Unpacking CBN's New E-invoicing Directive

Electronic invoicing or e-invoicing is the exchange of digital forms of an invoice for the delivery of a good or service as opposed to the hard copy forms that used to be required to process imports and exports. The electronic evaluation system is a new system adopted by the CBN to examine the invoices presented by authorized dealers against the global benchmark prices before allowing such import or export.

Compliance Touchpoints

Suppliers are now required to set their price within the 2.5% limit of the vertical price prescribed under the regulations. The circular discloses the adoption of the Global Price Verification Mechanism which contains the benchmark price against which the prices on the e-invoices will be measured.

Prior to now, final invoices were usually made in hard copy formats. The new regulation now digitizes this process requiring authorized dealers to present an electronic invoice. Importers and exporters are now required to ensure that their suppliers and buyers comply with the pricing limits as well as the e-invoicing directive.

CEMA Price Control and Potential Conflict Areas

There are concerns that the regulation is an attempt by the CBN to usurp the powers of the Board of Customs and Excise in relation to price control for imports and exports. A potential problem may arise with respect to price verification when the provisions of CEMA are compared with the CBN's regulation.

While the introduction of these innovations is laudable for their ability to plug leaks and check pervasive trading practices, the short deadline prescribed under the circular and its new process additions may yield more difficulties for Nigeria and Nigerians involved in international trade.