Do you still need Form A and Form M in Nigeria in 2026?

Since 1 June 2026 you no longer file a Form A to send money out of a self-funded domiciliary account, and a domiciliary account holder can move up to $10,000 a day by direct transfer without the full trade paperwork. Form M hasn't changed. Every import of goods paid for in foreign currency still needs one.

Both forms are about where the foreign currency comes from, not about which app you use. Form A was how you asked a Nigerian bank to sell you dollars at the official rate. If the dollars are already yours, sitting in an account in your own name at a bank, Grey, Daya Borders or Raenest, that queue was never yours to join in the first place.

The change came in the fourth edition of the Central Bank of Nigeria's Foreign Exchange Manual, which the CBN launched on 16 May 2026 and brought into force on 1 June 2026, replacing the 2018 edition. The CBN gave the manual to authorised dealer banks rather than publishing the text, so what follows comes from the dated law-firm readings of it, and from the banks' own trade pages.

What is Form A, and do you still need it?

Form A is the CBN's application form for buying foreign currency to pay for services rather than goods, and for a self-funded domiciliary account it's no longer required. First Bank describes it as the form used “to pay for service transactions (invisible trade)”: school fees, medical bills, airline tickets, dividends, loan repayments, and the personal and business travel allowances.

What changed on 1 June 2026 is narrow and worth being precise about. Pavestones Legal's reading of the new manual puts Form A as “Required” under the 2018 edition and “Removed” under the 2026 one, for outward remittances by holders of self-funded domiciliary accounts. A self-funded account is one you filled yourself, with your own foreign income, a transfer from abroad or a cash deposit, rather than with foreign currency the bank sold you.

What it means for you: if your dollars arrived from a client or an employer and are sitting in your domiciliary account, sending them out is now an instruction to your bank rather than an application to buy currency. The verification step hasn't gone away. Your bank still has to establish what the payment is for, and it faces a flat ₦100 million fine plus ₦10 million for each affected transaction if it processes one without adequate documentation. So expect to be asked what the money is for, and to show it.

What is Form M, and did it change in 2026?

Form M is the import declaration every Nigerian importer files for goods paid for in foreign currency, and nothing in the 2026 Foreign Exchange Manual changed it. First Bank calls it a “mandatory statutory document to be completed by all importers”, filed electronically on the CBN's trade portal and run jointly with the Nigeria Customs Service.

The part that catches people out is who it binds. A Form M has to be registered with an authorised dealer bank when the order is placed, in First Bank's words, “whether or not the transaction is valid for foreign exchange”. In plain terms: the form follows the goods, not the money. You file one even when you're not asking any Nigerian bank to sell you a single dollar.

What a Form M needs, per First Bank's own trade page:

• A proforma invoice from your supplier, valid for 90 days
• An e-Insurance certificate
• A NAFDAC or SONCAP certificate, where the goods require one

A Form M is valid for 180 days for general merchandise and 365 days for plant and machinery. Your bank can grant one extension of the same length; anything beyond that needs the CBN's approval.

One genuine Form M change did land in 2026, and it was temporary. In January the CBN told banks to keep accepting NAFDAC licences that had expired on 31 December 2025 for the purpose of processing Form M, because NAFDAC was moving from its old NICIS II system to the B'Odogwu platform and importers couldn't renew. That dispensation expired on 28 February 2026.

What is Form Q, and who uses it?

Form Q is the small-scale importer's version of Form M, and it gives access to $20,000 per quarter at the official rate. First Bank lists what it asks for: a valid proforma invoice, a current account you've operated for six months or more and funded adequately, and a payment instruction from you.

If you import physical goods in small quantities, Form Q is usually the lighter route. Above $20,000 a quarter you're back to Form M.

What else changed for your money on 1 June 2026?

The 2026 Foreign Exchange Manual moved several numbers that decide how much foreign currency you can get and what paperwork comes with it. The ones that reach an individual or a small business:

1. A domiciliary account holder can make direct telegraphic transfers (bank-to-bank wires) of up to $10,000 a day without the full trade documentation.
2. An importer can now pay up to 30% of an order up front, measured on the free on board value of the goods, which is the price of the goods loaded onto the ship, before freight and insurance. Reports put the old ceiling at 15%.
3. School fees abroad go up to $25,000 per semester, from $15,000.
4. Travel allowances stay at $4,000 and $5,000 a quarter, but only 25% can now be taken as cash. The other 75% comes through a card or another electronic channel.
5. Money sent to you from abroad through a remittance service pays out in naira. If you want cash, you are capped at the naira equivalent of $200, and anything above that goes into a bank account.
6. Exporters no longer pay to process a Form NXP, the export declaration. Export proceeds have to come home within 180 days for oil and gas and 90 days for everything else, with a 1% penalty on the amount if they don't.
7. Goods and services sold between two Nigerian companies have to be priced and settled in naira, with exemptions for named activities in oil and gas, maritime, aviation and the free trade zones.

The naira-payout rule on inbound remittances is the one that surprises people most, and it's worth reading alongside why the black market rate differs from the official rate, because the rate you are paid at decides what that money is actually worth.

Do these forms still apply if you pay through an app instead of a bank?

Form M still applies, and this is the question that trips up most Nigerian importers who have moved their payments to a fintech. Form M is tied to goods arriving in Nigeria and clearing customs, not to which institution sent the money. First Bank's own page settles it: the form is registered with an authorised dealer bank when the order is placed “whether or not the transaction is valid for foreign exchange”. Paying your supplier from dollars you already hold doesn't remove the declaration.

Form A is different, because Form A only ever existed to buy foreign currency from a Nigerian bank. If you hold your own dollars, you were never filing one for that money. Since 1 June 2026, holders of self-funded domiciliary accounts don't file one for outward transfers either.

So the honest split is this. A fintech account can take the currency-buying problem off your desk. It cannot take the customs declaration off your desk, and any provider suggesting otherwise is describing something that isn't on offer.

Where does Daya Business fit?

Daya Business is for CAC-registered companies, and it covers the money side of a supplier payment rather than the paperwork side. Daya Business gives a company account details in its own name for US dollars, British pounds and euros, lets it hold those currencies and convert between dollars and naira, and pays out by bank transfer, wire, ACH, or on-chain in USDT and USDC. Daya Business needs CAC registration and business verification.

What that changes in practice is the sequence. If your customers abroad pay you in dollars and those dollars sit in your own account, you are not applying to anyone to buy currency before you can pay a supplier. What it doesn't change is Form M: if goods are coming into Nigeria, the declaration is still yours to file with an authorised dealer bank, and the practical detail of that sits in our guide to paying international suppliers from Nigeria.

For an individual rather than a company, the equivalent is Daya Borders, which takes 0% on incoming dollars and euros with no cap and no conditions, and has no fees at all today.

Where Daya Business isn't the pick: if you want to compare costs before you commit, Grey Business and Verto both print per-plan numbers, and on Verto read its Nigeria page rather than its default pricing page, which serves United States figures. What Daya Business has instead is the widest currency set of the three on its own page, with dollars, pounds and euros all live, where Grey Business has dollars live and lists pounds and euros as coming soon.

What happens if your bank gets the paperwork wrong?

The 2026 manual put real money behind bank compliance, and the effect on you is a bank that asks more questions. A bank that processes a foreign exchange transaction without adequate documentation faces a flat ₦100 million fine plus ₦10 million for every affected transaction. There is also a tight clock on inbound investment: capital has to be registered within 24 to 48 hours of arriving, and the law-firm readings warn that missing it can permanently damage the legal standing of the investment.

So before you send anything out, do three things:

1. Ask your bank, in writing, which of its domiciliary accounts yours is. Several Nigerian banks run one account that only accepts transfers and a separate one that only accepts cash, and you can't move money between them.
2. Have the purpose of the payment documented before you start: an invoice, a contract, a school's bill. Form A going away doesn't remove the question, it just moves it from a form to a conversation.
3. If goods are involved, register the Form M when you place the order, not when the shipment is on the water.