What the 2022 Act changed

The National Health Insurance Authority Act 2022 replaced the scheme set up in 1999 with a national authority, the NHIA. Commentary from an accounting firm and a health policy publication describes the Act as making health insurance mandatory for every Nigerian and legal resident, reaching public and private employers and their staff, informal-sector workers and other residents.

The same commentary describes a duty on employers to provide health insurance once they reach a small headcount, though the exact headcount that triggers it is not clearly settled. Consumer guidance adds that enforcement against private employers is uneven and depends on each state’s scheme, so the paper rule and day-to-day practice do not always match.

State schemes and the federal programme

Cover runs through two channels: the NHIA’s own programme for federal employees, and state health insurance schemes, which the NHIA regulates and brings into one framework. Each state runs its own scheme, so access to care and the choice of facilities differ from one state to the next.

A federal fund pays for a basic minimum package of care delivered with the states. A separate vulnerable group fund subsidises cover for vulnerable and indigent people, and commentary on the Act notes that anyone who already has private cover is not eligible for that subsidy.

HMOs: how employers usually buy cover

Employees usually join through their employer, which registers staff and chooses an accredited health maintenance organisation (HMO). Consumer and policy guides describe most employer health cover in Nigeria as bought this way. An HMO manages access to a network of hospitals and clinics.

Under the 2022 Act, HMOs are treated as one type of third-party administrator. Policy commentary says they must register with the NHIA and pay a security deposit, and they no longer manage pooled state-scheme funds.

Private HMO plans are often weighed against the NHIA scheme on choice of hospital, speed of access and extras. Take current contribution rates from the HMO or the EOR before you budget.

Group life is a separate duty, not health cover

Nigeria’s pension law requires every employer to keep a group life insurance policy for all employees, worth at least three times each employee’s annual total emolument. The pension regulator also asks employers to display the policy certificate at their premises. This is life cover, and it does not pay for medical treatment.

Employers also make pension contributions and pay into the employees’ compensation fund run by the national social insurance trust fund. Guidance on employer duties says meeting the pension, group life and compensation obligations does not satisfy the separate health insurance mandate under the NHIA Act, so budget for each on its own.

International plans and local insurance rules

Because the NHIA Act makes health insurance mandatory for residents, an international plan is best treated as a top-up to locally compliant cover. Whether a private or international plan on its own would satisfy the mandate is not settled, and it is a legal question, so check with a local adviser in Nigeria before relying on one.

Insurance in Nigeria is regulated by the National Insurance Commission under the Nigerian Insurance Industry Reform Act 2025, signed in August 2025, which replaced the Insurance Act 2003. Legal commentary on the 2025 Act describes a ban on insuring Nigerian-based assets or interests with a foreign insurer unless an exemption applies. How far that reaches personal health cover is not settled, which is one reason cover there is usually arranged through a locally licensed insurer or an NHIA-registered HMO. Whether a given international insurer can add cover is for that insurer to confirm.

For the general picture, see the overview of international health insurance for remote employees and the Middle East and Africa region page.

Employer of record or contractor

EOR providers describe an employer of record as the usual way a US company without a Nigerian entity employs someone there. In that setup the EOR is the legal employer and handles pension, the compensation fund, group life and health cover, so find out which HMO plan it uses before adding anything.

A genuine independent contractor is not enrolled by the client and arranges their own health cover. Our guide to health coverage for EOR employees and contractors abroad explains how the two arrangements differ, and insurance changes for remote teams covers the US-side lines we request from insurers, such as employment practices liability, with the insurer deciding terms.

Getting an introduction for a Nigerian hire

Mithril1 does not sell or recommend health plans. Use the quote form on this page to tell us the state each person lives in, how many people are on the team, whether they work through an EOR or your own entity, whether they already have HMO cover, and which family members you want included. We will pass the details to a benefits partner that handles international and remote-team health coverage; the partner and the insurer decide eligibility, plans and pricing.

Nearby pages cover South Africa and Egypt, and the employee benefits hub lists every guide in the section.

A few useful answers

Common questions

Is health insurance mandatory in Nigeria?

Commentary on the NHIA Act 2022 describes health insurance as mandatory for every Nigerian and legal resident, including employees, though enforcement on private employers is uneven and varies by state.

Who runs health insurance in each Nigerian state?

Each state runs its own state health insurance scheme, which the NHIA regulates, while the NHIA runs its own programme for federal employees.

What does an HMO do in Nigeria?

A health maintenance organisation manages employees’ access to a network of hospitals and clinics. Under the 2022 Act it must register with the NHIA and pay a security deposit.

Does the group life policy count as a health benefit?

No. The group life policy required under Nigeria’s pension law is life cover. It does not meet the separate health insurance mandate.

Can an international plan replace local cover in Nigeria?

It is best treated as a top-up. Whether an international plan on its own satisfies the mandate is not settled, and the insurer has to confirm what it can provide.

International Health Insurance for Remote Employees in Nigeria