Nigeria
National minimum wage renegotiation – labour law update
Impact date: 1 May 2026 (announcement); July 2026 (negotiations commence)
At the 2026 May Day celebration in Abuja (1 May 2026), the Nigeria Labour Congress (NLC) and the Trade Union Congress (TUC) jointly announced that formal renegotiation of the National Minimum Wage will commence in July 2026. The NLC President, Mr Joe Ajaero, confirmed that renegotiation was being initiated early to prevent the delays experienced during the 2024 wage cycle. The NLC and the Joint National Public Service Negotiating Council (JNPSNC) have formally demanded a new minimum wage of ₦154,000 per month — a 120% increase from the current ₦70,000 floor set by the National Minimum Wage (Amendment) Act 2024.
The NLC also demanded that all workers receive 100% of their basic salaries from July 2026 pending the conclusion of negotiations. The TUC President called for strengthened social dialogue platforms and reforms to labour administration to ensure fairer industrial relations. The statutory review cycle under the 2024 Act is three years (next due in 2027), but organized labour is seeking an early review citing persistent inflation above 30%, naira depreciation, and the sharp erosion of real purchasing power since the ₦70,000 rate was agreed.
Employer implications/action needed Employers should immediately begin financial modelling for the potential impact of a substantially higher minimum wage, including scenarios of 50%, 100%, and 120% increases from the current ₦70,000 floor. Budget and workforce planning teams should assess the cascading effect on higher pay bands, as minimum wage increases typically trigger consequential adjustments across salary structures. Employers should also review current collective bargaining agreements and ensure compliance with the existing ₦70,000 minimum (and applicable state-level minimums, e.g. Lagos ₦85,000, Imo ₦104,000) while negotiations are ongoing. HR teams should monitor NLC communications closely for any planned industrial action ahead of or during negotiations.
Employer risk The primary risk is a significant and unbudgeted increase in payroll costs if the ₦154,000 demand is agreed in full or in substantial part. There is also a secondary risk of industrial action, work stoppages, or strikes if negotiations stall, given the NLC’s history of coordinated action in wage disputes. Employers operating in Nigeria should have business continuity plans in place for potential disruptions. Additionally, any failure to comply with the current ₦70,000 minimum wage pending the outcome of negotiations remains an independent statutory violation attracting regulatory penalties.
Link N/A
General Application and Implementation Directive
Impact date: 30 May 2026
During this period, the Nigeria Data Protection Commission (NDPC) extended the deadline for filing the 2025 Compliance Audit Returns (CAR) for Data Controllers and Data Processors of Major Importance (DCPMIs) from 31 March 2026 to 30 May 2026 under the Nigeria Data Protection Act 2023 and the General Application and Implementation Directive (GAID).
Employer implications/action needed Employers classified as DCPMIs should ensure completion of data protection compliance audits, Data Privacy Impact Assessments (DPIAs), employee data processing reviews, and filing of Compliance Audit Returns through licensed Data Protection Compliance Organisations (DPCOs). Employers should also ensure that employee monitoring and cross-border data transfers comply with the NDPA and GAID requirements.
Employer risk Failure to comply with the filing obligations or broader NDPA requirements may expose employers to administrative penalties, regulatory investigations, reputational damage, restrictions relating to international data transfers, and possible listing as non-compliant entities by the NDPC.
Link N/A
Contacts
© Eversheds Sutherland. All rights reserved. Eversheds Sutherland is a global provider of legal and other services operating through various separate and distinct legal entities. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.