Key points

• In Nigeria, Form M records an import transaction; it is not proof that money has been sent to an overseas supplier.
• For Nigerian import payments, the CBN’s January 2022 e-invoicing framework requires an electronic invoice authenticated by an authorised dealer bank and the relevant payment documents.
• Nigeria Customs Service service standards published in August 2025 list different documents for Form M and PAAR, so the payment file must match the transaction stage and the goods.
• Before a payment request is submitted in Nigeria, the supplier name, invoice, bank details, Form M records and shipment documents must be consistent.

In Nigeria, opening Form M begins an import file but does not itself pay an overseas supplier. The payment is requested separately through an authorised dealer bank, which reviews the authenticated electronic invoice and the transaction documents required for the specific import file, as at September 2026.

Key takeaways

• In Nigeria, Form M records an import transaction; it is not proof that money has been sent to an overseas supplier.
• For Nigerian import payments, the CBN’s January 2022 e-invoicing framework requires an electronic invoice authenticated by an authorised dealer bank and the relevant payment documents.
• Nigeria Customs Service service standards published in August 2025 list different documents for Form M and PAAR, so the payment file must match the transaction stage and the goods.
• Before a payment request is submitted in Nigeria, the supplier name, invoice, bank details, Form M records and shipment documents must be consistent.

Form M starts the import file; it does not send money to the supplier

In Nigeria, Form M is an import-registration record used in the trade process; it does not confirm that a foreign supplier has received funds. As at September 2026, the Central Bank of Nigeria (CBN) framework separates the import file, customs processing and the payment instruction handled through an authorised dealer bank.

What Form M records in the Nigerian import process

Form M is the import-registration form through which a Nigerian importer opens an import file with an authorised dealer bank. An authorised dealer bank is a bank authorised within the CBN foreign-exchange framework to handle the relevant trade and foreign-exchange documentation. The official Nigeria Trade Portal Form M manual describes a workflow in which the importer submits the application and the bank validates it before the related processing continues.

Form M therefore connects the commercial purchase to Nigeria’s import-control process. It is not a payment receipt, a supplier credit confirmation or a substitute for a payment instruction. BankiPay does not replace Form M, an authorised dealer bank, Nigeria Customs Service procedures or any CBN compliance review; our role in an international supplier-payment journey is distinct from Nigeria’s import-registration process.

Registration, customs processing and payment are different events

A Nigerian import transaction can involve three connected but different events: registering the import through Form M, completing customs-related processing such as a Pre-Arrival Assessment Report (PAAR) where applicable, and asking the authorised dealer bank to process payment. Treating an approved or registered Form M as evidence that the supplier has been paid can create avoidable confusion between the importer, the bank and the supplier.

On 15 May 2026, the CBN announced the Fourth Edition of its Foreign Exchange Manual. Because trade documentation and bank operating requirements can change, the authorised dealer bank remains the named institution to confirm the current requirements for the individual Nigerian import file.

Build one consistent file before asking the bank to make the payment

For a Nigerian import payment, the practical objective is one consistent file: the supplier identity, goods description, value, payment terms and supporting documents must not contradict each other. The Nigeria Customs Service lists different documents for Form M and PAAR in its August 2025 service standards.

Documents listed for Form M and PAAR are not identical

A proforma invoice is the supplier’s preliminary sales document stating the proposed goods, quantity, price and commercial terms before the final commercial invoice. In the Nigeria Customs Service service standards published in August 2025, the documents listed for Form M include a proforma invoice, an insurance certificate and applicable regulatory certificates.

For PAAR processing, the Nigeria Customs Service August 2025 standards list the registered Form M, applicable regulatory certificates, a bill of lading, air waybill or waybill, a commercial invoice, a packing list and a certificate of origin. A commercial invoice is the supplier’s final sales document for the goods supplied; a packing list is the itemised description of the packages and their contents.

Product controls can add documents

In Nigeria, product-specific controls can require certificates beyond the documents listed in a general service standard. Food, medicines, chemicals, regulated equipment and other controlled goods may involve requirements from the relevant Nigerian regulator. The Nigeria Customs Service and the authorised dealer bank can identify the customs and payment-file documents, while the applicable product regulator confirms its own certification requirements.

At BankiPay, our payment preparation process does not remove those Nigerian requirements. Keeping the commercial file complete before a payment request is raised gives the importer and supplier a shared record of what the payment relates to.

Open Form M through an authorised dealer bank

In Nigeria, an importer opens Form M through an authorised dealer bank, which validates the file before the relevant CBN and Nigeria Customs Service processes proceed. A bank review is not an automatic approval of the import file, foreign exchange, customs treatment or supplier payment.

Each participant has a separate role

The Nigerian importer supplies the commercial and regulatory information for the Form M application. The authorised dealer bank validates the file in its role within the CBN process. The relevant CBN and Nigeria Customs Service processing then follows according to the transaction and the applicable controls. The Nigeria Trade Portal’s Form M application manual, published in 2021, documents this bank-validation workflow and the handling of application information.

For a Nigerian importer, the useful question is not merely whether Form M has been opened. The useful question is whether the named supplier, invoice terms, goods description and documentary evidence remain aligned from Form M to the later payment request and shipment records.

Use the supplier identity that matches the transaction

Under the CBN circular dated 24 August 2020, authorised dealers were directed to open Forms M and related payment arrangements in favour of the ultimate supplier rather than a buying company, agent or other third party. A CBN clarification dated 18 November 2020 explains that the ultimate supplier is the direct party selling the goods to the importer, whether that party is the manufacturer or an internationally recognised buying company, supplier or agent.

The same CBN clarification of 18 November 2020 states that the supplier name should match the beneficiary on the Form M, invoice, bill of exchange, letter of credit instrument and other relevant transaction documents. Where the contractual seller is not the manufacturer, the authorised dealer bank can explain how the CBN rule applies to the supplier named in the Nigerian import file.

Request the supplier payment as a separate bank step

In Nigeria, payment to an overseas supplier is a separate request made through the authorised dealer bank after the importer has prepared the relevant payment file. Form M registration alone does not establish that funds have moved, that the bank has accepted the payment instruction or that the overseas beneficiary has been credited.

Submit a payment instruction, not only a Form M reference

A payment request identifies the beneficiary, beneficiary bank details, amount, currency, purpose and supporting documents. The importer presents that request through the authorised dealer bank instead of treating the Form M reference as a payment confirmation. The bank can query inconsistencies, request clarification or apply compliance checks before deciding how to process the instruction.

Where BankiPay is used for an international supplier payment, BankiPay still does not turn Form M into a payment receipt. Our payment records can support the importer’s audit trail, while the Nigerian authorised dealer bank and the applicable authorities retain their respective roles in the import and foreign-exchange process.

The authenticated electronic invoice is a specific CBN payment requirement

For Nigerian import payments, the CBN e-invoicing regulation issued on 21 January 2022 states that an importer may not effect payment to a foreign supplier unless the electronic invoice has been authenticated by an authorised dealer bank and presented with the relevant payment documents. The CBN introduced the framework for import and export transactions effective from 1 February 2022.

An authenticated electronic invoice is the foreign supplier’s electronic invoice that has passed the relevant authorised dealer bank authentication step under the CBN e-invoicing framework. It is not the same thing as PAAR: the e-invoice belongs to the CBN import-payment and trade-documentation framework, while PAAR belongs to the Nigeria Customs Service import process.

Keep the payment file connected to PAAR, shipment and customs records

In Nigeria, PAAR, shipment records and payment documents can concern the same import but perform different functions. Keeping them connected helps the importer explain the goods, supplier, value and shipment stage when the authorised dealer bank or Nigeria Customs Service asks for a document review.

What PAAR means in the Nigerian import process

PAAR is the Pre-Arrival Assessment Report used in the Nigeria Customs Service import process. The Nigeria Customs Service service standards published in August 2025 give an administrative benchmark of two days and no fee for PAAR processing. This is an administrative service benchmark, not a guaranteed end-to-end timetable for shipment release, payment execution or receipt by the overseas supplier.

The Nigeria Customs Service August 2025 document lists the transport document, commercial invoice, packing list and certificate of origin for PAAR, alongside the registered Form M and applicable certificates. Those records become relevant at the shipment and customs stage where applicable; not every import follows an identical documentary path.

Administrative benchmarks do not equal payment timelines

The Nigeria Customs Service August 2025 standards list a one-day benchmark and no fee for Form M registration. The same standards list a two-day benchmark and no fee for PAAR. These published benchmarks do not include the time needed for bank review, document queries, foreign-exchange processing, supplier-bank processing, shipment documents or compliance checks.

BankiPay covers more than 154 destinations, but destination coverage does not replace the documentary requirements of a Nigerian import file. Before preparing a payment request, use the supplier’s destination, the transaction currency and the documents requested by the authorised dealer bank as separate checks.

Track the payment and resolve a document mismatch without resubmitting blindly

For a Nigerian supplier payment, tracking begins with the payment-instruction reference and ends with retained evidence of the bank or payment outcome. If the file is queried, identifying the exact inconsistent document is more useful than sending duplicate instructions or changing records without the bank’s direction.

A practical payment-status process

1. Confirm the payment-instruction reference with the authorised dealer bank handling the Nigerian import-payment file.
2. Confirm with the overseas supplier that the beneficiary name, account number or IBAN where applicable, bank name and other bank details match the payment instruction.
3. Retain the payment instruction, authenticated electronic invoice, bank correspondence and any payment evidence with the Form M and shipment records.
4. If the file is queried, ask the authorised dealer bank to identify the document, field or inconsistency that requires correction before submitting an amended record.

Where a BankiPay payment is available for the supplier’s destination, our payment-tracking page can be used alongside the records retained for the Nigerian import file. A platform tracking reference does not replace confirmation from the authorised dealer bank on a Form M, e-invoice or PAAR query.

Material changes can require another review

In Nigeria, a change to the supplier identity, invoice value, goods description, beneficiary bank details or payment terms can affect the consistency of the Form M, e-invoice, payment request and customs records. The Nigeria Trade Portal Form M manual published in 2021 includes amendment mechanics, and the authorised dealer bank can identify whether a proposed change requires review in the current file.

Do not assume that a corrected invoice can simply be attached to an earlier instruction without impact on the rest of the file. The appropriate route is to ask the authorised dealer bank which record must be corrected and which supporting evidence it requires for the Nigerian import transaction.

What a Nigerian importer should confirm before committing to a supplier payment

Before a Nigerian importer commits to an overseas supplier payment, the key check is documentary alignment: the supplier, goods, value, payment terms and bank details must tell the same transaction story. A complete file supports a payment request, but it does not predetermine how the authorised dealer bank or compliance processes will treat it.

Payment-file checklist

• The direct contractual supplier is named consistently across the Form M, invoice, payment instruction and related records, in line with the CBN clarification dated 18 November 2020.
• The proforma invoice, commercial invoice and electronic invoice accurately identify the goods, price, currency and payment terms for the Nigerian import transaction.
• The beneficiary bank details correspond to the supplier named in the file.
• The applicable Nigerian product certificates have been identified with the relevant regulator and the authorised dealer bank.
• The Form M status and, where applicable, PAAR and shipment-stage records are available and consistent.
• The electronic invoice has been authenticated by the authorised dealer bank and is presented with the relevant payment documents under the CBN January 2022 framework.
• Payment evidence and correspondence are retained with the import records.

The distinction that matters in Nigeria is simple: a complete import file supports a supplier-payment request, but the authorised dealer bank and applicable compliance checks determine whether and how that request is processed. Before you prepare the payment request, check whether BankiPay covers your supplier’s destination.

In summary

• In Nigeria, Form M records an import transaction; it is not proof that money has been sent to an overseas supplier.
• For Nigerian import payments, the CBN’s January 2022 e-invoicing framework requires an electronic invoice authenticated by an authorised dealer bank and the relevant payment documents.
• Nigeria Customs Service service standards published in August 2025 list different documents for Form M and PAAR, so the payment file must match the transaction stage and the goods.
• Before a payment request is submitted in Nigeria, the supplier name, invoice, bank details, Form M records and shipment documents must be consistent.

This article provides general information, current as of September 2026. It is not legal, tax or investment advice. Exchange-control rules and reporting obligations differ by country and change over time. For your own situation, refer to your account-holding bank and to the Central Bank of Nigeria, the Nigeria Customs Service and the competent product regulator in Nigeria.