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
The naira is legal tender, and section 20(5) of the CBN Act makes it an offence to refuse naira as a means of payment. A CBN circular discouraged pricing in foreign currency, but Templars' May 2025 analysis says no statute bans quoting or contracting in dollars if you accept naira when offered. For a Nigerian client, the safer course is to invoice in naira, or to show a naira equivalent at a named rate and date and accept payment in naira.
Consultants, software firms, importers and real estate agents often think in dollars because their costs are in dollars. When the client is also in Nigeria, invoicing in dollars raises a legal and a practical question. This explainer sets out the position as information, not legal advice.
The legal tender rule
The naira is Nigeria's legal tender under the Central Bank of Nigeria Act 2007. Section 20(5), as quoted by Templars, makes it an offence to refuse to accept the naira as a means of payment, punishable by a fine of ₦50,000 or six months' imprisonment. A proviso lets the CBN prescribe circumstances in which other currencies may be used.
Separately, the CBN issued a circular titled "Currency Substitution and Dollarisation of the Nigerian Economy" (BSD/DIR/GEN/LAB/08/013) which purported to make pricing in foreign currency illegal and said business offers and acceptances should be in naira.
Is a dollar invoice illegal?
The May 2025 Templars paper argues that no statute criminalises listing prices or contracting in a foreign currency, and that quoting in dollars is not the same as refusing naira. It notes that Nigerian courts generally enforce foreign-currency contracts and can award foreign-currency sums, with a naira equivalent for enforcement.
Enforcement has still happened. The same paper discusses FHC/L/353C/2025, where defendants pleaded guilty to refusing naira under section 20 of the CBN Act after selling a bracelet for dollars. The practical risk is in refusing naira, not in writing a dollar figure.
For a business, the takeaway is that the legal position is argued, and the CBN's stated policy is against dollar pricing between Nigerians. Courts and regulators can take a different view from a law firm's analysis, so build your invoicing to avoid the question rather than to win it.
When dollar invoicing is common and accepted
- Exports and services to clients outside Nigeria. See invoicing a foreign client.
- Contracts where both parties have domiciliary accounts and agree to settle in foreign currency, such as some oil and gas and shipping contracts.
- Pass-through costs priced in dollars (imported equipment, foreign software licences), where the invoice shows the dollar cost and the naira amount payable.
Even then, the client may not have dollars. Do not make a contract depend on payment in dollars alone if the client is in Nigeria.
How to show naira equivalence
- State the price in naira as the amount payable, or both currencies with naira clearly payable.
- Name the exchange rate source and date (for example, "converted at the [named reference] rate published on the invoice date"). Do not leave the rate vague.
- Say what happens if payment is late and the rate moves, for example that the naira amount is recalculated on the payment date.
- Give naira payment details, plus dollar details if the client chooses to pay in dollars.
Worked example
Example: a firm supplies a licence that costs it $2,000. The invoice shows "US$2,000, payable in naira at the [named reference] rate published on the payment date, or in US$ to our domiciliary account". If the client pays in naira, the firm multiplies 2,000 by that day's published rate, states the naira figure on the receipt, and accepts the transfer. No rate is fixed in advance, so neither side gains from a stale figure. Check the current rate on the day; we do not quote one here because it changes daily.
Contract wording to consider
If you must quote in dollars because your costs are in dollars, put the currency mechanics in the contract, not only on the invoice. Useful clauses cover:
- Currency of account and currency of payment. The price may be expressed in dollars while the client may pay the naira equivalent.
- Rate source. A named published reference rate, and the day it is taken (invoice date or payment date).
- Rate movement. Who bears the change if payment is late, and whether a top-up invoice will be issued.
- Bank charges. Who pays charges on a foreign-currency transfer, if the client chooses to pay in dollars.
Have a lawyer review this wording for large contracts. The aim is a contract that never asks the client to refuse naira and never leaves the naira amount open to argument.
Tax and records
Keep your books in naira and record the rate you used for each invoice. Under the Nigeria Tax Act 2025, a VAT invoice must show the gross amount and VAT charged; showing these in naira avoids confusion for your client's tax return. If e-invoicing applies to you, follow the format your access point provider uses. Also see can a Nigerian business price in dollars.
Where Pryme fits
A Pryme Business Account holds NGN, USD, GBP and EUR with local account details for each, so you can receive a client's naira or dollar payment without forced conversion. Swap converts only when you choose, showing the rate first. See business multicurrency.
Questions people ask
Is it illegal to invoice in dollars in Nigeria?
The CBN Act makes refusing naira an offence. Templars argues no statute bans quoting or contracting in dollars, but the CBN has discouraged dollar pricing. Accept naira whenever it is offered. This is not legal advice.
Can a Nigerian company pay another Nigerian company in dollars?
Some do between domiciliary accounts by agreement, especially in oil, gas and shipping. Neither party should refuse naira if the other offers it.
What is the penalty for rejecting naira?
Section 20(5) of the CBN Act provides a fine of ₦50,000 or six months' imprisonment, as quoted by Templars.
How do I convert a dollar invoice to naira?
Name the rate source and date on the invoice, show the naira amount payable, and say how late payment is handled if the rate moves.
Sources
- Templars: Pricing in Foreign Currency Under Nigerian Law (May 2025) · accessed Oct 2026
- Mondaq: Examination of the VAT provisions under the Nigeria Tax Act 2025 (28 May 2026) · 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.