September 2026 is a useful point for Nigerian businesses to review whether their compliance systems have actually caught up with the major legal and regulatory changes now in operation. The most important issues are not isolated filing dates; they are the controls, records and decisions that determine whether the business can comply consistently.
1. The 2026 federal tax framework is now operational
The new tax laws proceeded on the announced 1 January 2026 commencement timetable. Businesses should ensure that tax calendars, templates, correspondence, responsibilities and internal guidance reflect the current framework and the Nigeria Revenue Service rather than relying on pre-2026 processes.
Action: Review every recurring tax workflow and identify any assumptions, forms or internal references carried over from the former regime.
2. VAT small-business relief requires more than a turnover check
The Nigeria Tax Administration Act defines a small business using both turnover and fixed-asset criteria and expressly excludes professional-services businesses from that classification. This means a professional firm should not conclude that it is outside VAT obligations simply because turnover is below ₦100 million.
Action: Document the basis for the business’s VAT treatment and monitor whether its classification changes during the year.
3. Audit and assurance appointments now require an FRC register check
The Financial Reporting Council’s National Audit and Assurance Firms Register became fully operational from 1 April 2026. Entities requiring regulated audit or assurance work should verify the relevant firm and signing professional before appointment and retain evidence of that verification.
Action: Add FRC registration verification to audit-committee, board or management appointment procedures.
4. Data protection has moved from policy wording to operational compliance
The Nigeria Data Protection Act 2023 is supported by the General Application and Implementation Directive issued by the Nigeria Data Protection Commission in March 2025 and effective from September 2025. Businesses should now be able to explain what personal data they hold, why they process it, who receives it, how it is protected and how data-subject requests or incidents are handled.
Action: Review privacy notices, vendor arrangements, access controls, retention practices and breach-response procedures against actual operations.
5. Sustainability-reporting readiness should start before mandatory adoption
In February 2026, the FRC released an amended sustainability-reporting Roadmap and SRG 1, providing clearer implementation guidance for IFRS S1 and IFRS S2. The voluntary period runs through 2027; public-interest entities move into mandatory adoption from 2028 and SMEs from 2030, with early adoption encouraged.
Action: Determine the entity’s roadmap category and start the board, gap-analysis, implementation-plan and data-readiness work before reporting becomes compulsory.
6. CAC annual-return processes are still evolving on iCRP
The Corporate Affairs Commission’s current iCRP notice states that annual-return filing is available for business names registered before July 2025 while the Commission works on an AI-powered process intended to cover both older and newer business names. Portal procedures should therefore be checked at the actual filing date rather than assumed from an earlier workflow.
Action: Review annual-return backlogs, post-incorporation changes and corporate records, and confirm the current CAC portal process before promising a completion timeline.
Management’s September review
- Which 2026 tax processes still use old assumptions?
- Is the VAT position supported by the statutory classification?
- Are regulated audit or assurance providers properly verified?
- Can the business demonstrate operational data-protection controls?
- Has sustainability-reporting readiness been assigned to management and the board?
- Are CAC records and annual returns current, with evidence retained?
Source trail
Primary references include the Presidency’s 30 December 2025 commencement statement on the new tax laws, the Nigeria Tax Administration Act 2025, Financial Reporting Council notices and 2026 sustainability-reporting publications, Nigeria Data Protection Commission guidance, and the current CAC iCRP public notice.
Publication note: This watch is a management briefing, not a substitute for advice on a specific entity. Laws, thresholds, portal procedures and regulator guidance should be checked against the facts and date of the relevant transaction or filing.