AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Choose the law and forum where you can actually enforce payment. For a small contract with a Lagos client, Nigerian law and Lagos courts let you use the Lagos Small Claims Court; for larger work, mediation then arbitration is common, because Nigeria's Arbitration and Mediation Act 2023 incorporates the New York Convention for awards, while a South African court judgment must be registered in Nigeria within strict limits.
Most freelance contracts end with two clauses people skim: which law governs the contract, and where disputes are resolved. When you are in South Africa and your client is in Nigeria, those clauses decide whether a dispute is something you can act on or something you write off. This guide explains the common choices and the trade-offs for a South African freelancer.
Two different clauses
- Governing law
- Which country's law interprets the contract: what the terms mean, whether there was a breach, what damages are.
- Dispute resolution (forum)
- Where and how a dispute is decided: the courts of a named place, or arbitration, or mediation first.
They can point to different places, but mixing them (South African law decided by a Lagos court, say) adds cost, because the court must hear evidence on foreign law. For a small freelance contract, keeping them together is usually simpler.
The common choices
| Choice | For you | Risks |
|---|---|---|
| South African law and courts | Familiar to you and your lawyer | A judgment must then be registered in Nigeria to enforce against Nigerian assets |
| Nigerian law and courts (e.g. Lagos) | Enforcement happens where the client and its money are; small claims possible | You are dealing with an unfamiliar system from abroad |
| Arbitration (with a named seat and rules) | Neutral, private, and awards travel well internationally | Can be expensive for small sums unless scaled down |
| Mediation first, then courts or arbitration | Cheap way to settle most disputes early | Adds a step if the client is simply refusing to pay |
Why enforcement drives the choice
The question that matters is where the client's money is. Global Legal Post's April 2026 guide to enforcement in Nigeria explains that foreign judgments are enforced under the Reciprocal Enforcement of Judgments Ordinance 1922 and the Foreign Judgments (Reciprocal Enforcement) Act 1990, that a judgment must generally be registered within 12 months unless the court extends time, and that registration can be refused on grounds including lack of notice, lack of jurisdiction, fraud, public policy, or a judgment that is not final or not for a sum of money. The guide gives no list of reciprocating countries, so do not assume a South African judgment registers easily; ask a Nigerian lawyer before relying on it.
Arbitration awards follow a different track. The same guide says section 60 of the Arbitration and Mediation Act 2023 incorporates the New York Convention for awards made in Convention states arising from commercial relationships, with its own limited refusal grounds. Mondaq's summary of the 2023 Act adds that mediated settlements are binding and enforceable, and that an emergency arbitrator can be appointed within two business days of an application.
A practical default for freelancers
- Small contracts with a Lagos client: Nigerian law and Lagos courts, so an unpaid invoice can go to the Lagos Small Claims Court (claims up to ₦5,000,000; see options when a Nigerian client is not paying).
- Larger or longer contracts: mediation first, then arbitration with a named seat, rules and a sole arbitrator to keep costs down. See arbitration with a Nigerian client.
- Client with assets in South Africa: South African law and courts may work, since you can enforce locally.
Sample wording to discuss with a lawyer
"This agreement is governed by the laws of Lagos State, Nigeria. The parties will first try to resolve any dispute by negotiation for 14 days, then by mediation. Any dispute not resolved within 30 days of a written notice may be referred by either party to the courts of Lagos State." This is an example only; have a lawyer adapt it to your contract.
Other clauses that work with it
- Currency and payment date, so the amount owed is clear: see an FX clause for retainers.
- Late-payment interest at a stated rate.
- Notices: email addresses that count for formal notice, so a demand letter is validly served.
- Ownership of work passing on full payment.
- Signatures by someone with authority at the client company, with the company's registered name and RC number.
Raise these clauses early. Nigerian companies often send their own template, which may name Nigerian law and courts already; that may suit you for a small job. Where the client's template names arbitration in a city you cannot easily reach, or courts in a different state from where the client operates, ask for a change before signing, while you still have leverage. A clause you can use is worth more than one that sounds impressive.
A broader version of this topic for Nigerians in any country is in governing law in contracts with Nigerian clients. This is information, not legal advice.
Where Pryme fits
Pryme invoicing lets you reference the contract on every invoice, and a verifiable receipt or statement through VerifyDoc.ai gives you records the other side can check are unaltered, which helps if a payment dispute ever reaches mediation or court.
Questions people ask
Which law should govern my contract with a Nigerian client?
Pick the law and forum where you could enforce payment. For small contracts with a Lagos client, Nigerian law and Lagos courts are often the practical choice.
Can I enforce a South African judgment in Nigeria?
Only by registering it in Nigeria, generally within 12 months, and registration can be refused on grounds such as lack of notice or jurisdiction. Ask a Nigerian lawyer first.
Is arbitration worth it for a freelancer?
For larger contracts, often yes; Nigeria's 2023 Act incorporates the New York Convention for awards. For small invoices, court or small claims is usually cheaper.
What is the difference between governing law and jurisdiction?
Governing law decides how the contract is interpreted; the dispute or jurisdiction clause decides where and how a dispute is heard.
Sources
- Global Legal Post (Streamsowers & Kohn): enforcement of judgments, Nigeria (11 Apr 2026) · accessed Oct 2026
- Mondaq: salient provisions of Nigeria's Arbitration and Mediation Act 2023 · accessed Oct 2026
- Lagos State Practice Direction on Small Claims Court 2023 (Lagos MEPB copy, Dec 2025) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.