Accreditation before filing for Nigerian clients
Why a firm needs accreditation to represent and file for Nigerian tax clients, what may happen to returns filed without it, and how to control who files.
By Achekam · · 4 min read · For Accountants & audit firms in Nigeria
Launching soon. Some of the screens this article describes for Nigerian and Kenyan businesses are not reachable in Achekam yet. They are coming soon.
A client's return was prepared carefully, reviewed, approved by the client and filed before the deadline. Months later the client receives a notice treating the return as not filed. The figures were never in question. The problem was who filed it.
That scenario is the risk behind a short sentence in the NRS's guidance. Under the Nigeria Tax Administration Act, 2025, representing a taxpayer is not open to anyone who can operate a portal. A firm that files for Nigerian clients should know whether each person doing so holds the accreditation the law expects, and should be able to prove it.
Representation only with accreditation
The NRS FAQ, describing the position under the Nigeria Tax Administration Act, 2025, says a tax agent may represent a taxpayer only with accreditation from the relevant tax authority. The NRS frequently asked questions set this out alongside other practical consequences of the new administration Act.
Two points in that sentence deserve attention. Accreditation is given by "the relevant tax authority", so a firm acting before more than one authority should check the position with each one. And the restriction is on representation generally, not only on the act of pressing "submit". Corresponding with the authority on a client's behalf, attending meetings and handling objections are all forms of representation.
Returns filed without accreditation may not count
The same FAQ adds the consequence: returns filed by agents without accreditation may not be considered duly filed.
For a client, a return that is not duly filed risks being treated as a late or missing return, with whatever penalties and interest the law attaches to that. For the firm, it is a professional failure that the client is entitled to hold against it. The careful preparation and review that went into the return count for nothing if the filing itself is defective.
That makes accreditation a precondition of the filing service, not a detail. Engagement letters that promise to "file returns on the client's behalf" should be backed by a check that the people who will file can do so.
Where NRS guidance mentions accreditation
The NRS's guidance points taxpayers towards professionals with accreditation in several places, which tells firms how the authority sees their role:
| NRS guidance | What it says |
|---|---|
| Tax calendar page | Recommends using a tax professional or agent with accreditation for complex filings or compliance questions, and subscribing to tax authority alerts for changes to deadlines |
| Individual income tax page | Individuals file personal income tax returns on Form A, B or H, electronically through the NRS or their State Internal Revenue Service portal, on paper at the nearest office, or through a tax professional with accreditation |
| FAQ | Representation only with accreditation; returns by agents without it may not be duly filed |
The consistent message is that the NRS expects taxpayers who use an intermediary to use one with accreditation. Clients may begin to ask their firm to confirm it.
Representation before the Tax Appeal Tribunal
Disputes that reach the Tax Appeal Tribunal follow their own rules. The Tribunal's FAQ, restating its Procedure Rules 2021, says an appellant may appear in person or be represented by counsel or a chartered accountant or adviser. A partnership may act through one of its partners, and a company through one of its directors, officers or employees.
The Tribunal's list is about who may appear in the appeal, and it is separate from the question of who may represent the client before the tax authority. A firm handling a dispute from assessment to appeal should check both: accreditation for dealings with the authority, and eligibility to appear for the Tribunal stage.
Filing permission only for named people
Accreditation belongs to people, so the firm's systems should reflect named people rather than broad roles. Achekam is built that way for Nigerian filing.
No role in Achekam receives the Nigerian filing permission by default. A firm grants it to named people only. Partners receive every other Nigerian pack permission by default, but not this one.
Achekam does not file Nigerian tax returns itself. A person with the firm's NRS filing permission files on Rev360 and uploads the receipt, and a different person verifies it before the return counts as filed in Achekam. That is the natural point to enforce the accreditation rule: grant the filing permission only to people the firm has confirmed hold the accreditation, and remove it when that changes.
People join and leave the firm, and their accreditation changes with them. A firm administrator can invite colleagues by e-mailed link, give each a role, and suspend, reactivate or remove them, with the subscription's seat limit checked on every addition. When someone with filing permission leaves, removing or suspending them in Achekam should happen the same day, together with their access on the NRS's systems. How staff gain their own access to client profiles is covered in adviser access on Rev360, and the firm's own registration in registering on the NRS Tax Consultants Portal.
An accreditation register for the firm
Keep a short register, reviewed by a partner each quarter:
- Name of each person who files or represents clients before a Nigerian tax authority.
- Authority that granted the accreditation.
- Evidence held, and its date.
- Expiry or renewal date, if the accreditation has one.
- Filing permission in Achekam: granted or not, and by whom.
- Status at the last review.
Anyone on the register without current evidence should lose filing permission until it is produced. Anyone with filing permission who is not on the register is a gap to close immediately.
List every person who has filed a return for a Nigerian client in the past year. Check each one's accreditation with the relevant authority, record the result in the register, and align Achekam's filing permission with the list before the next return is filed.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
