FIRS E-Invoicing Mandate for Large Taxpayers
14 July 2025
The Federal Inland Revenue Service (FIRS) has announced the mandatory implementation of its National E-Invoicing Regime.
On 9 July 2025, the Federal Inland Revenue Service (FIRS) issued a public notice confirming the official commencement of the National E-Invoicing Regime – Electronic Fiscal System (EFS). Effective 1 August 2025, all large taxpayers, defined as companies with an annual turnover of ₦5 billion or more, must adopt the system under the Merchant Buyer model.
This marks the end of the pilot phase launched in November 2024 and signals a shift to mandatory compliance.
What is the E-Invoicing Regime?
The e-invoicing framework is part of Nigeria’s broader digital tax transformation strategy. It is designed to:
- Enable real-time monitoring of taxable transactions
- Enhance transparency and auditability
- Reduce tax evasion and improve compliance
The invoicing process will follow a four-party structure involving the seller (merchant), buyer, FIRS, and FIRS-approved Access Point Providers (APPs). Under this regime, invoices are:
- Generated by the seller’s ERP/accounting system
- Transmitted securely via APPs to both FIRS and the buyer
- Validated and digitally signed by FIRS in real time
The system aligns with international standards such as UBL and PEPPOL.
Who is affected?
- Companies with a turnover of NGN5 billion or above
- Taxpayers filing under the Large Tax Office (LTO) network
- Non-Resident Companies (NRCs) with taxable supplies in Nigeria (mandatory from 1 January 2026)
Companies below this threshold are currently exempt but encouraged to begin early preparation.
Compliance requirements
By 1 August 2025, all affected taxpayers must:
- Register on the FIRS e-Invoicing platform
- Integrate their ERP or accounting software with the FIRS system
- Begin real-time invoice submission via approved APPs
FIRS will begin monitoring and enforcement immediately following the deadline.
How we can help
Transitioning to e-invoicing requires both technical integration and regulatory readiness. Forvis Mazars is equipped to support you with:
- Gap analysis and compliance readiness assessments
- Integration guidance and APP liaison
- Ongoing technical and regulatory support
Download our detailed alert to explore the implications and steps you need to take.
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