitor Ministry of Interior and Nigeria Immigration Service announcements on the levy's status.
4. Don't rely on informal assumptions that the levy is "cancelled" — confirm current status before making hiring or budgeting decisions that depend on it.