FRC’S REGISTRATION ENFORCEMENT DRIVE: HOW BUSINESSES SHOULD PREPARE BEFORE APRIL 2026.

The Financial Reporting Council of Nigeria (FRC) has issued a Public Notice announcing the mandatory registration of audit firms and other assurance service providing firms, with enforcement taking effect from the 1^st of April, 2026. The notice is issued pursuant to Sections 41, 60, 61, 64 and 72 of the Financial Reporting Council of Nigeria Act No. 6, 2011 (as amended) and the Audit Regulations 2020, and follows earlier public notices on the registration and classification of audit and assurance firms.

From April 2026, only firms duly listed on the National Audit and Assurance Firms Register will be legally permitted to undertake audit or assurance engagements in Nigeria. Reporting entities that engage unregistered firms risk regulatory sanctions and potential invalidation of audit engagements. Therefore, all firms providing audit or other assurance services in Nigeria are mandatorily required to register and/or update their regulatory profile on the FRC’s Official registration portal on or before 31st March, 2026.

This newsletter highlights the Council’s regulatory compliance requirements for businesses in Nigeria and the risks and implications of non-compliance. It also emphasises the importance of verifying a business’s status before engagement.

Scope of the Mandatory Registration

The Notice makes it clear that registration is no longer an optional or administrative in nature but a mandatory regulatory prerequisite for carrying on audit or assurance services within Nigeria.

The requirement extends beyond traditional statutory audit firms. It applies to all firms providing assurance-related services, including:

1. Attestation and verification services
2. Certification and independent opinions are relied upon for financial reporting
3. Sustainability reporting
4. Valuation and business/finance valuation
5. Corporate governance reviews
6. Compliance assessments
7. Actuarial and tax assurance services
8. Statutory audits
9. Tax assurance services, and other assurance-related engagements

In effect, the FRC has adopted a broad interpretation of “assurance services,” ensuring that firms whose work influences financial reporting, regulatory compliance, or public interest decision-making fall within the regulatory net.

Registration Requirements for Firms

In line with the notice, unregistered firms must meet the following registration requirements:

1. Online Registration Process: Firms are to complete their registration process online by following the steps below:
   • Visitation to the FRC registration portal at https://registration.frcnigeria.gov.ng/register.
   • Selecting registration category and type
   • Inputting RC or BN number.Selection of firms’ category and type
   • Input of required details and upload of documents
   • Submission and payment of registration fee

2. Registration Documents:

• Certificate of incorporation
• FRC individual registration numbers of the partner(s)
• Financial statements for the last four years
• FRC number of your auditor’s audit firm
• A scanned copy of the declarant’s signature 3. Payment of Registration Fees and Dues: The Council, in its guidelines, has outlined the registration fees for firms based on their type and category. They are;
• Audit firms:
• Big Firms- ₦2 Million
• Medium Firms- ₦500,000
• Small Firms- ₦10,000
• Other Assurance Service Firms require a flat rate of ₦50,000

Firms are also required to pay annual dues regularly.

Practical Compliance Steps for Businesses

To ensure compliance with FRC’s notice of cessation of operations ahead of the March 31, 2026, deadline, businesses should ensure;

1. Verify Registration Status: Businesses should check the FRC’s National Audit and Assurance Register to confirm that current auditors, tax consultants and valuation firms are registered.
2. Confirm Signing Partners: Beyond the firm, verification of individuals signing audit reports should be carried out to ensure they hold an active FRC registration number.
3. Update Vendor Onboarding: Procurement and onboarding policies should be updated to require FRC registration for any firm providing audit, valuation, actuarial, or assurance services.
4. Review Existing Contracts: Contracts with unregistered service providers should be terminated or paused before the deadline to prevent financial statements from being invalidated.

Effect of Non-Compliance

From the 1^st of April 2026:

1. Unregistered firms will be prohibited from operating.
2. Audit or assurance reports issued by unregistered firms risk being treated as invalid.
3. Reporting entities engaging such firms may face regulatory sanctions.
4. Responsible officers may be subject to scrutiny where due diligence obligations are neglected.

This enforcement aligns with broader regulatory reforms aimed at strengthening public oversight, enhancing transparency, and reinforcing confidence in Nigeria’s financial reporting framework

While the statutory framework is clear, the practical implications of enforcement (particularly regarding report invalidation and sanctions) may require case-specific legal analysis, especially where contractual obligations and regulatory filings are involved. Prompt review is advisable to ensure full compliance before the deadline.