The National Insurance Commission, NAICOM, has issued a directive mandating individual customers of insurance companies to link their National Identification Number, NIN, to their insurance policies by April 2026.
NAICOM also directed corporate clients to provide Certificate of Incorporation documents before the deadline.
The directive was contained in a circular with the number NAICOM/TD/MCCB/CIR/73/2025, titled “Mandatory Submission of National Identification Number and Certificate of Incorporation as Material Information for all Insurance Contracts, Including Group Life Cover,” addressed to all managing directors/CEOs of insurance companies and brokers.
The circular stated: “In line with Section 64(4) of the Nigerian Insurance Industry Reform Act (NIIRA) 2025 and in exercise of the powers conferred on the Commission by the NAICOM Act 1997, the Commission hereby issues the following directive as part of efforts to strengthen transparency and facilitate the Nigerian insurance industry’s compliance with Know Your Customer (KYC) requirements:
“An insurance underwriter and broker shall neither provide nor incept any insurance cover without having obtained the NIN of the individual client and CAC documents of the corporate client.
“An insurance underwriter and broker shall obtain the National Identification Number (NIN) from individual clients and CAC documents from corporate clients before acceptance and inception of any risk. The CAC documents referred to under this circular include the Certificate of Incorporation, Particulars of Directors and Share Allotment (Status update) of the intending entity.
“All proposal forms shall clearly restate the requirement for NIN from individuals and CAC documents from corporate entities, which shall be obtained before cover inception. For group life policies, underwriters or brokers shall obtain a schedule listing the employees’
name, dates of birth and NINs prior to commencement of cover.
“Insurance underwriters are required to reject ab initio any risk offered without submission of NIN or CAC documents.
“For policies already issued prior to this directive that are still active but lacked the required NIN or CAC documents, the insurance underwriter shall, directly or through the insurance intermediaries, engage the policyholders to obtain same and link the information to the respective customer’s records on or before 30th April 2026.
“Insurance underwriters are also mandated to collaborate with insurance brokers and agents to intensify customer awareness campaigns, emphasising the importance of compliance with this directive.
“The Commission will monitor this circular and take appropriate regulatory action to ensure strict compliance.
An insurance underwriter that fails to obtain an intermediary that fails to provide the NIN or CAC documents shall be sanctioned by the Commission. This circular supersedes the earlier circular referenced NAICOM/TD/MCCB/CIR/58/2025 on this subject matter.”
