CBN Releases New Export/Import E-invoicing Guidelines

The Central Bank of Nigeria (CBN) has released guidelines for the e-Valuator and e-Invoice for import and export in Nigeria.

This guideline released by the bank is a conclusion to an earlier letter dated August 5, 2020, with reference number TED/FEM/FPC/GEN/01/005 designed to replace the hard copy final invoice as part of the documentation required for all import and export transactions.

The circular, which was prepared by Dr. O. S. Nnaji, Director, Trade, and Exchange Department of the CBN, was made public on the official website of the bank. https://www.cbn.gov.ng/Out/2022/TED/TEDFEMFPCPUB01001.pdf

The circular provided clear guidelines on the dos and don'ts of the new e-valuator and e-invoicing for importers and exporters hoping to carry out their transactions using the FORM M or FORM NXP platforms. This new rule is to take effect on February 1, 2022.

According to the circular, "all import and export operations will require the submission of an electronic invoice (e-Invoice) authenticated by the authorised dealer banks on the Nigeria Single Window portal Trade Monitoring System (TRMS)."

It said, "Products that are more than 2.5 percent around the vertical price would be queried and will not be allowed successful completion of Form M or Form NXP, as the case may be."

"An importer/exporter of goods into Nigeria shall ensure that the purchase/sale contract with a foreign supplier/buyer stipulates compliance with the obligations set out in the CBN regulation and the supplier’s/seller’s invoice must be submitted in electronic format and authenticated by an authorised dealer bank (ADB) as part of the documentation for payment.

"Also, no importer/exporter may effect payment to the credit of any foreign supplier unless the electronic invoice has been authenticated by authorized dealer banks and presented together with the relevant documents for payment.

"A supplier/buyer of goods or services for import/export operations into or out of Nigeria is required to register on a dedicated electronic portal provided by the CBN and operated by the CBN’s agent service providers as per the operational manual for Form M and Form NXP e-invoicing.

"Following satisfactory registration and authentication, the CBN-appointed service provider will deliver a verification report and digital certificate to the supplier/buyer, which is valid for one year from the date of issuance. A supplier will use the digital certificate to sign any e-invoice to be submitted.

"After satisfactory registration and authentication, the supplier/buyer is required to register or submit e-invoices in the dedicated portal for their validation and authentication as specified by the CBN.

"The CBN-appointed Service Provider will additionally transmit the e-invoices to the Nigeria Single Window Portal Trade Monitoring System (TRMS).

"An annual subscription fee of US $350 will be charged per authentication of suppliers on the system.

"the supplier/buyer is advised that an electronic invoice that has been authenticated is required for payment." Any printed version of the electronic invoice will display a QR code to permit verification of its authenticity online. 

However, the circular stated the exemption to the new requirement. Accordingly, "all individual invoices with a value of less than USD10,000 (or its equivalent in another currency), except where suppliers have an annual cumulative invoicing value equal to or above USD500,000 (or its equivalent in another currency), shall be submitted as e-invoices for all their operations, regardless of the individual value of an invoice.

"Import and export transactions made by all security agencies in the country. Supplies to diplomatic and consular missions and supplies to international agencies dependent on the United Nations.

"Donations made by foreign governments or international organizations to foundations, charities, and recognized humanitarian organizations."