The transition from FIRS to NRS is being executed in two main phases:

Phase 1 (From March 4, 2025):
This phase encompasses naira-denominated payments, automatic tax deductions, and financial oversight mechanisms. During this period, the existing Remita gateway remains in use. Ministries, Departments, and Agencies (MDAs) can access the new Tax Management and Revenue Administration System (TMRAS) using their Remita credentials through the Office of the Accountant-General of the Federation (OAGF) portal. Training sessions for MDAs have also been initiated. 

Phase 2 (From June 1, 2025):
Builds on the first phase by adding foreign‑exchange transaction processing, integration with MDAs’ ERP systems, and enabling budget modules for non‑budgetary agencies. 

Legal Framework & Empowerment

The NRS was formally established and empowered under the Nigeria Revenue Service (Establishment) Act, 2025, which:

Rebrands FIRS into NRS and positions it as a centralized authority for tax and non-tax revenue. 

Grants new financial autonomy, allowing the NRS to:

Borrow funds via loans or overdrafts.

Retain 4% of non-oil revenue collected, subject to appropriation by the National Assembly. 

Mandates accountability and transparency, including:

Annual audited financial statements to the Finance Minister, Federal Executive Council, and National Assembly.

Timeline for budget submissions and audit completion. 

Expands enforcement capabilities, including:

Power to assess and collect taxes on behalf of all government levels.

Enhanced cross-border enforcement capabilities.

Ability to recover unremitted revenue directly from MDAs. 

Introduces staffing flexibility, allowing secondments and deployment of personnel from other agencies. 

Key Challenges and Stakeholder Concerns

1. Inter‑Agency Tensions & Revenue Autonomy Risks
MDAs like Customs (NCS), FAAN, NCAA, NAMA, NUPRC, and others face loss of revenue-collection powers. There are fears of operational disruption due to funding uncertainties. 
Experts urge a phased, consultative rollout to avoid destabilizing port, maritime, aviation, and petroleum-related functions. 

2. Complex Legal and Institutional Overlaps
Overlapping mandates across key agencies like between NRS, NCS, and NUPRC and pending litigations over VAT and other taxes could lead to turf wars or implementation delays. 
Some analysts suggest forming a transition committee to harmonize institutional roles and resolve legal ambiguities. 

3. Infrastructure & Digital Integration Hurdles
The NRS depends heavily on digital systems e‑filing, e‑invoicing, database linkages (e.g., NIN/BVN), and enforcement platforms. However:

Identity systems remain fragmented across registries.

Only about 60% of adults have linked NIN to bank accounts.

Cybersecurity is a pressing concern, with over 5,000 reported annual attacks. 
And many small businesses lack digital tools only 38% reportedly use digital accounting solutions. 

4. State–Federal Dynamics and Fiscal Equity
The shift in VAT distribution models and centralization of revenue functions has sparked concerns that states especially less economically active ones might lose their revenue base. 
Political resistance from some state governors is emerging, and equity in distribution remains a flashpoint.

5. Capacity Building & Public Engagement
Building trust will require:

Mass sensitization campaigns in local languages.

Simplified filing interfaces for low-literacy users.

Visible service improvements tied to taxpayer contributions. 
Additionally, the Tax Appeal Tribunal and Office of the Tax Ombudsman need to be established and staffed swiftly, along with the revamped NRS leadership. 

Summary Overview

Phased Rollout Phase 1 (Mar 2025): naira payments, TMRAS access. Phase 2 (Jun 2025): forex, ERP integration, budgets for MDAs.
Legal Empowerment NRS formalized with expanded authority, retention of 4% non-oil revenue, and borrowing powers.
Accountability Financial transparency mandated—audits, budget submissions, and reporting deadlines legislated.
Institutional Risks Loss of autonomy for revenue-generating agencies; need for coordination to prevent operational breakdowns.
Digital Infrastructure Integration and cybersecurity remain weak; digital literacy gaps may slow adoption.
State Equity Concerns Redistribution of VAT and centralized functions may alienate states; requires equitable frameworks.
Capacity & Trust Critical to train officers, run outreach campaigns, and establish complaint and appeals mechanisms.

Final Thoughts

The NRS rollout is well-structured legally and technically, featuring a careful two-phase transition. However, its success hinges on addressing:

Institutional resistance and potential operational disruptions.

Gaps in digital infrastructure and cybersecurity readiness.

Equitable fiscal arrangements between the federal and state levels.

Public trust through transparency, service delivery, and capacity-building.

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