Lagos, Nigeria – The [Nigeria Revenue Service](https://www.nra.gov.ng) has warned mining and energy firms that non‑compliance with the newly mandated electronic invoicing framework could trigger tax disputes, as the agency phases the programme across all taxpayer tiers from November 2025 to 2028.
**What does the e‑invoicing mandate require?**
The rule obliges businesses falling within the specified taxpayer categories to generate invoices that are validated by the NRS through the Merchant Buyer Solution ([MBS](https://www.nra.gov.ng/e-invoicing)). Each invoice must display a unique Invoice Reference Number (IRN) issued by the system.
**Which taxpayer groups are affected and when?**
- Large taxpayers with annual turnover exceeding N5 billion began compliance in November 2025.
- Medium taxpayers, whose turnover lies between N1 billion and N5 billion, entered the scheme on 1 July 2026, with enforcement scheduled for January‑March 2027.
- Emerging taxpayers with turnover below N1 billion are expected to join from July 2027, with enforcement slated for 2028.
**Why are mining and energy firms particularly vulnerable?**
The solid minerals sector often conducts transactions through artisanal miners, buying centres, aggregators and processors that rely on cash payments and handwritten receipts. Such informal documentation creates gaps that can expose companies to disputes over input [Value Added Tax](https://en.wikipedia.org/wiki/Value-added_tax) (VAT) claims, allowable deductions and tax assessments when purchases lack valid invoices. Energy companies face comparable risks because their operations depend on extensive networks of contractors, subcontractors and community‑based service providers, many of which do not have the infrastructure for electronic invoicing. Exporters may also struggle to recover input VAT on zero‑rated exports if supporting invoices and purchase records are incomplete.
**How can companies mitigate the risks?**
Businesses are advised to integrate their accounting platforms with the MBS via accredited service providers, embed tax identification and invoice verification steps into supplier onboarding, and retain records that link purchases to delivery notes, assay certificates, royalty payments and export documentation. Industry bodies and mining cooperatives can play a role by coordinating supplier registration, delivering training and promoting technology adoption across the supply chain.
With the enforcement window for medium‑taxpayers approaching, firms that strengthen invoicing and procurement controls now can lower audit exposure, safeguard legitimate tax claims and enhance transparency throughout their operations.