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A committee including the Ministry of Justice, NEPZA, OGFZA, Customs and the Nigeria Revenue Service is drafting new legislative and regulatory instruments for special economic zones, including a proposed 75/25 export-to-domestic sales framework.
The Federal Government is drafting revised legislation and regulations for Nigeria’s special economic zones to stop goods imported under free zone concessions from being diverted into the domestic market, The Guardian reported on 27 September 2026. Minister of Industry, Trade and Investment Dr Jumoke Oduwole disclosed the plans at a drafting retreat held after stakeholder consultations on 17 September.
Who is drafting
According to the report, the work is being done by a Special Economic Zones Legislative and Regulatory Reform Committee. Its members include the Federal Ministry of Justice, the Federal Ministry of Industry, Trade and Investment, the Nigeria Export Processing Zones Authority (NEPZA), the Oil and Gas Free Zones Authority (OGFZA), the Nigeria Customs Service and the Nigeria Revenue Service.
Oduwole framed the problem directly: “A Free Zone cannot become an alternative route into the Nigerian domestic market on terms unavailable to manufacturers.”
What is on the table
The Guardian reported that the reform areas include a proposed 75/25 framework for export and domestic sales, customs coordination procedures, an expansion of digital free zones with new licence categories, a “one authority, one visit, one record” principle to reduce regulatory friction, and transition arrangements for existing investments. The minister said legitimate incentives, including duty-free importation of capital goods and tax exemptions on export profits, would remain. The text of the draft instruments has not been published.
Why it matters
Free zone status is often a central assumption in the business case for manufacturing, logistics and energy projects in Nigeria, and the ability to sell into the customs territory is a large part of that value. A formal cap on domestic sales, combined with tighter customs coordination between zone authorities and the Customs Service, would change the economics for enterprises that rely on the local market. Investors should review their operating licences, zone agreements and financial models against a 75/25 split, and identify which products and revenue streams would fall on each side of the line.
The transition arrangements will be the main issue for existing licensees and their lenders. Counsel will want to know whether current enterprises keep their terms for a fixed period, whether the new rules apply to licence renewals, and how disputes over classification of sales will be resolved. Where investments were made on the strength of statutory incentives, questions about legitimate expectations and, for foreign investors, treaty protection may arise if the change is abrupt.
Manufacturers operating outside the zones, whose position the minister cited, are likely to press for strict enforcement. The involvement of OGFZA as well as NEPZA also means oil and gas service companies in OGFZA zones should follow the drafting closely, alongside general free zone enterprises. Businesses that want to shape the final text should engage with the committee before the instruments go to the National Assembly or are issued as regulations.
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