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The Nigeria Revenue Service (NRS) has issued a Public Notice announcing the phased implementation of its E-Invoicing and Electronic Fiscal System (EFS) regime. You may download a copy of the Public Notice here. You may download a copy of the Public Notice here.
The rollout, which commenced in November 2025 for large taxpayers (defined as businesses with an annual turnover of above ₦5 billion), has recorded significant progress, with many taxpayers successfully transmitting invoice data to the Merchant-Buyer Solution (MBS).
The NRS intends to implement the roll-out in the following stages:
- Stakeholder Engagement
- Pilot Rollout
- Go-Live
- Post Go-Live Review
- Compliance Enforcement
The timeline for each phase is outlined below:
| Taxpayer Category | Annual Turnover Threshold | Stakeholder Engagement | Pilot Rollout | Go-Live | Post Go-Live Review | Compliance Enforcement |
|---|---|---|---|---|---|---|
| Large Taxpayers | Above ₦5 billion | Completed | Completed | Completed | Jan – March 2026 | April – June 2026 |
| Medium Taxpayers | ₦1 billion - ₦5 billion | Jan – March 2026 | April – June 2026 | 1st July 2026 | Oct – Nov 2026 | Jan – March 2027 |
| Emerging Taxpayers | Below ₦1 billion | Jan – March 2027 | April – June 2027 | 1st July 2027 | Oct – Nov 2027 | Jan – March 2028 |
Commentary
This initiative underscores the NRS's commitment to driving the adoption of the e-invoicing solution and advancing the digital transformation of Nigeria's tax administration system. It also represents a significant shift in the tax compliance landscape. Though MBS is a VAT-focused compliance tool, it may evolve into a control mechanism for income tax purposes. Taxpayers that are non-compliant may not be able to claim, as deductible expenses, those expenses that are not supported by compliant electronic invoices, subject to specified exemptions. It has, therefore, become imperative that qualifying taxpayers manage their tax compliance risks appropriately.
Taxpayers should take note of the implementation timeline, particularly considering the Tax Reform Acts, which mandate the use of government-approved fiscal systems and prescribe penalties for non-compliance. KPMG is an approved system integration services provider and is willing to assist organisations in conducting readiness assessments and navigating the complexities of E-invoicing, ensuring full compliance with the evolving tax laws and regulations.
For further insights, you can access our detailed publication on the E-invoicing solution here.
The opinion expressed in this article is solely personal and does not represent the views of any organization or association to which the authors belong.
