On 22 September 2026, TEMPLARS attended the stakeholder consultation convened by the Nigerian Midstream and Downstream Petroleum Regulatory Authority (NMDPRA) on the Draft Midstream and Downstream Petroleum Prevention of Anti-Competitive Practices and Behaviour Regulations, 2026. If adopted, the Draft Regulations would give the sector its first standalone competition framework. Competition risk could therefore translate into broader regulatory and commercial exposure for licensees.
The Draft Regulations are made further to the Petroleum Industry Act, 2021 and published for comment on 6 August. They go well beyond cartels to cover abuse of dominance, third-party access to pipelines, storage and jetties, affiliate dealings, exclusive and take-or-pay arrangements, prior approval of transactions and joint ventures, and algorithmic pricing.
Licensees would need to keep compliance programmes in place and hold records for ten years. Penalties would extend to licence suspension or revocation, and NMDPRA will coordinate enforcement with the Federal Competition and Consumer Protection Commission (FCCPC) under a Memorandum of Understanding signed on 10 September 2026.
This client alert highlights what the Draft Regulations mean for licensees, infrastructure operators and investors ahead of finalization.
For guidance, contact TEMPLARS Partner, Dayo Okusami, Managing Counsel, Inna Ali and Associate, Nabila Gaduya.