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Nigeria: PenCom Implements BVN Mandate for RSA Registration and Data Recapture Starting February 1, 2025

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The National Pension Commission (PenCom) has announced a new directive requiring the mandatory inclusion of Bank Verification Numbers (BVN) for all Retirement Savings Account (RSA) registrations and data recapture activities.

This policy, outlined in a circular dated January 9, 2025, will take effect from February 1, 2025, and is intended to enhance the security and integrity of the pension industry database. The circular was signed by A.M. Saleem, Head of the Surveillance Department.

The directive stated:
“PenCom hereby directs all Pension Fund Administrators (PFAs) to mandate the provision of the Bank Verification Number (BVN) for individuals/RSA holders during RSA registration or data recapture processes. This initiative aims to strengthen the security and integrity of the pension industry database.”

Key Requirements of the Directive

PenCom has outlined the following measures for compliance:

  1. BVN Validation:
    PFAs must ensure that the provided BVN contains the correct 11 digits and is properly validated.
  2. RSA Registration:
    New RSA registrations must include the BVN of the individual. PFAs are required to mark the BVN field on registration forms as mandatory for successful processing.
  3. Data Recapture:
    Existing RSA holders must provide their BVN during the data recapture process. PFAs must update their forms to reflect this requirement.

Provisions for Existing Records

To accommodate RSA holders whose BVN details are not yet on the Enhanced Contributor Registration System (ECRS), PenCom has directed PFAs to update these records before the implementation date. This ensures a seamless transition to the new requirements.

The circular also supersedes specific sections of the Revised Guideline on Retirement Savings Account Registration (2024), particularly Sections 2.2.1 (15) and 5.3.6 (16), emphasizing PenCom’s commitment to modernizing its processes and strengthening the pension system’s security.

Revised Documentation for RSA Registration

In a separate circular dated January 8, 2025, also signed by A.M. Saleem, PenCom announced revised documentation requirements to simplify RSA registration for formal sector employees.

The changes address challenges faced by PFAs in obtaining Letters of Employment from new employees. These updated guidelines, which take immediate effect, supersede Section 4.1.2 of the Revised Guideline on RSA Registration (2024).

New Documentation Requirements

  1. For Private and Public Sector Self-Funded Agencies:
    Employees must provide a Letter of Employment, Letter of Appointment, or Staff Identity Card.
  2. For Treasury-Funded Agencies and Police Personnel:
    Required documents include a Letter of First Appointment, an Attestation Letter, or a Staff Identity Card.
  3. Alternative Identification:
    If a Letter of Employment or Appointment is provided, alternative IDs like a Staff Identity Card, National Driver’s License, Permanent Voter’s Card (PVC), or International Passport can be used. When a Staff Identity Card is submitted as primary documentation, additional ID is not required.
  4. Mandatory NIN Submission:
    Employees must also present a National Identity Card or Enrolment Slip issued by the National Identity Management Commission (NIMC) with their National Identification Number (NIN).

PFAs may request further documentation at their discretion, and PenCom has indicated that additional requirements could be introduced in the future.

Ensuring Flexibility and Security

These measures aim to enhance the pension system’s security while addressing the practical challenges faced during the RSA registration and data recapture processes. PenCom’s directives reflect its ongoing commitment to fostering a secure and efficient pension industry framework.

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