Library / PETROLEUM INDUSTRY ACT, NO. 6, 2021 MIDSTREAM AND DOWNSTREAM PETROLEUM PREVENTION OF ANTICOMPETITIVE PRACTICES AND BEHAVIOUR REGULATIONS, 2026 ARRANGEMENT OF REGULATIONS

PETROLEUM INDUSTRY ACT, NO. 6, 2021 MIDSTREAM AND DOWNSTREAM PETROLEUM PREVENTION OF ANTICOMPETITIVE PRACTICES AND BEHAVIOUR REGULATIONS, 2026 ARRANGEMENT OF REGULATIONS

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3. If turnover is not available or not indicative, the Authority may apply a 
fixed-sum fine commensurate with the seriousness of the offense and size 
of the undertaking. 
4. Fines do not preclude the Authority from taking additional administrative 
actions, including licence suspension or referral for criminal sanctions. 
 
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SCHEDULE 4 
Regulation 109(1)(a) 
 
 
LENIENCY POLICY FOR THE MIDSTREAM AND DOWNSTREAM PETROLEUM 
INDUSTRY 
 
 
(Issued by the Nigerian Midstream and Downstream Petroleum Regulatory 
Authority pursuant to the Petroleum Industry Act, 2021, the Midstream and 
Downstream Petroleum Industry Competition Regulations, 2025, and 
harmonised with the FCCPC Leniency Rules, 2022) 
 
Part I – Preliminary Provisions 
 
1. Title and Citation 
 
This document may be cited as the Leniency Policy for the Midstream and 
Downstream Petroleum Industry, 2025. 
 
2. Objectives 
 
The objectives of this Policy are to: 
(a) Encourage self-reporting of cartel conduct and other anti-competitive 
practices by market participants; 
(b) Deter collusive behaviour and promote compliance with the Act  and 
Midstream and Downstream Petroleum Industry Competition Regulations; 
(c) Provide clear guidance on the qualification criteria, cooperation 
obligations, and benefits available to applicants for leniency; 
(d) Harmonise sector-specific competition enforcement with the FCCPC 
Leniency Rules, 2022, while preserving petroleum industry–specific regulatory 
authority. 
 
3. Scope of Application