Foreign digital companies serving Nigerian customers face uncertainty over how to comply with Nigeria's e-invoicing rules, according to a new PwC report that highlights a lack of guidance for businesses based overseas.

The report, "VAT in Africa: Digital Services 2026," notes that Nigeria's tax rules cover foreign companies supplying taxable digital services to Nigerian customers. However, it identifies ambiguity about how those companies should meet the country's e-invoicing requirements — a gap that touches businesses in sectors such as streaming, online advertising, cloud storage, and online gaming, which already fall within Nigeria's digital services VAT rules.

E-invoicing involves creating and managing invoices electronically, enabling tax authorities to monitor transactions and verify whether businesses are paying the correct taxes.

The uncertainty arises as Nigeria implements new tax laws, including the Nigerian Tax Act and the Nigerian Tax Administration Act, which form part of a broader overhaul of the country's tax system. Nigeria's electronic invoicing system is designed to improve tax monitoring and compliance, and the rules generally apply to taxable transactions by both local and foreign businesses. PwC points out, however, that it remains unclear how non-resident digital service providers should follow these requirements in practice.

Starting in February 2026, the Nigeria Revenue Service (NRS) made e-invoicing mandatory only for large taxpayers with an annual turnover of at least ₦5 billion. PwC notes that the NRS has not expressly excluded foreign digital service providers from this category, leaving open questions about whether some of these companies could fall within the rules and what steps they would need to take.

PwC advises affected businesses to contact the NRS and request written clarification on whether they must comply and whether penalties could apply. The report does not state that all foreign digital platforms are exempt from e-invoicing; rather, it underscores the uncertainty over how the requirements apply to them.

E-invoicing is a separate matter from the requirement to collect and pay value-added tax (VAT) on digital services in Nigeria. While both relate to tax, they are handled through distinct rules, meaning compliance with one framework does not by itself settle a company's position under the other.

Under the VAT framework, a foreign company providing digital services to customers in Nigeria must register for VAT once its annual sales reach, or are expected to reach, $25,000 or the equivalent in other currencies. Nigeria applies a standard VAT rate of 7.5%.

The VAT rules cover services such as streaming and downloadable content, online advertising, cloud storage, online gaming, digital education, subscription-based social media, online marketplaces, and ride-hailing platforms. For example, a foreign company selling a taxable digital subscription to a Nigerian customer may be required to charge VAT on the transaction and remit it to the NRS.

Registered providers must obtain a tax identification number, issue tax invoices, file monthly VAT returns, and remit the tax by the 21st day of the following month. The rules also extend to business-to-business transactions: if a foreign supplier fails to charge VAT on a taxable service sold to a Nigerian business, the Nigerian customer may have to calculate and remit the tax itself.

PwC says Nigeria's simplified VAT compliance circular, which took effect in January 2022, remains relevant while the country awaits an updated circular reflecting the newer tax legislation. For foreign digital companies, the key question is how to meet their existing tax obligations while navigating the newer rules and any applicable e-invoicing requirements. Until that updated guidance arrives, the written clarifications PwC recommends requesting from the NRS are, for now, the main route for a platform to confirm where it stands.