Nigeria
Clearance model through the Merchant Buyer Solution (MBS), the platform operated by the Nigeria Revenue Service — the renamed, restructured successor to FIRS. Suppliers submit B2B and B2G invoices for clearance before issuing them to the buyer; cleared invoices receive an Invoice Reference Number and a cryptographic stamp. Formats are Peppol BIS Billing 3.0 UBL in XML or JSON, which makes Nigeria one of the few African clearance regimes built on Peppol semantics. Phased by taxpayer size: large live since Nov 2025 with a 31 Jul 2026 compliance deadline, medium from 1 Jul 2026 with enforcement in Q1 2027, and small and emerging taxpayers from 1 Jul 2027 with enforcement in Q1 2028.
// Phased rollout
- 01 Nov 2025 · livePhase 1 — large taxpayersLarge taxpayers live on MBS; compliance deadline 31 Jul 2026.Annual turnover >= NGN 5 billion
- 01 Jul 2026 · livePhase 2 — medium taxpayersMedium taxpayers go live; enforcement scheduled January-March 2027.Annual turnover NGN 1bn - 5bn
- 01 Jul 2027 · upcomingPhase 3 — small and emergingRemaining taxpayers go live; enforcement projected January-March 2028.Annual turnover < NGN 1 billion
// Penalties
Penalties under the Federal Inland Revenue Service (Establishment) Act and the 2025 tax reform acts; an uncleared invoice is not a valid tax invoice.
// What you have to do
- Confirm which of your flows are in scopeB2B is phased, B2G is phased, B2C is phased.
- Emit one of Peppol BIS Billing 3.0 (UBL XML) or JSONYour ERP must produce this syntax, not a PDF or a print stream.
- Connect via MBS clearance API or Access pointThis is the channel, separate from the format. Most projects underestimate it.
- Plan for the Clearance modelThe regulator validates before the invoice is legally issued, so a rejection blocks the sale. Build the rejection path first.
- Retain for 6 yearsArchive the structured original, not a rendering of it.
- Understand the exposurePenalties under the Federal Inland Revenue Service (Establishment) Act and the 2025 tax reform acts; an uncleared invoice is not a valid tax invoice.