Regulatory updates - Nigeria

As previously reported by Pagero, the roll-out of the Nigerian mandate commences with a pilot for the largest taxpayers expected in July 2025, followed by an extension to medium and smaller taxpayers. With the launch of the portal, a vital step is reached, as the government infrastructure is now available, allowing all VAT-registered businesses in Nigeria to eventually issue e-invoices in accordance with Section 25, Part 5 of the Tax Administration and Enforcement Act of 2007.

To utilize the MBS portal, taxpayers must be enabled by submitting the required information on the FIRS MBS Portal. FIRS, in turn, allows for issuance directly in the FIRS MBS Portal or automatically through integrating with the FIRS MBS e-invoice API. Invoices issued via the MBS must be sent in the acceptable XML or JSON format and contain all necessary fields, as outlined in the e-invoice schema.

Upon issuance, invoices will be exchanged through a pre-clearance model, as they are validated by the MBS system and receive a unique identifier number before buyer exchange is allowed. Furthermore, the buyer and seller will receive a notification of the cleared invoice and can reject or cancel said invoices.

Further detailed information about the MBS system is available on the FIRS dedicated web page.

On February 18, 2025, FIRS announced that the proposed implementation of electronic invoicing is expected to commence in the second half of 2025 with a pilot encompassing the largest taxpayers.

A phased approach will follow, although the exact date for broader enforcement is yet to be announced.

Transactions in scope

FIRS proposes implementing electronic invoicing systems across various transaction types, including Business-to-Consumer (B2C), Business-to-Business (B2B) and Business-to-Government (B2G).

Proposed electronic invoicing models and requirements

Emphasis is put on using harmonized invoicing flows aligned with international standards. Invoices are therefore proposed to be sent in the Peppol BIS Billing 3.0 format. Furthermore, different e-invoicing requirements are proposed depending on the transaction:

B2C transactions:

• Invoice issuance and fiscalization: The supplier issues the invoice to the buyer and reports it to FIRS within 24 hours by using an access point provider;

• Buyer validation: The buyer may, in turn, validate the invoice using a QR code;

• Invoice element requirements: Invoices must contain essential elements, including seller details, invoice number, invoice date, description of goods or services, total payable amount, and applicable taxes.

B2B and B2G transactions:

• Invoice issuance and clearance: The supplier must transmit the invoice for clearance to FIRS before sending it to the buyer;

• Invoice element requirements: Invoices must contain detailed information about the transaction, including details of the buyer and seller, the invoice number, the date, a breakdown of items (description, quantity, price), applicable tax rates, and the total payable amount.

Accreditation requirements for service providers

Comprehensive requirements are put on the service providers to exchange compliant invoices, including the ability to apply advanced electronic signatures (AES) on the invoices.

The engagement survey is open to the public

Stakeholders are invited to share opinions on the proposed implementation by participating in the survey on FIRS website.

Pagero is closely following the developments in Nigeria, as further e-invoicing obligation announcements are made.

This new regulation aims to attain accurate price values for the flow of imports and exports in the country.

Assuring accurate prices

A Global Price Verification Mechanism would be a part of the new system, obtaining actual spot market prices at the time e-invoice transactions begin. Imports and exports of more than 2.5% of the verified spot market price will be questioned and not allowed to complete transactions.

Registration platform

Trading partners must ensure compliance with the new regulations. Suppliers and buyers operating in imports and exports will need to register on a dedicated electronic platform provided by the Central Bank of Nigeria (CBN).

Once a supplier or buyer is successfully registered, a CBN-appointed service provider issues a verification report and digital certificate valid for one year. Suppliers must use the digital certificate for signing e-invoices to be submitted.

Dedicated e-invoice portal

Invoices must be submitted in an electronic format, and invoice amounts must be verified by an Authorized Dealer Bank within Nigeria. Furthermore, buyers cannot submit payment to suppliers unless the associated e-invoice has passed verification with an Authorized Dealer Bank. Printed versions of e-invoices will have a QR code to verify authenticity.

CBN service providers will deliver verified e-invoices to the supplier and buyer for transmission between trading partners. In addition, the CBN service provider will submit the e-invoice to the Nigeria Single Window portal – Trade Monitoring System (TMRS).

Exemptions to the new e-invoicing requirements

• Invoices with a value less than USD 10 000 (ca. EUR 8970,00). However, if a supplier’s annual cumulative invoice value is equal to or greater than USD 500 000 (ca. EUR 448 460,00), they will have to submit e-invoices;
• Transactions made by security agencies in the country;
• Supplies to specific diplomatic and consular missions, as well as supplies to international agencies dependent on the United Nations;
• Donations made by foreign governments or international organizations to foundations, charities, and other humanitarian organizations;
• Goods directly supplied by foreign governments.

Read the full announcement here.