Renaissance Capital warns that recent capital requirement increases for Nigeria’s Pension Fund Administrators and Custodians could impede industry growth, prompting calls for a more risk-focused approach amid ongoing consolidation efforts.

Renaissance Capital Africa has raised concerns over the recent directive from the National Pension Commission (PenCon) to increase the minimum capital requirements for Nigeria’s Pension Fund Administrators (PFAs) and Pension Fund Custodians (PFCs). While the policy aims to bolster the sector’s financial stability, operational resilience, and long-term sustainability, the firm warns that it might unintentionally hinder growth among PFAs by setting capital thresholds that do not fully align with their actual risk profiles.

On 26 September 2025, PenCon revised its capital framework, mandating that PFAs managing assets below N500 billion maintain a minimum capital of N20 billion. For PFAs with assets exceeding N500 billion, the requirement is now N20 billion plus 1% of the amount above N500 billion. PFCs are now required to hold N25 billion plus 0.1% of Assets Under Custody (AUC). These updated rules, which are based on Sections 60(1)(b), 62(b), and 115(1) of the Pension Reform Act (PRA) 2014, are intended to bring Nigeria’s pension regulatory standards more in line with international best practices. They take effect immediately for new licenses, while existing operators are given until 31 December 2026 to comply.

Renaissance Capital acknowledges the rationale behind this move, especially given that the AUM of the pension industry has grown significantly—advancing at a compound annual rate of approximately 16% since the 2021 recapitalization that raised PFAs' capital from N2 billion to N5 billion. Much of this expansion stems from strong investment performance and the devaluation of the Naira in 2023 and 2024, which increased asset valuations. Additionally, recent regulatory changes allowing PFAs to diversify into higher-risk investments—such as securities lending, repos, infrastructure, and private equity—have amplified operational and counterparty risks. Consequently, higher capital buffers are seen as necessary safeguards to mitigate these risks.

However, Renaissance Capital cautions that the structure of the new requirements—particularly the tiered approach based on asset size—may not accurately reflect the operational risk profiles of large PFAs. Since these firms typically earn a flat 1% fee on AUM and do not directly bear market risk, forcing them to allocate profits into capital reserves could be inefficient. Moreover, the exclusion of statutory reserves from qualifying capital might encourage profit retention rather than capitalization, leading to potential over-capitalization.

The firm advocates for a fixed capital requirement model that emphasizes operational risk exposure rather than size-based tiers. They warn that the current tiering incentivizes smaller or larger PFAs alike to limit growth and could distort competitive dynamics within the industry.

The anticipated outcome of these new thresholds includes considerable industry consolidation. Renaissance estimates that PFAs will need approximately N275.7 billion additional capital to meet the new standards, with larger firms primarily leveraging group resources to comply. Smaller PFAs are likely to face difficulties, potentially accelerating mergers and acquisitions—a pattern already observed in the 2021 recapitalization cycle, which saw firms like Tangerine Pensions expand through acquisitions and GTBank entering the market by taking over Investment One Pension Managers. Currently, the number of PFAs has decreased from 22 to around 17, following Leadway Pensure's acquisition of PAL Pensions. Going forward, further consolidation could solidify a “Big Five” dominance by firms such as Stanbic IBTC, Access ARM, Leadway-PAL, Premium, and NPF Pensions.

For PFCs, the shortfall resulting from the new capital requirements is projected at approximately N28.9 billion. Major players such as First Pension Custodian, Zenith Pensions Custodian, and UBA Pensions Custodian will need to raise N6.4 billion, N8.2 billion, and N14.3 billion respectively. Their affiliations with large banking groups are expected to facilitate these capital increases. Nonetheless, these reforms may influence dividend payout strategies, especially among entities within tier-one banking groups, prompting a focus on profit retention to meet the new capital standards. While group-level dividends might remain relatively unaffected, internal capital allocations are likely to be adjusted in the short term.

In sum, PenCon’s push for increased capital adequacy is a vital step toward safeguarding contributor assets and enhancing industry resilience. Nonetheless, striking the right balance between sufficient capital buffers and fostering sector growth remains delicate. It is crucial for regulators and industry stakeholders to monitor how these reforms evolve, ensuring that the restructuring leads to a stable, competitive, and innovative pension industry without discouraging expansion or market vitality.

Source: Noah Wire Services

Verification / Sources

  • https://nairametrics.com/2025/10/03/pencom-n20-billion-recapitalisation-may-discourage-pfas-pfcs-growth-renaissance-capital/ - Please view link - unable to able to access data
  • https://nairametrics.com/2025/09/27/pencom-raises-capital-requirement-for-pfas-to-n20-billion/ - On 27 September 2025, the National Pension Commission (PenCom) announced a significant revision to the capital requirements for Pension Fund Administrators (PFAs) and Pension Fund Custodians (PFCs). The minimum capital for PFAs was increased tenfold, from N2 billion to N20 billion, while PFCs were required to raise their capital from N2 billion to N25 billion. This move aims to strengthen financial stability and operational resilience within Nigeria's pension industry. The new capital requirements are aligned with global best practices and are set to take effect immediately for new licenses, with existing operators given until 31 December 2026 to comply. PenCom emphasized that the review was conducted in line with Sections 60(1)(b), 62(b), and 115(1) of the Pension Reform Act (PRA) 2014, aiming to support the long-term viability of pension operators and ensure the sustainability of the Contributory Pension Scheme (CPS).
  • https://www.thecable.ng/pencom-raises-capital-base-for-pfas-to-n20bn-pfcs-to-n25bn/ - On 27 September 2025, the National Pension Commission (PenCom) announced an increase in the minimum capital requirements for Pension Fund Administrators (PFAs) and Pension Fund Custodians (PFCs). PFAs are now required to maintain a capital base of N20 billion, while PFCs must hold N25 billion. This decision aligns the capital requirements with the assets under management (AUM) and assets under custody (AUC) of the PFAs and PFCs, respectively. The new capital requirements are set to take effect immediately for new licenses, with existing operators given until 31 December 2026 to comply. PenCom stated that the review was conducted in line with global best practices to ensure that capital is proportionate to the risk exposure of the Pension Fund Operators.
  • https://guardian.ng/business-services/pencom-releases-new-capital-requirement-for-pfas-pfc/ - The National Pension Commission (PenCom) has introduced a new capital regime for Pension Fund Administrators (PFAs) and Pension Fund Custodians (PFCs) to strengthen financial stability and safeguard the long-term sustainability of Nigeria’s pension industry. Under the revised structure, PFAs managing assets above N500 billion must hold a minimum capital of N20 billion, plus one per cent of funds exceeding that threshold. Those with assets below N500 billion are required to maintain a flat N20 billion. The new capital requirements are set to take effect immediately for new licenses, with existing operators given until 31 December 2026 to comply. PenCom emphasized that the measure was necessary to protect operators against macroeconomic shocks, enhance service delivery, and safeguard contributors’ savings.
  • https://independent.ng/pencom-sets-new-capital-base-for-pfas-pfcs-at-n20bn-exercise-ends-dec-2026/ - The National Pension Commission (PenCom) has mandated Pension Fund Administrators (PFAs) and Pension Fund Custodians (PFCs) to increase their capital base to N20 billion and N25 billion, respectively, by December 2026. This directive aims to strengthen the financial stability and operational resilience of Nigeria's pension industry. The new capital requirements are set to take effect immediately for new licenses, with existing operators given until 31 December 2026 to comply. PenCom emphasized that the review was conducted in line with global best practices to ensure that capital is proportionate to the risk exposure of the Pension Fund Operators.
  • https://www.ecofinagency.com/news-finances/2909-49102-nigeria-orders-pension-fund-operators-to-recapitalize-by-december-2026 - Nigeria’s National Pension Commission (PenCom) announced on 26 September 2025 that it will require pension fund administrators and custodians to recapitalize by the end of 2026. The regulator increased the minimum capital for PFAs to N20 billion from N5 billion and for PFCs to N25 billion from N2 billion. The recapitalization must be completed by 31 December 2026, with biennial compliance checks and a 90-day deadline to cover any shortfall. PenCom stated that the reform is designed to enhance financial stability, ensure the long-term viability of operators, and align the system with international standards where capital requirements reflect risk exposure.
  • https://independent.ng/pfa-with-over-n500bn-aum-to-raise-capital-to-n25bn/ - The National Pension Commission (PenCom) has mandated Pension Fund Administrators (PFAs) with over N500 billion in Assets under Management (AUM) to increase their capital base to N25 billion from the current N5 billion. This directive is part of PenCom's efforts to strengthen the financial stability and operational resilience of Nigeria's pension industry. The new capital requirements are set to take effect immediately for new licenses, with existing operators given until 31 December 2026 to comply. PenCom emphasized that the review was conducted in line with global best practices to ensure that capital is proportionate to the risk exposure of the Pension Fund Operators.

Noah Fact Check Pro

The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.

Freshness check

Score: 10

Notes: ✅ The narrative is current, published on 3 October 2025, and addresses recent developments in Nigeria's pension industry, including PenCom's directive from 26 September 2025. No evidence of recycled or outdated content was found. 🕰️

Quotes check

Score: 10

Notes: ✅ No direct quotes were identified in the provided text, suggesting original or exclusive content. 🕰️

Source reliability

Score: 8

Notes: ⚠️ The narrative originates from Nairametrics, a Nigerian financial news outlet. While it is a known source, its reputation and editorial standards are not as established as those of global media organisations. This warrants cautious consideration. ⚠️

Plausability check

Score: 9

Notes: ✅ The claims align with recent regulatory changes by PenCom, as reported by other reputable sources. The analysis by Renaissance Capital appears consistent with the context of Nigeria's pension industry reforms. However, the potential impact on PFAs and PFCs' growth is a matter of professional opinion and may vary. ⚠️

Overall assessment

Veredict (FAIL, OPEN, PASS): OPEN

Confidence (LOW, MEDIUM, HIGH): MEDIUM

Summary: ⚠️ The narrative is current and addresses recent developments in Nigeria's pension industry. However, it originates from Nairametrics, a source with a less established reputation compared to global media organisations, which introduces some uncertainty. Additionally, the analysis by Renaissance Capital is an opinion that may vary, and the potential impact on PFAs and PFCs' growth is not definitively established. ⚠️