Nigeria e-invoicing and the Merchant Buyer Solution

What actually changed

Until now, a Nigerian invoice was a document between two parties. You wrote it, you sent it, the tax authority saw the consequences later through your returns.

Under the new regime, an invoice within scope is submitted to the tax authority before or at the point it goes to the buyer. The platform validates it and returns a reference number. The invoice the buyer receives carries that number. An invoice without one is not a compliant invoice, and the buyer has a reason to refuse it.

That is the substantive change. The document stops being private paperwork and becomes a record the state has already seen. Everything else, the deadlines, the providers, the penalties, follows from it.

• Invoices in scope are cleared through a national platform rather than simply exchanged.
• Each cleared invoice carries an Invoice Reference Number.
• Buyers in scope are expected to accept only invoices that carry one.
• Connection to the platform is made through an accredited provider, not directly by most businesses.
• The obligation arrives by turnover band, on published dates.

Who must comply, and when

The Nigeria Revenue Service published a phased timeline built on annual turnover. The table below is that timeline as reported by the sources listed at the foot of this page.

For the large taxpayer band there is a further date. In July 2026 the Nigeria Revenue Service set 31 July 2026 as the deadline for large taxpayers to complete onboarding on the Merchant Buyer Solution and integrate their systems through approved providers. That reporting also noted that more than 1,000 companies had complied as of the first quarter of 2026.

The sequence within each band is the same: engagement, pilot, go-live, a post go-live review, then enforcement. The published position is that enforcement only begins after those earlier phases are complete for that category. A go-live date is therefore not the date you start being fined.

What the Merchant Buyer Solution is

The Merchant Buyer Solution, abbreviated MBS, is the national e-invoicing platform. In official material it is also referred to as the E-Invoicing and Electronic Fiscal System, or EFS. The two names describe the same programme.

Its job is clearance. A supplier in scope sends invoice data to the platform. The platform checks it, records it, and returns a reference. The supplier then issues the invoice to the buyer carrying that reference. The buyer, if they are also in scope, is expected to accept only invoices that carry one.

Two consequences follow that are easy to miss. The first is that both sides of a transaction are affected, not just the seller. The second is that the invoice becomes structured data before it becomes a document, which is why connection is a systems project rather than a change of stationery.

The platform is at einvoice.firs.gov.ng.

Accredited Access Point Providers and System Integrators

Most businesses do not connect to the platform themselves. They connect through an accredited intermediary. Two roles are named in the guidance.

• An Access Point Provider, or APP, is the accredited party that transmits invoice data to and from the platform.
• A System Integrator, or SI, connects your existing accounting or ERP system to that access point.

The reported requirement for large taxpayers was to complete onboarding on the MBS and successfully integrate their systems through approved Access Point Providers or Systems Integrators. The same route applies as later bands come into scope.

Accreditation is the point. A vendor is either on the tax authority's accredited list or it is not, and there is no partial version of it. If you are in scope, start by establishing whether a prospective provider is accredited, and verify it with the Nigeria Revenue Service rather than taking the vendor's word for it.

The Invoice Reference Number

The Invoice Reference Number, or IRN, is what the platform returns when it accepts an invoice. It is the proof that the invoice was cleared.

The tax authority has instructed businesses to transmit invoices carrying valid IRNs and to receive only compliant electronic invoices carrying an IRN from their suppliers. In practical terms that turns your customers into enforcers. A buyer in scope who accepts an invoice without an IRN creates a problem for themselves, so they will not.

This is also what makes the mandate reach further than the bands suggest. A supplier who is below the threshold may still find that a large customer wants a compliant invoice, because the customer is inside the regime even if the supplier is not.

An IRN is issued by the platform. It is not a number you can generate, format or assign yourself, and no invoicing tool outside the accredited chain can produce one.

Penalties

The penalty structure that has been reported for default under the regime is NGN 1,000,000 for the first day of default, plus NGN 10,000 for each subsequent day it continues.

The published sequencing matters here too. Enforcement for each band is stated to begin after go-live and the post go-live review, on the dates in the table above, rather than on the go-live date itself. A shorter, more scannable version of the dates and penalties is at Nigeria e-invoicing deadlines and penalties.

What a business below the threshold should do now

If your annual turnover is under NGN 1 billion, the published go-live date for your band is 1 July 2027 with enforcement from January 2028. You are not in scope today. The useful response is neither to panic nor to ignore it.

The work that pays off either way is getting your invoicing tidy. Every requirement of the regime assumes you already have clean, uniquely numbered, complete invoice records with correct counterparty details. Most small businesses do not, and that is the gap that will hurt in 2027, not the technology.

1. 01Confirm which band your turnover puts you in, and recheck it each year.
2. 02Get your TIN and CAC details onto every invoice. See TIN and CAC details on your invoice.
3. 03Use one invoice numbering sequence with no duplicates and no gaps you cannot explain.
4. 04Capture the customer's registered name, address and tax details, not just a contact name.
5. 05Present VAT correctly and separately. See VAT on invoices in Nigeria.
6. 06Keep every invoice retrievable by number and by date, in one place rather than across phones and inboxes.
7. 07Ask your largest customers whether they will require IRN-bearing invoices from suppliers, and when.
8. 08When your band approaches, engage an accredited Access Point Provider or System Integrator in good time.

Step seven is the one people skip. A large customer inside the regime may change what it accepts from suppliers before your own band goes live. That is a commercial deadline, and it can arrive earlier than the regulatory one.

Where Billify stands

Stated once more without hedging: Billify is not an accredited FIRS or NRS e-invoicing service provider. It is not an Access Point Provider. It is not a System Integrator. It does not connect to the Merchant Buyer Solution and it cannot obtain an Invoice Reference Number. Nothing Billify does makes a business compliant with the e-invoicing mandate.

What Billify is, is invoicing software for businesses below the mandate threshold. The free plan covers 10 invoices a month for up to 5 clients on one business profile, with no card required. Paid plans are Pro at NGN20,000 a month and Enterprise at NGN70,000 a month, and include an AI invoice composer that drafts line items from a plain-words description of the work.

• Eleven A4 invoice templates, three of which are free, with your logo and brand details.
• Payment links and QR checkout on the invoice.
• Payments settle to a Billify wallet and are withdrawn to your bank account.
• Collection is naira only, through Kora Pay.
• A mobile app for iPhone and iPad. There is no Android app.
• A free invoice generator that needs no signup.

Billify is published by Onebit Technology Solutions Limited, RC1919657, Abuja.