.New tax-remission regime replaces project-by-project negotiations, opens path for stalled offshore developments
President Bola Ahmed Tinubu has approved a landmark investment framework designed to unlock up to $50 billion in new deep offshore oil and gas investments, in a major policy move aimed at reviving large-scale projects that have remained stalled for years.
The new framework replaces the previous approach of negotiating incentives on a project-by-project basis with a transparent, rules-based investment architecture intended to provide greater certainty for investors and strengthen Nigeria’s competitiveness for globally mobile capital.
The reform, which takes effect through the Deep Offshore Oil and Gas Projects Incentives (Tax Remission) Order, 2026, is expected to facilitate the development of a new generation of capital-intensive offshore projects, beginning with the approximately US$10 billion Bonga South West project.
The Presidency said the framework is designed to create a durable investment environment that will support long-term offshore developments while safeguarding Nigeria’s national economic interests.
The development follows President Tinubu’s engagement with the Chief Executive Officer of Shell plc, Wael Sawan, during which the President directed the development of measures to unlock the next wave of investments in Nigeria’s deep offshore sector.
Rather than limiting the response to individual projects, the Federal Government subsequently developed a broader framework applicable to multiple categories of qualifying deep offshore developments.
Under the new arrangement, NNPC Limited, as the Federal Government’s nominated counterparty under the relevant Production Sharing Contracts (PSCs), is authorised to proceed with the necessary amendments to eligible PSCs required to implement the investment framework.
Boost for Nigerian Content
A major component of the reform is its focus on strengthening domestic industrial capacity and ensuring that increased offshore investment translates into wider economic benefits for Nigeria.
According to the President’s Special Adviser on Energy, Olu Verheijen, qualifying projects will be required to maximise project execution within Nigeria wherever commercially and technically feasible.
“Projects qualifying under the framework will maximise execution within Nigeria wherever commercially and technically feasible, strengthening domestic engineering, fabrication, marine logistics, technical services and project management,” she said.
She added that the objective extends beyond increasing investment and crude oil production.
“The objective is not only to increase investment and production, but also to create skilled jobs, deepen local supply chains and position Nigeria as Africa’s regional hub for deep offshore project execution,” Verheijen said.
The framework was developed following an extensive inter-agency process involving the Presidency, fiscal and legal institutions, commercial and regulatory agencies, as well as operators and other stakeholders across the oil and gas industry.
The Presidency said the process brought together relevant expertise to develop an investment architecture capable of providing greater certainty to investors while ensuring that Nigeria continues to derive sustainable value from its hydrocarbon resources.
President Tinubu commended the Federal Ministry of Justice, Federal Ministry of Finance, Federal Ministry of Petroleum Resources, Nigeria Revenue Service, NNPC Limited, Nigerian Upstream Petroleum Regulatory Commission (NUPRC), Nigerian Content Development and Monitoring Board (NCDMB) and other industry stakeholders for their contributions to the reform.
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Tinubu: Certainty will attract long-term capital
President Tinubu said the reform was part of his administration’s broader effort to create an investment environment capable of attracting long-term capital into Nigeria’s energy sector.
“The countries that attract long-term investment are not necessarily those with the greatest natural resources. They are the ones that provide the greatest certainty,” the President said.
He added that the new framework demonstrates the Federal Government’s commitment to building an investment climate based on predictable rules, strong institutions and sustainable partnerships.
“This reform reflects our determination to build an investment environment defined by clear rules, strong institutions and enduring partnerships.
“We are creating the conditions for capital to flow, for Nigerian businesses to grow, for our people to prosper and for our natural resources to deliver lasting national value,” he said.
The Federal Government expects the new framework to improve the investment case for Nigeria’s deep offshore assets, accelerate the development of stranded and delayed projects, boost oil and gas production and generate additional opportunities for Nigerian companies across engineering, fabrication, marine services, logistics and other segments of the oil and gas value chain.
For an industry facing intense competition for international upstream capital, the reform represents a significant attempt to reposition Nigeria’s deep offshore sector as a more predictable and commercially attractive investment destination.
