The Nigerians in Diaspora Commission (NiDCOM) has challenged an instruction from the Central Bank of Gambia requiring banks to replace non-Gambian staff with local employees by the end of 2026 saying it could disrupt the jobs of 57 Nigerian professionals.
In a statement issued on Tuesday, NiDCOM Chairman Abike Dabiri-Erewa described the directive as “deeply worrisome” and called on the regulator to reconsider it.
The professionals work at four Nigerian-origin banks—subsidiaries of Access Bank, FirstBank, GTBank and Zenith Bank—and hold valid residency and work permits, according to the commission.
Those banks account for approximately 37.2% of total industry deposits (GMD 35.3 billion), 32.6% of loans (GMD 7.67 billion) and 37% of industry assets (GMD 44.78 billion).
They also hold about 34.5% of investments in the Central Bank bonds and have reportedly contributed 90% of the funding supporting the operations of the National Water and Electricity Company (NAWEC)
NiDCOM cited the above figures, and urged Gambian authorities to engage the Nigerian High Commission in Banjul rather than apply a blanket replacement order.
It began with a Central Bank’s circular, dated 16 September and signed by Second Deputy Governor Dr. Paul J. Mendy, followed a meeting with bank executives and an industry review. The Bank said the review found a relatively high number of non-Gambians working in banks beyond the staff already recognised as expatriates.
It described this as a breach of the Labour Act 2023 and inconsistent with its Guideline 9 on expatriate staff.
Banks were told to phase out existing non-Gambian employees, replace them with suitably qualified Gambians, and finish the process by 31 December 2026, while arranging for skills to be transferred and operations to continue smoothly.
However, the rules which the circular relies on are more limited in scope. Guideline 9 mainly restricts the number of expatriates in senior management positions to three, with some flexibility for newer banks that show a clear plan to train local successors.
Related corporate governance rules reinforce this by encouraging Gambian leadership in top roles and requiring succession plans.
The Labour Act 2023 sets up a quota system for foreign workers. Employers can only bring in expatriates for jobs where local skills are not available, and they must assign a Gambian understudy so knowledge can be passed on. Breaking these rules can lead to fines of at least 500,000 dalasis ($6,780).
Meanwhile, the circular’s language is broader, reflecting an attack on foreign workers. It directs banks to replace “existing non-Gambian staff” without clearly limiting the instruction to senior managers or to people working outside approved quotas.
If the Central Bank’s review simply found staff who were not properly authorised under the quota rules, enforcing those rules would be standard.
Requiring the replacement of every non-Gambian employee, regardless of their role or whether they already have formal approval, goes further than the guidelines and the Labour Act appear to require.
Furthermore, the short deadline adds practical pressure. Banks have roughly three months to identify replacements, transfer skills and keep services running. That is manageable for a small number of specialised senior positions.
It becomes more difficult if applied widely across the workforce. Because the four Nigerian-origin banks hold a substantial share of deposits and loans, and support key public infrastructure funding, any hasty or unclear implementation could affect the wider banking system.
NiDCOM’s intervention highlights the need for the Central Bank to spell out exactly which employees the directive covers, how existing work permits will be treated, and what standard of “suitably qualified” will be applied.
Clarifying these points would show whether the measure is simply enforcing current labour and banking rules, or whether it is introducing a wider localisation requirement than those rules currently contain.
