On the 26th day of June 2025, the tax reform Acts (the Nigeria Tax Administration Act, the Nigeria Revenue Service Act, the Joint Revenue Board Act and the Nigeria Tax Act 2025) were signed into law. The Acts were subsequently published in the Official Gazette and set to commence on the 1st of January 2026.
The Nigeria Tax Act, 2025 (NTA) consolidates and repeals major tax laws such as the Companies Income Tax Act, Personal Income Tax Act, Petroleum Profit Tax Act, Stamp Duties Tax Act, Capital Gains Tax Act and Value Added Tax Act, while the Nigeria Tax Administration Act, 2025 (NTAA) sets out registration, filing, enforcement and procedural rules. The enactment of the NTAA has raised several concerns, particularly that banks and other financial institutions would deny customers who do not have Tax Identification Numbers access to their bank accounts.
The Nigeria Tax Administration Act (NTAA) 2025
The Nigeria Tax Administration Act (NTAA) 2025 makes obtaining a Tax ID mandatory for all taxable persons (individuals, companies, non-residents engaged in taxable activities) as a condition precedent to registration with the relevant tax authority. It also provides for the issuance of a Taxpayer Identification (Tax ID) to improve compliance with tax obligations.[1] The relevant tax authorities are also empowered to issue Tax ID to persons who neglect or fail to apply based on available information.[2] The NTAA ties the use of the Tax ID to many key transactions, such as opening or operating bank accounts, engaging in insurance, stockbroking, financial services, and entering into contracts with federal or state governments.[3]
Non-resident persons who make taxable supplies into Nigeria or derive income, profits or gains from Nigeria are also required to register and obtain Tax ID.[4] However, such a non-resident may not be required to register for and obtain a Tax ID where he/she derives only passive income from investments in the country.[5] In such a situation, the non-resident is only required to provide relevant information to the appropriate tax authority. The Act also mandates persons engaged in financial sector (banks, insurance) to demand the Tax ID from every taxable person in dealing with them.[6]
Taxable persons must also notify the tax authority of any change in their particulars (for example, business structure, ownership, address) within 30 days. Failure to do so may attract a penalty of ₦100,000 then ₦5,000 for each subsequent month.[7]
Legal Position on Bank Account Access
A major provision of the Act is the requirement for every taxable person to register and obtain a Tax ID. The Act goes further to mandate persons engaged in the financial sector to request a Tax ID from every taxable person doing business with them.
The Joint Tax Board (JTB) issued a public notice signed by Akpe E. Adohon, Head of Corporate Communications, on the 15th day of September, 2025, stating that Nigerians will not be denied access to their bank accounts or financial services as of January 2026 due to a lack of a Tax ID.[8] The statement explained that ongoing tax reforms aim to simplify compliance, eliminate multiple taxation, and grant exemptions to vulnerable individuals and small businesses, thereby lowering the tax burden for most Nigerians. The notice also stated that to ease compliance, a harmonised National Tax Identification system is being developed in collaboration with the FIRS, using the National Identification Number (NIN) for individuals and the Registration Number (RC) for businesses to generate Tax IDs automatically. The JTB assured the public to remain calm, as no disruptions to banking or financial transactions will occur, reaffirming its commitment to fair, inclusive, and business-friendly tax policies.[9]
It is important to note that failure to register and obtain a Tax ID attracts administrative penalties. Section 100 of the Act provides that:
A taxable person who fails or refuses to register for tax under section 4 of this Act, shall be liable to pay an administrative penalty of –
(a) ₦50,000 in the first month in which the failure occurs; and
(b) ₦25,000 for each subsequent month in which the failure continues.
In other words, while Section 8 NTAA requires financial institutions to request Tax IDs from taxable persons, regulators have clarified there will be no blanket account blocks on 1 January 2026. It only contemplates fines and administrative sanctions as the primary immediate penalties for registration defaults.
Practical Legal Realities
Generally, financial institutions are obliged to perform KYC and may require TIN/NIN information as part of customer onboarding or to meet AML/CFT expectations. Restrictions are even placed on accounts in line with contractual terms, CBN circulars or regulatory directives in certain circumstances.
Therefore, it is advised that taxable persons and businesses comply, in line with agreed terms of account opening. They are advised to verify whether they already have Tax IDs (TIN), as many NIN and BVN records have been automatically linked. Where no Tax ID exists, registration should be completed promptly through the JTB or FIRS channels, either online or at designated tax offices. It is also important to update bank KYC records by providing NIN and Tax ID details and retaining proof of submission. In cases where an account is restricted, taxpayers should immediately request written reasons from the bank, inquire about the specific legal or regulatory authority relied upon, escalate the issue internally, and seek urgent legal review where necessary.
Conclusion
A coordinated approach is essential to ensure the smooth implementation of the Tax ID framework without disrupting legitimate financial activities. Government and revenue authorities must provide clear operational guidance with set timelines and facilitate automatic linkage of TINs to NIN and CAC records. Taxpayers and businesses should take proactive steps by registering for Tax ID, reconciling their BVN, NIN, and CAC RC records, and retaining proof of compliance to safeguard against future disputes.
[1] S. 4 Nigeria Tax Administration Act, 2025
[2] S. 7 (3) Nigeria Tax Administration Act, 2025
[3] S. 8 (1) Nigeria Tax Administration Act, 2025
[4] S. 6 (1)
[5] ibid
[6] S. 8(2) Nigeria Tax Administration Act, 2025
[7] S. 112 Nigeria Tax Administration Act, 2025
[8]Joint Tax Board, ‘Tax IDs and Access to Bank Accounts’ Public Notice, 15th September, 2025 < https://jtb.gov.ng/2025/09/15/tax-ids-and-access-to-bank-accounts/ > accessed 26th September, 2025
[9] ibid
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