Stanbic IBTC: FIRS e-Invoicing Compliance
In 2025, FIRS mandated that large taxpayers integrate their billing systems with the FIRS platform before January 1, 2026. The deadline was statutory — no extensions, no phased options, no room to negotiate. For Stanbic IBTC, that meant coordinating six core teams across Finance, Tax, IT, Compliance, and Procurement, alongside Qucoon as our external Access Point Provider, to deliver a working end-to-end solution in two months. There was no Nigerian banking precedent to reference. We were figuring it out as we went. The project went live on January 1, 2026. Zero penalties. Full compliance from Day 1.
Jan 1, 2026
Regulatory go-live — achieved on schedule, first submission validated Day 1
Zero
Regulatory penalties incurred — full compliance from the first day of the mandate
6 Teams
Core stakeholder groups coordinated: Finance, Tax, IT, Compliance, Procurement, Qucoon
2 Months
End-to-end delivery — from regulatory interpretation to production go-live
What I Did
1 — Regulatory interpretation
Worked with Tax and Compliance to translate the FIRS technical specification into requirements the IT team and Qucoon could actually build against. The gap between what the circular said and what the systems needed to do was wider than it looked on paper.
2 — Governance structure from scratch
Six teams, different reporting lines, no natural programme owner. Set up the cross-functional RACI and delivery tracker that gave everyone clarity on their dependencies and kept leadership informed without turning every update into a meeting.
3 — SAP workaround architecture
Early in requirements gathering, a direct SAP integration was not going to work in a two-month window. Instead of treating it as a blocker, I facilitated the sessions that landed on the interim architecture: Power Automate pulling data from a SharePoint file manually exported from SAP, feeding it into the data reservoir for onward transmission to Oracle. Not the ideal long-term design — but it worked, it was auditable, and it got us to January 1st.
4 — Qucoon integration workstream
Managed the integration workstream with Qucoon end-to-end. Ran the technical alignment sessions between our IT team and their team to resolve ambiguities in the NRS Merchant Buyer Solution (MBS) specs, agree on error-handling behaviour, and lock down the data mapping before UAT started.
5 — UAT coordination
Coordinated UAT across Finance and Tax Operations. Test scenarios were mapped directly to FIRS validation rules, covering edge-case invoice formats, rejection-and-resubmission flows, and the audit trail requirements tied to each transaction type.
6 — Post-go-live performance response
After go-live, a performance issue surfaced in the transmission layer. The cron service was pushing 100 transactions per second but the volume running into the millions was more than it could sustain. I coordinated the response: we spun up multiple parallel microservices to distribute the processing load and hit the throughput the business needed. The issue was caught, escalated, and resolved without creating a compliance gap.
7 — Cutover and go-live readiness
Led cutover planning, go-live readiness, and post-launch service monitoring, including a full end-to-end simulation in the last week of December 2025 to confirm everything would hold before the statutory date.
Technical Stack
Access Point
Qucoon (APP)
Integration
NRS Merchant Buyer Solution (MBS)
ERP
SAP (source system)
Automation
Power Automate
Interim Data Layer
SharePoint Online + Oracle
Transmission
Microservices (parallel processing)
Project Tracking
Jira + Confluence
Collaboration
Microsoft Teams + SharePoint
Artefacts Delivered
The Outcome
Full regulatory compliance on Day 1, with the first submission validated by FIRS on January 1, 2026. Zero penalties incurred. A direct SAP integration was not feasible in the two-month window — the workaround we engineered got us there on time without compromising auditability. A live transmission bottleneck running into millions of transactions surfaced post go-live and was resolved through parallel microservice deployment before it created a compliance gap. The project ran to deadline with six teams aligned across Finance, Tax, IT, Compliance, Procurement, and a third-party Access Point Provider — with no Nigerian banking precedent to draw from.