In the twilight of 2019, the Department of Petroleum Resources (“DPR”) issued the Guidelines for the Release of Staff in the Nigerian Oil and Gas Industry, 2019 (“2019 Guidelines”) to replace similar Guidelines issued in 2015 (“2015 Guidelines”).

The 2019 Guidelines, just like the 2015 Guidelines, require employers in the oil and gas industry to obtain prior approval from the Minister of Petroleum Resources (“Minister”) through the DPR before they can disengage any Nigerian employee. Before the 2019 Guidelines could gain traction, the Nigerian economy and indeed the global economy was hit by the COVID-19 pandemic.