Practical guidance drawn from Dr. Tunde Lemo, Dotun Adekunle (OPay), Tim Siloma (PwC), Olamide Obajimi (Ed Tax Practices Group), and Dr. Ayodele Zubair (LIRS) | FintechNGR Outlook Webinar, 24 February 2026

Nigeria’s new tax regime is in effect. For fintech founders, operators, and boards, the question is no longer whether to act — it is whether you act before the pressure forces you to. Moderator Toyin Olufon closed the FintechNGR 2026 Outlook Webinar with a direct challenge: “I encourage you not to disembark with just notes, but with strategy; not just insight, but action points.” Every step below is drawn directly from the recommendations of speakers at the webinar.

Step 1: Conduct a Full Tax Impact Assessment

Dr Tunde Lemo, former Deputy Governor of the CBN, made this the priority. Identify your exposure areas under the new regime — capital gains treatment, the 15% minimum effective tax rate, and VAT deductibility. Review current pricing models to confirm tax obligations are correctly reflected in your unit economics. This is not a task for a junior team member. As Dr Lemo stated: “Tax must now be at the centrepiece of all strategic planning to avoid profit erosion.” A board-level review is appropriate.

Step 2: Run a Retrospective Compliance Review

The new regime did not erase historical obligations. Dr Lemo specifically recommended a tax risk assessment covering pre-reform years. For any fintech fundraising, preparing for acquisition, or in investor due diligence, historical tax exposure is a deal-breaker. Find and address it now — not when a third party finds it during a data room review.

Step 3: Migrate Fully to the LIRS eTax Platform

LIRS Chairman Dr Ayodele Zubair was unambiguous: migrate to eTax now and migrate completely. Every taxpayer has a personal account showing their full tax history and all payments made on their behalf. Withholding tax remittance schedules must include the taxpayer ID of every individual covered — incomplete uploads are rejected. Banks have been instructed not to accept withholding payments without contractor details. The legacy system is being shut down. Also check your withholding tax credits: if older remittances were submitted without your taxpayer ID, credits owed to your business may not have been applied to your account. Log in and verify.

Step 4: Audit All Commercial Contracts

Olamide Obajimi of Ed Tax Practices Group flagged two provisions that demand immediate contract review. First, stamp duty: check whether it has been explicitly allocated in every current and pending agreement. If not, add a clause before signing — the party that ends up bearing it unplanned will feel it in their margins. Second, cross-border VAT: confirm whether your offshore technology, infrastructure, and platform providers are registered for Nigerian VAT. If they are not, your company bears the liability. This requires active due diligence, not assumptions.

Step 5: Obtain Binding Rulings on Ambiguous Transactions

Under the new Nigerian Tax Administration Act, a written ruling from the tax authority is now legally binding on that authority. Obajimi described this as the most underutilised protection available to fintechs. If your business model involves unclear tax treatment — particularly in crypto, peer-to-peer lending, embedded finance, or cross-border digital services — do not scale without first obtaining a ruling. Engage qualified advisers to prepare the application, submit it to the relevant authority, and preserve the written ruling as part of your compliance documentation.

Step 6: Rebuild Your Architecture for Tax Adaptability

Dotun Adekunle, COO of OPay, offered a practical principle for payment platforms, wallets, and marketplace businesses: build flexibility in from day one. Implement modular fee structures so tax rates can be updated without re-engineering the core product. Maintain clean separation between revenue and pass-through funds. Build configurable tax logic in a transaction rules engine. Ensure every transaction is categorised, taxed correctly, and backed by defensible records. For founders launching today, Adekunle was direct: you are in a privileged position — build the right architecture from inception rather than retrofitting under pressure.

Step 7: Build Board-Level Tax Capacity

Dr. Lemo’s final recommendation: tax governance is now a board responsibility, not a finance team responsibility. Establish a clear tax strategy at the board level. Schedule regular compliance reviews throughout the year, not just at year-end. Build meaningful tax expertise on the board through training or a dedicated adviser. Foster proactive relationships with regulators and participate in industry consultations — shaping the framework is better than reacting to it.

“The startups and fintechs that understand their obligations, build tax-efficient structures from the ground up, and incorporate tax planning into their unit economics and fundraising models will have structurally stronger businesses.” — Dr Stanley Jacob, President, FintechNGR

The bottom line: The new tax regime is more demanding than what came before — but also more predictable, more transparent, and more supportive of compliant actors. The fintechs that move first will not merely be compliant. They will be more fundable, more stable, and more scalable than peers who treat tax as a problem to solve later. Later, in this environment, is expensive.