The National Minimum Wage (Amendment) Act 2024: An Employer's Compliance Guide
The National Minimum Wage (Amendment) Act 2024 raised Nigeria's minimum wage to ₦70,000 a month and shortened the review cycle. Here's what employers still need to check.
The new rate and timing
The National Minimum Wage (Amendment) Act 2024 sets the national minimum wage at ₦70,000 per month for eligible employees — a significant increase from the previous 2019 rate. The Act was signed into law and came into effect on 29 July 2024, but the new rate is stated to take effect from 1 May 2024, meaning employers who paid below ₦70,000 between May and July 2024 may owe back‑dated arrears. The Act also shortened the mandatory wage review period from five years to three.
Who is exempt
Not every employer is caught by the new floor. Notable exemptions include:
- Establishments with fewer than 25 employees.
- Workers employed on a part‑time, commission‑based or piece‑rate basis.
- Workers in seasonal employment such as agriculture, construction and tourism.
- Crew covered by merchant shipping or civil aviation legislation.
Exemption is fact‑specific — don't assume your business qualifies without checking against the precise statutory wording.
Core compliance obligations
- Pay all eligible employees at least ₦70,000 per month.
- Keep accurate records of salaries and conditions of employment for every employee.
- Calculate and settle any arrears owed for the May–July 2024 gap, if applicable.
Penalties for non‑compliance
- Failure to pay the minimum wage: a fine of up to 5% of the employer's monthly wage bill, plus payment of all outstanding wage arrears.
- A further penalty at a rate not less than the prevailing CBN lending rate on unpaid wages, for each month the violation continues.
- Failure to keep required records: a fine of up to ₦75,000, plus a further ₦10,000 for each day the failure continues.
Employer checklist
- Audit payroll to confirm every eligible employee is paid at least ₦70,000/month.
- Confirm whether any exemption genuinely applies to your business before relying on it.
- Calculate and settle any outstanding arrears from May–July 2024, if not already done.
- Update employment contracts, offer letters and payroll systems to reflect the new floor.
- Tighten record‑keeping on salaries and employment conditions — this is separately enforceable.
Quick FAQs
We have 20 employees — are we exempt?
Establishments with fewer than 25 employees fall within one of the Act's exemptions, but you should confirm how this applies to your specific structure (e.g., group companies, related entities) before relying on it.
Do we owe arrears even though the Act wasn't signed until July 2024?
The Act states the new rate applies from 1 May 2024, so employers who paid below ₦70,000 for eligible staff between May and the signing date may need to calculate and pay arrears.
Does the minimum wage apply to casual or seasonal staff?
Workers in seasonal employment such as agriculture, construction and tourism are carved out under the Act — but classification disputes are common, so get the categorisation right before treating anyone as exempt.
Need help?
This guide is for general information only and does not constitute legal advice — see our Disclaimer. For advice tailored to your business, get in touch.
Key Sources
- National Minimum Wage (Amendment) Act, 2024.
- Federal Ministry of Labour and Employment.
Last updated: July 2026. Laws and enforcement practice in this area are moving quickly — please confirm current status with us before relying on any specific figure or deadline.