A Nigerian firm's own e-invoices for its fees
How a Nigerian accounting firm puts its own fee invoices and credit notes through the NRS fiscalisation system, and what Achekam drafts for it.
By Achekam · · 4 min read · For Accountants & audit firms in Nigeria
Launching soon. Some of the screens this article describes for Nigerian and Kenyan businesses are not reachable in Achekam yet. They are coming soon.
Accountants spend so much time on clients' obligations that their own can slip down the list. A firm that has spent the month helping clients prepare for e-invoicing may not yet have asked the obvious question about itself: every fee note it sends a client charging VAT is a taxable supply, so how does that invoice pass through the NRS's system?
For a Nigerian firm the answer is not optional, and the cost of getting it wrong is set in the law. This article covers what the NRS requires, the penalty, and how Achekam helps a firm prepare its own invoices and credit notes for submission.
The Merchant Buyer Solution and fiscalisation
The NRS describes its national e-invoice system, the Merchant Buyer Solution, as a digital platform for creating, validating, submitting and tracking electronic invoices, with real-time authentication of each invoice linked to the business's tax profile. Some links on the NRS's own page still point to the old einvoice.firs.gov.ng address, a reminder that the transition from FIRS is recent.
The law itself uses different words. The Nigeria Tax Administration Act, 2025 speaks of fiscalisation and an Electronic Fiscal System, and does not use the word "e-invoicing". Under the Act, where the Nigeria Revenue Service deploys an Electronic Fiscal System, any person making a taxable supply must use it to record and report all supplies. The NRS is to specify the system and a transition arrangement and to issue a regulation. The full gazetted Nigeria Tax Administration Act, 2025 contains the fiscalisation provisions alongside the rules on returns, objections and penalties.
Every taxable supply goes through the system
The NRS's information circular on VAT administration puts the duty in practical terms. A taxable person making a taxable supply must implement the fiscalisation system by adopting the Electronic Fiscal System the NRS has deployed, record and report all taxable supplies through it, and keep accurate records of all transactions processed through it. Taxpayers must also follow any regulations, specifications and transition arrangements the NRS issues.
For an accounting firm, "all taxable supplies" means more than the annual audit fee. It includes:
- monthly bookkeeping and payroll fees;
- tax compliance and advisory fees;
- disbursements re-charged with VAT;
- credit notes that reduce any of the above.
A firm that puts its large invoices through the system and handles small or ad hoc fees outside it has not met the duty.
The penalty for not fiscalising
Under the Nigeria Tax Administration Act, a taxable person that fails to process a taxable supply through the fiscalisation system is liable to an administrative penalty of ₦200,000, plus 100 per cent of the tax due, plus interest at the prevailing Central Bank of Nigeria Monetary Policy Rate per annum. The NRS's circular states the same penalty, though it prints the 200,000 without a currency sign.
Because the penalty attaches to a failure to process a taxable supply, a firm issuing many invoices each month needs a process that misses none. These figures are as stated at the time of writing; check the Act and any NRS regulation for the current position.
Recording the firm's registration in Achekam
In Achekam, a Nigerian firm can record its own NRS e-invoicing registration. Once the registration is recorded, Achekam drafts an e-invoice for each invoice and credit note the firm issues. The draft is for the firm to upload through its provider.
That design reflects the firm's position. The firm issues its invoices from Achekam; the provider the firm has chosen connects to the NRS system; the firm uploads the drafts through that provider. Setting up the Nigerian pack more generally is covered in setting up the Nigerian and Kenyan packs.
What Achekam is not
Three limits matter for planning, and the firm should know them before it relies on the drafts:
| Limit | What it means for the firm |
|---|---|
| Achekam holds no NRS accreditation as an Access Point Provider or System Integrator | The firm needs its own provider to submit to the NRS |
| Achekam never generates an Invoice Reference Number itself | The reference comes back through the provider, not from Achekam |
| No Nigerian or Kenyan tax-authority connection is live as shipped | E-invoice transmission works only after Achekam authorises the connector and the firm adds its own production credentials |
The drafts also cover only the firm's own sales. A client's invoices do not pass through the firm's Achekam e-invoicing, and the firm should not suggest otherwise in its engagement letters.
A monthly routine for the firm's own invoices
- Issue. Raise invoices and credit notes in Achekam as usual.
- Draft. Confirm a draft e-invoice exists for each one.
- Upload. Submit each draft through the firm's provider.
- Confirm. Record the reference returned for each invoice and credit note.
- Match. At month end, compare the list of invoices issued with the list confirmed through the provider; anything unmatched is chased the same day.
- Keep. Retain the records of what passed through the system, as the NRS requires.
The month-end match is the control that protects the firm from the penalty. Done monthly, it catches a missed upload while the invoice is still fresh; left to the year end, it becomes an investigation. The firm's other returns are covered in a firm's own tax returns in Nigeria and Kenya.
Confirm that the firm has chosen a provider and recorded its NRS e-invoicing registration in Achekam. Then name the person who will run the monthly match, and have a partner review the first month's result.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
