The National Health Insurance Authority (NHIA) Act, enacted by the Federal Government in 2022, repealed and replaced the National Health Insurance Scheme (NHIS) Act of 2004. The previous law failed to achieve meaningful population coverage or to integrate Nigeria’s fragmented health insurance system.
The NHIA Act of 2022 marks a significant policy and legal shift toward making universal health coverage (UHC) both a legal and operational reality for Nigerians. The law mandates the enforcement of a Basic Minimum Package of Care for all citizens and establishes the Vulnerable Group Fund to subsidize healthcare for the poor, the elderly, children under five, as well as persons with physical or mental disabilities. Furthermore, states are required to establish health insurance schemes or, in the interim, engage third-party administrators until their schemes are operational.
In line with the NHIA framework, President Bola Tinubu, on September 3, 2025, directed all Ministries, Departments, and Agencies (MDAs) to enrol their employees in the NHIA scheme. To ensure compliance, all entities participating in public procurement must now present a valid NHIA-issued Health Insurance Certificate. The directive also empowers the Secretary to the Government of the Federation to enforce enrolment and monitor compliance, with the potential to significantly expand health coverage across MDAs.
Additionally, the NHIA Act requires the governments of the 36 states and the Federal Capital Territory to provide the Basic Minimum Package of Care to all residents of Nigeria. To achieve this, the NHIA is tasked with implementing the Basic Health Care Provision Fund, as outlined in the National Health Act of 2014, and ensuring adherence to relevant guidelines. While state health insurance schemes will manage the fund and oversee its implementation, states without such schemes may rely on third-party administrators pending their establishment.
The overarching objective of the NHIA Act is to guarantee that every Nigerian and legal resident has access to affordable, quality, and comprehensive healthcare services through mandatory health insurance. To this end, the NHIA has created a regulatory and institutional framework for the promotion, supervision, and regulation of all health insurance schemes in Nigeria—whether public or private.
Despite these reforms, challenges remain. The Health Care Providers Association of Nigeria reports that more than 90 per cent of Nigerians still lack health insurance coverage. The association warns that this high rate of uninsured citizens poses a major obstacle to achieving universal health coverage. Poverty has been identified as a primary factor, with millions of Nigerians officially recognized as multidimensionally poor.
The NHIA Act provides mechanisms to address this. Section 25 of the Act stipulates that health insurance for vulnerable groups shall be fully funded by government, while Section 31 requires employees to make contributory payments toward their healthcare. The law defines “vulnerable groups” to include children under five, pregnant women, the elderly, persons with physical or mental disabilities, and the indigent, as may be further specified over time. Given that a large proportion of citizens now fall within the indigent and vulnerable category, it is imperative for the federal, state, and local governments to allocate sufficient resources to fund healthcare for all.
This obligation aligns with Section 17(3)(d) of the Nigerian Constitution, which places a duty on government to ensure the provision of “adequate medical and health facilities for all persons.” It is also consistent with Article 16 of the African Charter on Human and Peoples’ Rights (Ratification and Enforcement) Act, which affirms that “every individual is entitled to the highest attainable standard of physical and mental health.”
