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Nigeria: fintech & payments regulation

Regulated

Dual-regulated fintech: CBN for payments, SEC for crypto/digital assets

Lead regulator
Central Bank of Nigeria (CBN)
Also involved
SEC (digital assets) · NFIU (AML/CFT) · NDPC (data privacy)
Core law
Payment Systems and Procedures Act, 2009
Entry capital
NGN 100m (PSSP)
Approval timeline
6-12 months for full license; ARIP provides interim AIP
Customer assets
Segregated trust accounts required
Data protection
NDPA 2023 · NDPC
Sandbox
Yes - ARIP

Nigeria operates a dual-regulatory framework for fintech. The Central Bank of Nigeria (CBN) supervises payment service providers, e-money issuers, and remittance operators under the Payment Systems and Procedures Act. The Securities and Exchange Commission (SEC) regulates digital assets and crypto-related activities under the Investments and Securities Act. Recent years have seen a tightening of compliance, data localization, and capital requirements.

Which licence do you need?

Your activityRequirementCapitalTimelineAuthority
Payment processing / gatewayLicencePayment Solution Service Provider (PSSP)[1][2]

Requires NIBSS/UPSL connectivity and ISO 20022 migration

NGN 100m6-12 monthsCBN
E-money & wallet issuanceLicenceE-Money Issuer (EMI)[3]

Strict KYC and wallet tiering rules apply

NGN 2bn6-12 monthsCBN
Domestic money transferLicencePayment Solution Service Provider (PSSP)[1]

Domestic transfers fall under PSSP or PSP licensing

NGN 100m6-12 monthsCBN
Cross-border remittanceLicenceInternational Money Transfer Operator (IMTO)[4][5]

Must use designated Naira settlement accounts with AD Banks

NGN 1bn6-12 monthsCBN
Agent networkLicenceAgent Banking License[6][7]

Subject to geo-fencing and cash-out limits

NGN 100m3-6 monthsCBN
Open banking / account informationRegistrationNIBSS/UPSL Member

Access via licensed aggregators or direct NIBSS connection

—3-6 monthsCBN
Foreign-exchange servicesLicenceBureau De Change (BDC) / IMTO[8][9]

EFEMS mandatory for interbank trading

NGN 500m3-6 monthsCBN

New — what changed recently

  • 2026-06-15Market Structure & Data Localisation — CBN mandated UBO disclosure, data localisation, and capped cross-border transaction flows for payment operators.[1]
  • 2026-05-29PoS Geo-Fencing Enforcement — CBN increased mandatory PoS geo-fence radius from 10m to 70m with strict enforcement deadlines.[10]
  • 2026-03-18SEC Revised Minimum Capital — SEC increased minimum capital for capital market operators, with compliance required by June 2027.[11]
  • 2026-03-16NRS TMS Integration — CBN mandated all PSSPs and switching companies to integrate with the Nigeria Revenue Service Transaction Monitoring System.[12]
  • 2026-03-24Diaspora Remittance Directives — IMTOs required to route all transactions through designated Naira settlement accounts with Authorized Dealer Banks.[5]

Market-entry checklist

  1. 1Incorporate entity with paid-up capitalRegister with CAC and ensure minimum capital (e.g., NGN 100m for PSSP) is deposited in a monitored account.
  2. 2Apply for CBN Payment LicenseSubmit application to CBN's Payments System Supervision Department with detailed business plan and compliance framework.
  3. 3Register with SEC for Digital AssetsIf offering crypto services, apply for SEC registration or ARIP admission to operate legally.
  4. 4Implement Data LocalisationEnsure all customer data is stored on servers within Nigeria as per CBN's 2026 market structure requirements.
  5. 5Integrate with NRS TMSConnect payment systems to the Nigeria Revenue Service Transaction Monitoring System for tax compliance.
  6. 6Establish UBO DisclosurePrepare and submit Ultimate Beneficial Ownership details to CBN and maintain updated registers.

Sources

  1. Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures In The Nigeria Payments System · 2026-06-15
  2. Migration to ISO 20022 Standard for Payment Messaging and Mandatory Geo-Tagging of Payment Terminals · 2025-08-26
  3. Circular on Tier 1 Wallets and Accounts, Guidance Note and Profiling of All Customer Accounts/Wallets · 2023-12-01
  4. Measures to Further Deepen Diaspora Remittances and Compliance · 2026-03-30
  5. MEASURES TO FURTHER DEEPEN DIASPORA REMITTANCES AND COMPLIANCE · 2026-03-24
  6. Circular and Guidelines for the Operations of Agent Banking in Nigeria · 2025-10-06
  7. Circular on Cash-Out Limits for Agent Banking Transactions · 2024-12-17
  8. Guidelines for the Electronic Foreign Exchange Matching System (EFEMS) · 2024-11-26
  9. Regulatory and Supervisory Guidelines for Bureaux De Change Operations in Nigeria · 2024-05-22
  10. Revised Implementation Timeline and Enforcement on PoS Geo-Fencing · 2026-05-29
  11. Guidelines On Revised Minimum Capital For Regulated Entities The objectives of these Guidelines are to: a. Promote investor protection by ensuring that CMOs maintain adequate financial resources to absorb operational and market-related losses; b. Enhance the resilience, integrity, and stability of the Nigerian capital market; c. Establish a risk-sensitive and proportionate capital framework aligned with the nature, scale, and complexity of regulated activities; d. Support effective supervision and early regulatory intervention through clear capital adequacy standards; and e. Reinforce domestic and international confidence in the prudential soundness of the Nigerian capital market, consistent with IOSCO principles. · 2026-03-18
  12. Mandatory Integration with the Nigeria Revenue Service Transaction Monitoring System (TMS) · 2026-03-16
This guide is compiled automatically from 12 primary-source documents published by Nigeria's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.