NIIRA 2025 tightened who may hold a premium in Nigeria and how quickly a broker must remit it. The collection sequence, the wording and the records to keep.
Every brokerage in Lagos, Abuja or Port Harcourt has the same conversation several times a week. The client wants cover to start on Monday, the premium will follow "as soon as the account is funded", and somebody has to decide what to tell the insurer. Nigerian law has answered that question the same way for more than a decade — no premium, no cover — and the Insurance Industry Reform Act signed in August 2025 did not soften it. What the new Act did change is who is allowed to hold the money, how long a broker may sit on it, and what the audit has to prove afterwards. That turns premium collection from a legal talking point into a follow-up discipline.
The Nigerian Insurance Industry Reform Act, 2025 was signed into law on 6 August 2025 and replaced the Insurance Act 2003 as the industry's principal statute. It keeps the rule that an insurer does not assume a risk until the premium has been received, and it goes further on distribution: agents may no longer collect premium, so the money reaches the insurer either directly from the client or through a licensed broker.
For brokers, three obligations sit together, and they are worth reading in the Act itself rather than in anybody's summary:
Add the identification requirements — Bank Verification Number and National Identification Number for individuals, Corporate Affairs Commission documents for companies — and the direction of travel is clear. The Act expects a brokerage to know exactly whose money it is holding, since when, and against which risk. The country page on insurance broking in Nigeria sets out the wider supervisory frame, and our note on NAICOM and the NDPA on WhatsApp covers the data side of the same conversations.
Almost no premium is lost because a client refused to pay. It is lost in ordinary gaps in the process, and the same five keep recurring:
Each of those ends the same way: the client believes there is cover, the insurer's position is that there is not, and the brokerage is in the middle holding a WhatsApp thread that says "noted sir". That thread is evidence either way, so it may as well be evidence of a process you would defend.
For a renewal, where the date is known months in advance, the sequence that works is short and dated. Adjust the numbers to your book; the point is that every step names the amount, the risk and the date on which cover would stop.
New business runs the other way round: nothing is confirmed until the money is in, so the sequence is a same-day debit note, a reminder the next morning, and a call on day three. Our premium reminder workflow sets out the cadence, and the overdue premium template shows a tone that gets answered without souring the relationship. Where a reminder leaves the twenty-four-hour window it has to go as an approved utility template, so the payment route and the standing line about your account details belong inside the template rather than in whatever the sender types.
| Include | Leave out |
|---|---|
| The policy reference, the premium and the due date | Bank details typed fresh into a chat message |
| The payment route already on the debit note | Any account that differs from the one you invoiced |
| The date cover starts or ends, stated plainly | "You are covered, just settle it this week" |
| A standing line that your account details never change | Manufactured urgency, or a consequence the policy does not carry |
| The name of the representative handling the file | Requests for a one-time passcode, card number or BVN in the thread |
The middle row deserves the most attention. A broker who writes "you are covered" before the premium is received has created an expectation the Act does not support, and the message will be read back word for word if a claim follows.
Two records have to agree. The money trail is the clients' account: date of receipt, client, policy, date of remittance to the insurer, remittance advice on file. The message trail is what the client was told and when — the debit note, the reminders, the confirmation, and any variation the client asked for. When those two live in different places, kept by different people, the reconciliation only happens once a year, in front of the auditor whose report to NAICOM has to confirm that collected premiums were remitted.
The Act also recognises cover notes and certificates issued in electronic form, which means the confirmation can go back down the same thread the client is already using instead of waiting for a hard copy. That is worth setting up deliberately. In ORIS the reminder, the client's reply and the confirmation sit against the customer record in a shared inbox, so a colleague can pick the file up when the usual representative is with a client, and the history stays with the brokerage rather than on a personal phone. ORIS does not take payments and cannot tell you that money has landed — that reconciliation belongs to your accounts system, and the reminder should point at the route that system expects. What it removes is the guessing about what was promised and when. Other follow-up sequences are collected under follow-ups and reminders.
No. The statutory position is that the insurer does not assume the risk until the premium has been received, and NIIRA 2025 restates it. A broker who tells a client otherwise is creating a liability for the brokerage rather than cover for the client, and the message saying so becomes part of the file.
The Act fixes a remittance window — widely summarised as twenty working days or thirty calendar days, whichever is later, from receipt or from inception — with interest above the Central Bank of Nigeria's minimum rediscount rate and a monetary penalty for late remittance. Read the section that applies to your licence in the Act text before you rewrite your process.
NIIRA 2025 removed premium collection from agents; the money goes to the insurer directly or through a licensed broker. If your distribution relies on agents banking cash for you, that arrangement needs redesigning rather than documenting.
It is good evidence if it is kept at brokerage level, attributable to a named representative and retrievable years later. A screenshot on a departed staff member's phone is not. Store the thread where the file lives, alongside the debit note and the remittance advice.
Electronic cover notes and certificates are recognised, so sending the document in the thread is workable provided the client has opted in and the document is the one the insurer issued. Keep the sent file against the customer record so the version delivered is the version you can produce later.
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