Effective 1 January 2026, Nigeria’s new tax code — the Nigerian Tax Act (NTA) 2025 — consolidates and updates the country’s rules on stamp duty, absorbing the earlier Electronic Money Transfer Levy (EMTL) into a single statutory framework. The change clarifies who bears the cost of small electronic levies and simplifies treatment of several common legal instruments.
Nigeria stamp duty: who pays and what is exempt
Under the reformed law the ₦50 charge on electronic transfers of ₦10,000 or more is formally designated a stamp duty. Crucially, the liability shifts to the sender of a qualifying electronic transfer. Previously, the EMTL had been intended to be borne by the recipient, and inconsistent practice by some financial institutions resulted in both sender and recipient being charged.
The new rules retain a set of exemptions. Transfers or deposits under ₦10,000 are not liable for the charge. Salary payments are exempt, and transfers between accounts owned by the same person within the same bank are excluded provided account names and identification details match. These carve-outs are intended to protect payroll flows and routine low-value transactions.
Separately, the NTA 2025 fixes stamp duty for agreements and contracts at ₦1,000 for specific instruments, moving away from an ad-valorem (value-based) approach for these items. Lawmakers have presented this as a simplification measure to reduce administrative complexity for common commercial documentation.
Another important legal consequence is evidentiary: unstamped documents, whether in physical or electronic form, will be inadmissible in Nigerian civil court proceedings. This restores the longstanding role of stamp duty as a condition for legal enforceability of certain instruments and is likely to prompt businesses and individuals to review their document processes to ensure compliance.
Background and practical implications
The EMTL was introduced in the Finance Act of 2019/2020 and initially excluded transactions routed through financial technology channels. In August 2024 the exemption for mobile money, internet banking and other electronic payment methods was removed, bringing fintech transfers into scope. The NTA 2025 goes further by integrating the EMTL provisions directly into the Stamp Duty Act, repealing the previous standalone legislation and creating a single statute intended to streamline compliance.
For consumers, the immediate practical effect is administrative clarity and a reallocation of liability to senders for certain transfers. Financial institutions will need to update their payment systems and customer communications to reflect the sender-pays rule. For businesses and lawyers, the fixed stamp duty on agreements simplifies calculation and reduces uncertainty around documentary charges.
Revenue from the revised levy will be shared among the three tiers of government using a formula: 15 percent to the Federal Government/Federal Capital Territory, 50 percent to State Governments, and 35 percent to Local Governments. The distribution is designed to bolster subnational revenues while preserving a federal allocation.
As the NTA 2025 takes effect, both individuals and organisations should review their payment and documentation practices to ensure compliance and avoid admissibility challenges in litigation.
Key Takeaways:
- Nigeria stamp duty reforms under the NTA 2025 unify the Electronic Money Transfer Levy into the Stamp Duty Act.
- The sender now pays ₦50 on electronic transfers of ₦10,000 or more; certain transfers such as salaries and intra-bank self-transfers are exempt.
- Stamp duty on agreements is fixed at ₦1,000 and unstamped documents are inadmissible in civil courts.
- Revenue from the charge will be shared 15% federal, 50% state and 35% local government.
