Are you trying to obtain an oil and gas permit in Nigeria but unsure whether to apply through NUPRC or NMDPRA?
You are not alone. Many contractors, suppliers and service companies entering Nigeria’s oil and gas industry need to understand which regulatory authority is responsible for their proposed activities and which permit applies to their business.
The Nigerian Upstream Petroleum Regulatory Commission (NUPRC) regulates the upstream petroleum sector, while the Nigerian Midstream and Downstream Petroleum Regulatory Authority (NMDPRA) regulates the midstream and downstream sectors. Both authorities operate service-permit systems for companies providing covered services to the petroleum industry.
NUPRC administers the Oil and Gas Industry Service Permit (OGISP). NMDPRA administers the Midstream and Downstream Oil and Gas Industry Service Permit (MDOGISP). Although these permits serve a similar broad purpose, they fall under different regulatory authorities and apply to different segments of the industry.
Choosing the correct permit is important. Applying through the wrong regulatory channel or selecting a service category that does not match your intended activities can create avoidable delays and compliance issues.
In this guide, we explain the difference between NUPRC and NMDPRA permits, the types of businesses that should consider each one, the main documentation requirements and how to determine the appropriate application route. We also explain why an industry service permit should not be confused with a separate licence required to operate a regulated petroleum facility or undertake a specific petroleum activity.
NUPRC vs NMDPRA: What Is the Difference Between the Two Permits?
The main difference between NUPRC and NMDPRA permits is the regulatory authority responsible for the relevant petroleum activity and the segment of the industry in which the service is provided.
NUPRC regulates the upstream petroleum sector, while NMDPRA regulates the midstream and downstream sectors under Nigeria’s petroleum regulatory framework. Each authority operates its own service-permit portal and publishes requirements applicable to its permit system.
Key differences at a glance
| Feature | NUPRC OGISP | NMDPRA MDOGISP |
|---|---|---|
| Regulatory authority | Nigerian Upstream Petroleum Regulatory Commission | Nigerian Midstream and Downstream Petroleum Regulatory Authority |
| Primary regulatory focus | Upstream petroleum activities | Midstream and downstream petroleum activities |
| Service permit | Oil and Gas Industry Service Permit (OGISP) | Midstream and Downstream Oil and Gas Industry Service Permit (MDOGISP) |
| Official application portal | ogisp.nuprc.gov.ng | mdogisp.nmdpra.gov.ng |
| Application requirements | Depend on the selected category and service specification | Depend on the selected category and service specification |
The two service-permit systems have similar category names and online application processes. However, this does not mean the permits are interchangeable. The applicable authority depends on the service and the petroleum activity to which it relates.
1. NUPRC OGISP: When is it relevant?
The NUPRC Oil and Gas Industry Service Permit is relevant to companies providing services covered by the Commission’s permit framework to licensees and lessees in the upstream petroleum industry. Examples of service areas listed in NUPRC’s guidelines include:
- rehabilitation, upgrade and fabrication works;
- equipment and material supply;
- domestic waterborehole;
- protocol and logistics;
- laboratory;
- onshore waste management;
- survey;
- integrity test;
- haulage;
- medical and pharmaceutical;
- hospitality;
- aviation support services;
- calibration services;
- offshore pipeline laying;
- major construction services;
- drilling and production services;
- exploration;
- technical consultancy;
- special transportation services;
- dredging services;
- waste management services;
- underwater inspection and services;
- hospital and medical services;
- heavy duty equipment supply, installation and maintenance services;
- communication services;
- international freight, clearing and forwarding;
- insurance; and
- automobile services, among others.
These examples are not an exhaustive list. A company should consult the current OGISP service specifications to determine whether its proposed activities fall within the framework.
Practical example: A company seeking to provide a covered aviation support service to an upstream petroleum operator should assess the applicable NUPRC OGISP requirements before applying.
2. NMDPRA MDOGISP: When is it relevant?
The NMDPRA Midstream and Downstream Oil and Gas Industry Service Permit is relevant to covered services provided within the midstream and downstream petroleum industry.
The midstream sector includes activities such as petroleum transportation, storage and processing infrastructure. The downstream sector includes activities involving the refining, distribution and marketing of petroleum products and natural gas. A business intending to provide covered services to operators in these segments should review the MDOGISP categories and service specifications.
Practical example: A contractor intending to provide a covered waste management service to a downstream petroleum business should assess the relevant MDOGISP requirements. The precise category will depend on the service being offered.
3. What if your company provides services across both sectors?
A company may provide different services to clients operating in different parts of the petroleum industry. In that situation, it should not assume that obtaining one service permit automatically satisfies the requirements applicable to every client or activity. The company should:
- Identify the services it intends to provide.
- Determine whether those services relate to upstream, midstream or downstream activities.
- Compare each service with the relevant authority’s published permit specifications.
- Confirm the applicable category and supporting documents with the relevant authority where the position is unclear.
The appropriate regulatory route should be determined by the actual activity and applicable requirements, rather than by the company’s name, general industry description or the permit held by another contractor.
Is an NUPRC or NMDPRA Service Permit Enough to Operate a Petroleum Facility?
No. An industry service permit should not automatically be treated as authorization to establish or operate a regulated petroleum facility.
For example, a company intending to operate a petrol station, LPG facility, petroleum depot or another regulated installation may need a separate licence or approval under the applicable NMDPRA framework. NMDPRA maintains separate systems for several facility and activity-specific approvals. Similarly, obtaining an OGISP does not, by itself, establish that a company has every separate approval required for a regulated upstream operation.
Before commencing an activity, distinguish between:
- An industry service permit: for a company providing services covered by the relevant service-permit framework.
- A facility licence: for establishing or operating a facility where a separate licence is required.
- An activity-specific approval: for a particular regulated operation, service or technical activity that requires additional authorization.
This distinction is important for companies expanding into new petroleum services, bidding for contracts or planning to operate their own facilities.
NUPRC and NMDPRA Permit Requirements: Documents Your Company Should Prepare
The documentation required for an OGISP or MDOGISP application depends on the selected category and service specification. Both official portals identify corporate registration documents, tax documentation and equipment information among the key application materials. Before beginning an application, prepare the following checklist.
| Document or requirement | What to check |
|---|---|
| Certificate of Incorporation | Confirm the company is properly registered and the document is legible. |
| Status Report | Prepare the applicable CAC forms and other documents required for the selected application. |
| Memorandum and Articles of Association | Check the applicable requirements for your company type and permit category. |
| Tax Clearance Certificate | Confirm that the required tax documentation is available and current. |
| Audited account | Prepare an audited account. |
| Proficiency documents | Obtain applicable professional registrations, certifications or accreditations where required. |
| Additional category-specific documents | Check the relevant authority’s current checklist for your selected service. |
How to Apply for an NUPRC or NMDPRA Service Permit
Both authorities process service-permit applications through their respective online portals. The general process is similar, but applicants must use the correct portal and follow the requirements applicable to their chosen category.
Step 1: Identify the relevant authority and category
Determine whether your proposed services fall within NUPRC’s upstream framework or NMDPRA’s midstream and downstream framework. Then identify the appropriate category and job specification. Do this before paying any application fee.
Step 2: Create a company account
Register through the appropriate official portal and verify your email address.
- NUPRC: ogisp.nuprc.gov.ng
- NMDPRA: mdogisp.nmdpra.gov.ng
Step 3: Complete the application
Log in to the company dashboard and select Apply Now. Choose the relevant permit category, services and job specifications, then complete the required fields. Both portals allow applicants to work on draft applications before final submission. Review each section and resolve any incomplete fields.
Step 4: Pay the applicable fee
Confirm the amount displayed for the selected category on the relevant official portal. Keep the payment confirmation and reference details.
Step 5: Upload supporting documents and submit
Upload the documents required for your category and service. The portals specify PDF documents and JPEG images as accepted formats, with a maximum file size of 4 MB per upload. Confirm the current technical instructions before submitting.
Step 6: Monitor the application
Use the company dashboard to monitor the application status and respond to any requests for corrections or additional information.
Step 7: Download and verify the permit
Once approved, download the permit through the relevant portal. Keep a copy of the permit and record its expiry date. Both authorities’ service permits are valid for one year and should be renewed annually from the approval date.
NUPRC vs NMDPRA Permit Fees and Validity
The application fees differ by authority and category. A permit’s fee should not be the only factor in choosing an application route. Applying to the wrong authority or selecting an unsuitable category may create additional work and delays.
Frequently Asked Questions About NUPRC and NMDPRA Permits in Nigeria
What is the difference between NUPRC and NMDPRA permits?
NUPRC administers the Oil and Gas Industry Service Permit (OGISP) for services covered by its upstream petroleum regulatory framework. NMDPRA administers the Midstream and Downstream Oil and Gas Industry Service Permit (MDOGISP) for services covered by its midstream and downstream framework. The correct permit depends on the services your company intends to provide and the applicable regulatory requirements.
Can I use an NUPRC permit to work for an NMDPRA-regulated company?
You should not assume that an NUPRC permit satisfies the requirements applicable to services under NMDPRA’s jurisdiction, or vice versa. Confirm the permit requirements for the specific service and client before accepting the contract.
Do all oil and gas contractors in Nigeria need an OGISP or MDOGISP permit?
Companies providing services covered by the relevant service-permit framework are expected to obtain the applicable permit. However, the precise requirement depends on the company’s activities and the regulatory framework governing the service. A service permit is also different from a licence required to operate a regulated petroleum facility.
How long does it take to obtain an OGISP or MDOGISP permit?
Both OGISP and MDOGISP applications have a processing period of up to 72 hours (three working days) after payment confirmation.
How long is an NUPRC or NMDPRA service permit valid?
Both OGISP and MDOGISP permits are valid for one year and should be renewed annually from the approval date. Permit holders should check the expiry date on their individual permits and begin the renewal process in good time.
Can a company apply for more than one permit category?
Yes. A company can apply for multiple permits. Whether multiple categories are appropriate depends on the services the company intends to provide and the applicable requirements.
Can I apply for an NUPRC or NMDPRA permit without all the required documents?
Applicants should prepare the documents required for their selected category before submitting, and the relevant documentation must be provided. Incomplete applications may require corrections or further action before processing can be completed.
What should I do if my service-permit application is rejected?
Review the reason for rejection and identify the missing information, incorrect category or deficient document. The portal provides a process for uploading corrected documents and resubmitting a rejected application. Follow the instructions on the relevant portal and address the stated issues before resubmission.
Is an NUPRC or NMDPRA service permit enough to operate a petrol station, LPG plant or petroleum depot?
No. An industry service permit is not a licence to establish or operate a regulated petroleum facility. Businesses intending to operate petrol stations, LPG facilities, depots or other regulated installations should identify the separate licence or approval applicable to that activity.
Common Mistakes to Avoid When Applying for NUPRC or NMDPRA Permits
Oil and gas contractors can reduce avoidable application problems by addressing these issues before submission.
- Choosing the wrong regulatory authority: A company may assume that a permit issued by one authority will cover services under the other authority’s jurisdiction. Confirm the applicable regulatory framework for the proposed service.
- Selecting a category based only on cost: The lowest fee is not necessarily the correct option. Match the service to the category and job specification listed by the relevant authority.
- Submitting incomplete or inconsistent documents: Ensure the company information in the application matches the supporting corporate documents. Check that every required document is legible and complete.
- Overlooking proficiency requirements: Some services require additional professional registrations, certifications, accreditation or evidence of technical capacity. Check these requirements before applying.
- Using incorrect company information: The portals indicate that certain details, including the company name, registration number and Tax Identification Number, cannot simply be edited through the company profile. Changes may require a formal request to the relevant support team.
- Assuming payment means approval: Payment is one step in the application process. Applicants must still meet the applicable documentation and assessment requirements.
How B. E Legal Services Can Assist
Choosing between NUPRC and NMDPRA is an important first step, but the process does not end with identifying the correct portal. Your company must also select the appropriate service category and prepare the relevant corporate and supporting documents.
B. E Legal Services assists businesses with regulatory compliance and oil and gas permit applications, including:
- assessing the appropriate NUPRC or NMDPRA application route;
- identifying the relevant permit category and service specification;
- reviewing corporate and supporting documentation;
- assisting with application preparation and submission; and
- following up on applications and addressing documentation issues.
If your company intends to provide services to oil and gas operators, marketers, depot owners or other industry participants, contact B. E Legal Services to discuss your proposed activities and the applicable permit requirements.
Prepare your company for oil and gas contracts with the right regulatory documentation in place.
This article is published for general informational and educational purposes only and does not constitute legal advice. Regulatory requirements, application procedures, fees and documentation may change from time to time. The applicable requirements depend on the nature of the services or activities involved and the relevant regulatory authority. Readers should consult the applicable official guidelines or obtain professional advice before taking action. B. E Legal Services does not guarantee the approval of any permit or regulatory application.