More than three years, two cleanup funds, zero activation, and a statutory register of licences and leases that did not exist. That is the position the NEITI audit of the 2022 and 2023 industry records placed on the record for the Nigerian Upstream Petroleum Regulatory Commission, the regulator headed through that period by Gbenga Komolafe.
Komolafe was confirmed in October 2021 as the pioneer Commission Chief Executive of the Nigerian Upstream Petroleum Regulatory Commission. The Petroleum Industry Act had taken effect in August 2021, before his confirmation, and the duties the audit later tested were already written into the law he took office to administer. SecretsReporters investigation examined the audit record against those duties, fund by fund and register by register.
The first fund is the Decommissioning and Abandonment Fund. Sections 232 and 233 of the Act require every licensee and lessee to prepare a decommissioning and abandonment plan and to fund the Decommissioning and Abandonment Fund for the cost of dismantling installations and restoring sites at the end of field life. The plan the sections require is a decommissioning and abandonment plan, prepared by the licensee or lessee, and the fund the sections require is the money for dismantling installations and restoring sites at the end of field life. The audit records that the Decommissioning and Abandonment Fund had not been activated. The cost covered is the cost at the end of field life. The installations covered are the installations to be dismantled under the plan. The sites covered are the sites to be restored under the plan.
The second fund is the Upstream Environmental Remediation Fund, established by Section 103 of the Act to finance rehabilitation and manage the negative environmental impacts of upstream operations. The audit records that this fund had also not been activated. The audit records, in the same finding, that the regulations for Section 103 were still ungazetted. Rehabilitation is the work the fund is to finance. The negative environmental impacts of upstream operations are the impacts the fund is to manage. Both purposes sit in the section alongside the fund itself.
The register failure runs beside the funds. Sections 219 and 222 to 224 of the Act require the Commission to keep a register of licences and leases that stands as conclusive evidence of rights. The sections require that register to be kept up to date and electronically accessible to the public free of charge. The requirements in the sections attach to the same register, a register of licences and leases kept by the Commission, current in its entries, open to the public on electronic access and free of charge, with the entries standing as conclusive evidence of rights.
The audit’s contextual report records the Commission’s own position on that register at printed page 62. There is no proper register, the Commission’s position records, and the document the Commission publishes under the name Concession Situation is described in its own words as a stop gap. The words recorded in the audit are that the Concession Situation document “is a stop gap solution pending when an electronic register will be deployed by the Commission as agreed in several engagements with NEITI and the EITI secretariat during the last country Validation.” The edition of the Concession Situation that the audit worked from was a December 2023 snapshot. The engagements named in the recorded position are engagements with NEITI and with the EITI secretariat. The deployment named in the recorded position is deployment of an electronic register by the Commission.
NEITI’s auditors recorded what that snapshot lacks against the register the Act requires. The audit records that the Concession Situation lacks the owners of the licences. The audit records that it lacks the location coordinates. The audit records that it lacks the production arrangement, the contract type, for the licences it carries. The audit records that it is not updated. A separate NEITI finding records the sum of what stood in place of the statutory register on the Commission’s website, 41 licences and 27 conversion contracts published by the Commission.
The audit’s beneficial ownership chapter turns to the persons behind the licences. The chapter names no beneficial owner of any licence. The chapter flags no politically exposed person. No licence in the chapter carries a named beneficial owner in the audit record.
Komolafe held the office through the whole period the audit covers and beyond, and he resigned in December 2025.
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