Fintech & payments regulation in Nigeria (2026)

Legal framework

Central Bank of Nigeria (CBN) under the CBN Act 2007 and BOFIA 2020, operationalized through the 2020 'Circular on New License Categorizations for the Nigerian Payments System' and supporting guidelines; digital consumer lending/BNPL additionally regulated by the Federal Competition and Consumer Protection Commission (FCCPC).

Key points: digital payments & fintech in Nigeria

1. 01CBN license categories

   The CBN's 2020 categorization streamlines payment-system licensing into four buckets: Switching & Processing, Mobile Money Operations (MMOs), Payment Solution Services (covering PSSP, PTSP and Super-Agent sub-licenses), and a Regulatory Sandbox. Only MMOs may hold customer funds; PSSPs cannot issue e-money or hold customer balances.

   cbn.gov.ng pwc.com

2. 02Capital requirements

   Switching companies and MMOs must maintain minimum shareholders' funds of ₦2 billion each, while PSSP/PTSP/Super-Agent operators sit at the lower tier (roughly ₦50m, ₦250m depending on category), evidencing a tiered, risk-based regime.

   pwc.com mondaq.com

3. 03Payment Service Banks (e-money / inclusion)

   The CBN's 2020 'Guidelines for Licensing and Regulation of Payment Service Banks' created PSBs that may accept deposits and issue debit/prepaid cards via mobile and digital channels to reach unbanked and rural populations, but cannot grant loans or hold foreign-currency deposits.

   cbn.gov.ng

4. 04Instant-payment rails (NIP / NQR)

   NIBSS operates the NIBSS Instant Payments (NIP) system for real-time interbank transfers settled in central-bank money, one of the largest instant-payment systems globally, alongside the NQR QR-code scheme (upgraded in 2025 for P2P and merchant payments) and the National Payment Stack.

   nibss-plc.com.ng nairametrics.com

5. 05Open banking (framework issued, launch delayed)

   The CBN issued Africa's first Open Banking Regulatory Framework (2021) and Operational Guidelines (March 2023), with NIBSS to run an Open Banking Registry and Consent Management System. A planned August 2025 go-live slipped; as of 2026 the system is in phased implementation rather than fully live.

   cbn.gov.ng techcabal.com technext24.com

6. 06BNPL & digital lending

   There is no standalone BNPL license; instead the FCCPC's DEON Regulations (enacted 21 July 2025, replacing the 2022 Interim Guidelines) require all digital lenders and BNPL providers to register on the FCCPC National Register, with a 5 January 2026 compliance deadline, mandatory fee disclosure, data-privacy limits, and penalties up to ₦100m or 1% of turnover.

   topeadebayolp.com nigeriadataprotection.com

Timeline of decisions

1. 10 Mar 2026Guidance
   CBN Issues Baseline Standards for Automated AML Systems

   The CBN (circular BSD/DIR/PUB/LAB/019/002) mandated all deposit money banks and fintechs to deploy AI-powered automated anti-money laundering systems, with 18-month deadlines for DMBs and 24 months for other financial institutions. Institutions must submit implementation roadmaps within 90 days and face sanctions for non-compliance, aligning Nigeria with FATF recommendations.

   The Cable (citing CBN circular BSD/DIR/PUB/LAB/019/002)

2. 2 Feb 2026Guidance · official
   CBN Publishes Fintech Policy Insight Report 2026

   Following a sector-wide stakeholder consultation and the October 2025 CBN Fintech Roundtable, the CBN released its first comprehensive post-PSV 2025 fintech policy report, proposing a Standing Fintech Engagement Forum, a Single Regulatory Window for multi-agency licensing, and Compliance-as-a-Service (CaaS). It also calls for expanding the regulatory sandbox to cover AI, embedded finance, and cross-border payments.

   Central Bank of Nigeria

3. 9 Sept 2025Guidance
   CBN Inaugurates Payments System Vision 2028 Project Committee

   The CBN launched the PSV 2028 initiative to replace the expiring PSV 2025 framework, with fresh priorities around deeper financial inclusion, payment infrastructure resilience, interoperability, and global competitiveness. It will serve as the principal strategic guide for Nigeria's payments ecosystem through 2028.

   Fintech Magazine Africa

4. 24 Nov 2022Guidance · official
   CBN Launches Payments System Vision 2025 (PSV 2025)

   The CBN published its three-year strategic blueprint targeting a cashless, inclusive, and efficient payments landscape, setting priorities across interoperability, financial inclusion, cybersecurity, and innovation. PSV 2025 became the primary governance framework coordinating all CBN payments regulation from 2022 to 2025.

   Central Bank of Nigeria

5. 25 Oct 2021Decision · official
   eNaira CBDC Launched, Africa's First Central Bank Digital Currency

   The CBN officially launched the eNaira, a retail CBDC pegged 1:1 to the naira on a two-tier architecture built by Bitt Inc., making Nigeria the second country globally (after The Bahamas) with a live CBDC. The eNaira was designed to deepen financial inclusion, lower remittance costs, and provide an additional monetary policy transmission tool.

   Central Bank of Nigeria

6. 17 Feb 2021Guidance · official
   CBN Issues Regulatory Framework for Open Banking

   The CBN published Nigeria's first open banking regulatory framework, mandating API-based data sharing across banks and non-bank financial institutions to enable third-party fintech access to consumer financial data. Implementation was repeatedly deferred (with live rollout originally planned for August 2025, then pushed to early 2026), but the framework remains the foundational legal instrument for open banking.

   Central Bank of Nigeria

7. 13 Jan 2021Guidance · official
   CBN Launches Formal Regulatory Sandbox Framework

   The CBN issued a framework establishing a supervised live-testing environment where fintechs can trial novel products, services, or business models for up to six months before applying for a full licence. The sandbox institutionalised CBN oversight of fintech innovation and was later earmarked for expansion to AI and embedded finance under the 2026 Fintech Report.

   Central Bank of Nigeria

8. 13 Nov 2020Law · official
   BOFIA 2020 Signed, First Statutory Recognition of Fintechs

   President Buhari signed the Banks and Other Financial Institutions Act 2020, repealing BOFIA 1991 and for the first time explicitly classifying digitally-operated financial entities as 'other financial institutions' subject to mandatory CBN licensing. Sections 57 and 69 specifically required fintechs and e-payment companies to be incorporated in Nigeria and hold a CBN licence, giving digital finance a statutory rather than purely guideline-based foundation.

   Central Bank of Nigeria

9. 27 Aug 2020Guidance · official
   CBN Issues Revised Payment Service Bank (PSB) Guidelines

   The CBN updated its 2018 PSB guidelines, formalising a licence category that allows telecoms operators, supermarkets, and mobile money operators to offer basic deposit, transfer, and payment services to the unbanked, subject to a ₦5 billion minimum capital requirement. The revised guidelines directly enabled MTN MoMo and Airtel Money to obtain PSB licences in 2022.

   Central Bank of Nigeria

10. 1 Jan 2012Guidance · official
    CBN Launches Cashless Nigeria Policy

    The CBN introduced cash-handling limits for individuals and businesses and mandated electronic payment channels (POS, mobile, internet banking), piloting in Lagos before a phased national rollout completing in 2014. This foundational policy catalysed Nigeria's digital payments ecosystem, drove mass deployment of payment infrastructure, and set the regulatory philosophy underpinning all subsequent fintech rules.

    Central Bank of Nigeria

Sources

1. 1.cbn.gov.ng/PaymentsSystem/PSPs.html
2. 2.pwc.com/ng/en/assets/pdf/cbn-circular-payment-service-providers.pdf
3. 3.cbn.gov.ng/out/2020/ccd/approved%20reviewed%20guidelines%20for%20licensing%20and
4. 4.cbn.gov.ng/Out/2023/CCD/Operational%20Guidelines%20for%20Open%20Banking%20in%20N
5. 5.nibss-plc.com.ng/national-payment-stack/
6. 6.nairametrics.com/2025/02/07/nibss-upgrades-nqr-payment-to-enhance-digital-transactions
7. 7.techcabal.com/2025/04/29/cbn-launches-open-banking/
8. 8.technext24.com/2025/10/20/cbns-open-banking-system-hasnt-launched/
9. 9.topeadebayolp.com/how-the-fccpcs-2025-deon-regulation-is-reshaping-nigerias-digital-len
10. 10.nigeriadataprotection.com/understanding-the-deon-regulations-in-2026/
11. 11.mondaq.com/nigeria/financial-services/1372606/requirements-for-payment-service-p