Matters Arising from CBN E-valuator and E-Invoice Policy By Adefolarin A Olamilekan

The “New World Order,” was an initiative that gain currency in the late ,1970s and early 80s before the decimation of for USSR now Russia and the fall of the Berlin Wall in Germany’s. The significant of the foregoing led to two in separate Neoliberal agenda in the form of Wave of Capitalist Democracy in Third World Countries and the shrinking of the earth under the weight of Global Capitalism. History will remember and continued to put us the focal point of what followed thereafter,with the Uruguay’s round table discussion on General Agreement on Trade and Tariff,birthing what is today World Trade Organization ,(WTO).Indeed,the hope of New World Order campaigners crash, as the ritual boom and boost of capitalist, dealt a blow on the hope of development countries as the entrap debt burden rubbish there collective will to ascertain a better trade deal and strong balance of trade that at weak point due to poor domestic monetary policy.
The above background is to help us appreciate the crux of this piece discussion on the current Central Bank of Nigeria,new launched policy,- evaluator and e-Invoice.
Interestingly, the policy has gone with a stiff challenger from players in the import and export sector.
Although this is a necessary context to debate around,especially as it touches the fundamental of international political economy strands. This for instance indicate the happenings around global Economic inequalities.
Being the factor in the choice of how developed nations maintained the dictations around what for monetary and fiscal policies directions developing and emerging market economy nations followed.
Now back to the CBN policy on e-invoice and E-valuator that became operational since February 1,2022 through a circular from the Director, Trade and Exchange Department of the CBN.
However,the major aim of the policy is to achieved “accurate value from import and export items in and out of Nigeria.”
According to the guidelines released by CBN on e-valuator and e-Invoice that is meant to replace hard copy invoices for both exports and imports
In summary it read” all Import and Export operations will require the submission of an Electronic Invoice (e-Invoice) authenticated by the Authorised Dealer Banks on the Nigeria Single Window portal Trade Monitoring System (TRMS)”.
It added that the “policy would operate on a Global Price Verification Mechanism guided by a benchmark price”. Again the policy draw on what it considered “the benchmark price is the actual spot market price obtainable at the time of consummation of invoicing, in that market where the goods are traded”.
Critically,and one of the controversy of the policy is what the apex bank noted as ” imports and exports with unit prices that are more than 2.5 per cent of the verified global checkmate prices would be queried and will not be allowed for successful completion of either form M or Form NXP as the case may be.
It said ,
In addition said “products that are more than 2.5 percent around the vertical price would be queried and will not be allowed successful completion of Form M or Form NXP as the case may be.
Accordingly, the policy required
“an importer/exporter of goods into Nigeria shall ensure that the purchase/sale contract with a foreign supplier/buyer stipulates compliance with the obligations set out in the CBN regulation and the supplier’s/seller’s invoice must be submitted in electronic format and authenticated by Authorised Dealer Bank (ADB) as part of the documentation for payment”.
Equally also the guideline stipulates that “no importer/exporter may effect payment to the credit of any foreign supplier unless the electronic invoice has been authenticated by Authorised Dealer Banks presented together with the relevant documents for payments Moreover the apex bank further added ” that the content of the electronic invoice authenticated by Authorised Dealer Banks is only advisory for the Nigeria Customs Service (NCS)”. In this regards the policy demand on” supplier/buyer of goods or services for import/export operations into or out of Nigeria is required to register on a dedicated electronic portal provided by the CBN and operated by CBN’s agent service providers as in the operational manual for Form M and Form NXP e-lnvoicing.
Interestingly, supplier will use the digital certificate for signing any e-invoice to be submitted”.
“After satisfactory registration and authentication, the supplier/buyer is required to register or submit e-invoices in the dedicated portal for their validation and authentication as specified by the CBN.
Confidentially,CBN appointed Service Provider will deliver the authenticated e-invoices to the supplier/buyer for transmission to the buyer and negotiation of payment.
The CBN appointed Service Provider will additionally transmit the e-invoices to Nigeria Single Window portal Trade Monitoring System (TRMS)”.
Another controversial part of the guideline’s is the “annual subscription fee of US$350 will be charged per authentication of suppliers on the system”. This raised vital questions from players in that sector.
In conclusion the policy advised” supplier/buyer that the electronic invoice authenticated is required for payment. In additional printed version of the electronic invoice will display a QR code to permit verification of its authenticity online.” In this wise also having satisfactory registration and authentication, the CBN appointed Service Provider will deliver a verification report and digital certificate to the supplier/buyer, which is valid for one year from the date of issuance”.
From the guideline’s submission one could fathom a policy that tends to ensure transparency, fidelity and price control mechanism as a fall out of what the apex bank monetary policy direction.
Regrettably, the new policy is not a welcome ideas for stakeholders and players in the export and import sectors.
Sincerely, for us it brings to fore,what leads a country’s economic consequential on the challenges with our balance of trade deficit.
Meanwhile,this aspects a general concerns that the CBN can never be shy away from as an important national economy health questions.
Again if one dissect it from the arguably abysmal performance of our productive sector that more or less made us an import dependent economy for many years.
Intriguing, concerns have been deployed by some of the import and export sector experts accusing the apex bank for,in my estimation of one is wrong time framing,as they argued thus”that it poor timing will distort prices of goods and services and create logjams for imports and exports, delay transactions and consequently cause ports congestion
Secondly they see the apex bank fronting beyond it constituted mandates,from it s branding status,therefore” that under Section 36 and 57 of the Customs and Excise Management ACT C 45 of 2004, the Minister of Finance has the authority to issue import and export recommendations.
They added that “under Section 36 and 57 of the Customs and Excise Management ACT C 45 of 2004, the Minister of Finance has the authority to issue import and export recommendations”
The CBN was further lebels has “gradually deviated” from its sole function of providing monetary policy measures to concentrating on fiscal policy measures which is the function of the federal ministry of finance
Thirdly the idea of “in the use of benchmarks for importation and exportation, is in violation of CEMA 20 of 2003 (as amended) and is an illegal policy that is globally unacceptable if the Brussels’s definition of value (BDV), consideration which is illegal worldwide”
Fourth, “the policy is coined from the angle of an over zealous chief,accordingly whose tact of monetary/fiscal input is to sudden, hurriedly or half-hazard to implementation that is in it best often leads to policy summersaults”
The argument above is germane and it cannot be overlooks. Nevertheless, it is also important to state here that the challenge of the Nigeria’s economy is to look beyond importation of goods that could also be produced here.
And as keen researcher on monetary and fiscal policies, it has been discovered that the pushed by CBN is how to discouraged importation
Fortunately, no serious central bank will watch as it balance of trade deficit keep risen and it local currency value nose dive.
What need to done goings forwards,ultimately is a collective stakeholders consensus on what policy platform we should adopt.
Especially as digitalization of trading activities and process is globally recognized now.
As a means to fast track and reduces risk in business.
Another is for stakeholders and CBN must show genuine concern’s benefits of the policy addressing some of the naira ,depleting of our foreign reserves through unpatriotic practice of over “invoicing by importers and enabling exporters to under -invoice”
Lastly,The posts colonial and neoliberal economic strategy perpetuate by developed nations through valuation of goods under the Act based on the World Trade Organisation (WTO) under GATT Articles IIV.
And this has been set on a logic of weaponizing global trade in balance. Leading to global unequal economic development For us it time for African Renaissance demands in this regards.
Adefolarin A Olamilekan,Political Economist and Development Researcher writes in from Nasarawa state

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