Crypto exchanges, take note: Nigeria now wants a monthly report on every transaction

If you run, advise, or invest through a Virtual Asset Service Provider (VASP) in Nigeria, Section 25 of the Nigeria Tax Administration Act (NTAA), 2025 changes what “compliance” means for you. Here is what it says, and what it means in practice.

What Section 25 actually says in Context

Section 25 creates a standalone filing obligation for VASPs and for anyone engaged in the exchange, custody, or management of virtual assets like cryptocurrency exchanges, wallet providers, and/or digital asset custodians.

The key features of Section 25:

•      No notice is needed. The return must be submitted “with or without notice”. A VASP cannot wait to be asked to file returns. It is a standing, self-triggering obligation.

•      It’s in addition to other returns. This sits on top of the ordinary income tax and VAT returns already required under sections 11 and 13 of the Act.

•      It’s granular, not aggregated. The relevant tax authority does not just want turnover figures. It wants a transaction-level account.

What has to go into the Tax Return. For every reporting period, a VASP must disclose:

•      A description of the virtual asset service provided such as exchange, sale, or transfer

•      The date of each transaction

•      The type and value of the virtual assets involved

•      The sales value of those virtual assets

•      The customer’s name, address, phone number, email, and Tax ID, including their National Identification Number where the customer is an individual. In effect, every trade on a Nigerian VASP platform now carries a tax paper trail map to a verified identity.

Non-compliance is not a slap on the wrist, compliance here is cheaper than defaulting. Under section 109 of the NTAA, a defaulting VASP faces:

•      An administrative penalty of ₦10,000,000 for the first month of default, and ₦1,000,000 for every subsequent month the default continues

•      Exposure to license suspension or revocation by the Securities and Exchange Commission (SEC)

Practical application: what this means for VASPs and their advisers

The Nigeria Revenue Service has since built on this statutory provision’s with its Guidelines on the Taxation of Virtual Assets (issued 31 July 2026), which explains the operational detail:

•      Registration first. VASPs, and the customers dealing on their platforms, need a Tax Identification Number before the reporting obligation can even be discharged properly.

•      KYC becomes a tax control, not just an AML one. Verifying a customer’s TIN and NIN is now as much a tax administration and compliance task as also a regulatory one.

•      Withholding responsibilities. VASPs are being positioned as intermediaries/agents required for deducting and remitting certain taxes on behalf of users in specified circumstances, even though the underlying taxpayer remains responsible for their own annual return.

•      Gains and income are in scope, not just turnover. Disposal gains, staking and mining rewards, DeFi yields, and virtual assets received as payment are treated as taxable when received, therefore the monthly transaction return under Section 25 will increasingly need to tie back to income and gains reported elsewhere.

A short checklist for VASPs and their tax advisers

•      Confirm registration with both the SEC and the relevant tax authority

•      Build a monthly reporting workflow now, don’t wait for a request from the tax authority

•      Capture transaction-level data (type, date, value, sales value) at source, not after the fact

•      Verify and store customer TIN/NIN at onboarding, not retroactively

•      Reconcile monthly VASP returns against annual income tax filings for gains, staking, mining, and DeFi income

•      Review internal systems and reporting tools against the NRS Guidelines, not just the bare text of Section 25

•      File promptly and on time.

The bottom line

The same transparency and reporting requirements with banks and other regulated financial intermediaries now applies to Nigeria Virtual assets sector too . For VASPs, the compliance obligation is monthly, not annual and the penalties under section 109 are designed to make default expensive from day one.

Sources: Nigeria Tax Administration Act, 2025 (sections 25 and 109); NRS Guidelines on the Taxation of Virtual Assets (31 July 2026).

Always consult with a licensed Tax Consultant, this article does not constitute tax advice.

#NIgeriaTax  #VirtualAssets  #Crypto  #TaxCompliance  #NTAA2025  #VASP  #FinTech  #TaxConsulting #DeFi income #NRS Guidelines