The new pension scheme requires pension funds to be privately managed by licensed Pension Fund Administrators. Pension Fund Administrators (PFAs) have been duly licensed to open Retirement Savings Accounts for employees, invest and manage the pension funds in a manner as the Commission may from time to time prescribe, maintain books of accounts on all transactions relating to the pension funds managed by it, provide regular information to the employees or beneficiaries and pay retirement benefits to employees in accordance with the provisions of the Pension Reform Act 2004.

Before it is issued with an operating license, the PFA must be a limited liability company whose sole object is the management of pension funds. To discourage frivolous applications and to ensure credibility, such company must have a paid up share capital of N150,000,000 and demonstrate professional capacity to mange pension funds and administer retirement benefits.

Pension Fund Custodians (PFCs) will be responsible for the warehousing of the pension fund assets. The PFAs shall not be allowed to hold the pension funds assets. The employer sends the contributions directly to the Custodian, who notifies the PFA of the receipt of the contribution and the PFA subsequently credits the retirement savings account of the employee.The Custodian will execute transactions and undertake activities relating to the administration of pension fund investments upon instructions by the PFA.

The custodian shall hold pension fund assets on trust for its clients. For the same reason adduced in the case of the PFA, a stakeholder of the Custodian must be a licensed financial institution and have a minimum net worth of N5,000,000,000 and a total balance sheet of not below N125,000,000,000. The shareholders of a Custodian must guarantee the pension fund assets held by it.

Closed Pension Fund Administrators (CPFAs) are a category of Pension Fund Operators Licensed by PENCOM under provisions of the PRA 2014. The CPFA License was granted in accordance with the provisions of Section 51 of the Act, to qualifying owner-managed Pension schemes that existed prior to the Pension Reform in 2004.

Even though they CPFAs are regulated by PENCOM, CPFA membership is only open to employees of companies that they represent and not for the general public. Notwithstanding the foregoing, CPFAs are subject to provisions of the PRA and rules of their Approved Existing Schemes, and other guidelines as specified by PENCOM from time to time.