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NIGERIA’S FOREIGN EXCHANGE MARKET: RECENT REGULATORY REQUIREMENTS FOR BDC OPERATORS AND BANKS

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BY ADERONKE ALEX-ADEDIPE & HILLARY OKOROTIE

Introduction

On February 10, 2026, the Central Bank of Nigeria (CBN) issued a circular on the Participation of Licensed Bureau De Change Operators in the Nigerian Foreign Exchange Market, permitting licensed Bureau De Change (BDC) operators to participate in the Nigerian Foreign Exchange Market (NFEM).

Following the commencement of BDC operators’ participation in the NFEM, the CBN, on July 15, 2026, issued the Guidance on the Purchase of Foreign Exchange by Bureau De Change Operators Through Authorized Dealer Banks in the Nigerian Foreign Exchange Market (the “Guidance Notice”). The Guidance Notice establishes the procedures governing the purchase of foreign exchange by BDC operators through authorized dealer banks and outlines the obligations of dealer banks in facilitating such transactions.

In this newsletter, we provide insights on the obligations of BDC operators and authorized dealer banks.

What Are the Obligations of Dealer Banks and BDC Operators Under the Guidance Notice?

Under the Guidance Notice, dealer banks and BDC operators are required to undertake the following:

  1. Due Diligence Processes
    Under the Guidance Notice, dealer banks are required to conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) checks  before engaging in any foreign exchange transaction with a BDC operator. As part of this process, dealer banks must obtain and verify the BDC operator’s incorporation documents, valid operating license, as well as beneficial ownership information. Where a BDC operator is identified as presenting a higher risk following the due diligence assessment, the dealer bank is required to apply Enhanced Due Diligence (EDD) measures before proceeding with the transaction. 
  2. Fulfilment of Foreign Exchange Purchase Requests
    Requests by BDC operators to purchase foreign exchange must be submitted through the CBN’s Foreign Exchange Purchase Tracker Portal (the “Portal”) to the preferred authorized dealer BDC operators are required to register on the Portal and provide real-time updates of all foreign exchange purchase transactions. . Upon receipt of the BDC’s purchase request, the dealer bank may either approve or reject the request through the Portal. Where a request is rejected, the dealer bank must state the reason for the rejection on the Portal.The Guidance Notice also permits BDC operators to submit multiple foreign exchange purchase requests within a week, provided that the value of the purchases does not exceed the prescribed weekly purchase limit of US$150,000.

     

  3. Disbursement of Funds to BDC Operators
    In processing and fulfilling a foreign exchange purchase request, dealer banks are required to disburse foreign exchange only into foreign exchange settlement accounts maintained by the BDC operators with licensed financial institutions. Dealer banks must ensure that all disbursements are made solely to the BDC operator’s designated settlement account and not to the account of any third party. Any disbursement of foreign exchange to a third-party account constitutes a breach of the Guidance Notice and may attract sanctions against the dealer bank by the CBN. 
  4. Retention of Purchased Foreign Exchange
    BDC operators are required to sell all foreign exchange purchased through the NFEM within 24 hours. Any outstanding balance must be sold within 24 hours. Failure to comply may result in regulatory sanctions, including the forfeiture of the outstanding balance to the CBN or the suspension of the BDC operator’s license. In addition, BDC operators are required to disclose any outstanding balance in their foreign exchange purchase request for the following week. 

What Are the Penalties for Non-Compliance?

The CBN has prescribed sanctions for breach of its circular on the Participation of Licensed Bureau De Change Operators in the Nigerian Foreign Exchange Market and the Guidance Notice. BDC operators that fail to comply with these directives may be subject to monetary penalties, suspension or revocation of their operating license, or suspension of their access to the NFEM.

Similarly, dealer banks that fail to comply with the CBN’s directives when transacting with BDC operators may have their status as authorized dealer banks revoked. Where a breach involves suspected criminal conduct, the CBN may also refer the matter for criminal investigation and prosecution to the appropriate authorities

Conclusion

The CBN’s objective in permitting BDC operators to purchase foreign exchange through authorized dealer banks in the Nigerian Foreign Exchange Market (NFEM) is to improve liquidity within the formal foreign exchange market. The framework is also intended to curb abuses and arbitrage in the foreign exchange market. If properly implemented therefore, it is expected that these policies will sustain the current stability in the market.

For more information on the participation of BDC operators in NFEM, please see our previous newsletter.

 

CBN’S DATA LOCALISATION DIRECTIVE – COMPLIANCE CONSIDERATIONS FOR PAYMENT SYSTEM PARTICIPANTS

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BY ADERONKE ALEX-ADEDIPE & PROMISE ITAH

Introduction

On June 15, 2026, the Central Bank of Nigeria (“CBN“) issued a Circular on Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigeria Payments System (the “Circular“). Among other regulatory reforms, the Circular introduces a significant data localisation requirement directing all financial institutions and participants facilitating payments within Nigeria—including banks, payment service providers, mobile money operators and other payment participants— (collectively “Payment System Participants”) to ensure that data generated in relation to payment transactions in Nigeria is stored and managed in Nigeria by January 1, 2027.

In this newsletter, we examine the scope of the CBN’s data localisation requirements, their interaction with existing data protection obligations, and some of the key legal, contractual and operational considerations which Payment System Participants should consider in preparation for compliance.

  1. Who does the Circular Apply to?
    The Circular applies to payment transaction data generated through Nigeria’s payments system. Although the Circular does not define the term “payment transaction data”, it intuitively includes information generated in connection with a payment transaction, including the payer’s and beneficiary’s payment details, transaction amounts, payment references, authentication records, settlement and routing information, transaction logs and other related technical data required to process, verify or record a payment.

    The Circular also appears to frame the localisation requirement by reference to payment transaction data generated within Nigeria, rather than the location in which the business is principally domiciled. On this basis, therefore any Payment System Participant processing payment transaction data generated within Nigeria may be expected to comply with this requirement, regardless of their country of domicile.

  1. What are the Key Compliance Requirements?

    a. Local Processing and Storage
    Payment System Participants must ensure that payment transaction data is both stored and managed within Nigeria. This extends beyond maintaining a local copy of data and requires that the primary processing environment, databases, backups and operational control remain on infrastructure located within Nigeria.

    The requirement for payment transaction data to be “managed” in Nigeria may also have implications for administrative activities such as access management, database administration, encryption key management and audit logging, particularly where these functions are performed through offshore infrastructure or personnel.

    b. Technology and Infrastructure
    The Circular is likely to require many Payment System Participants to review their technology infrastructure, particularly where payment services rely on foreign cloud service providers or systems hosted outside Nigeria. Given the requirement for payment transaction data generated within Nigeria to be stored and managed locally, organisations should assess whether their existing technology architecture involves the storage, processing or replication of payment transaction data outside Nigeria. Areas that may require review include:

    • cloud hosting arrangements and the location of servers;
    • disaster recovery and backup systems;
    • analytics and monitoring platforms that process payment data;
    • testing and development environments that use live or production payment data; and
    • third-party APIs and other technology integrations that may transfer payment data outside Nigeria.

Payment System Participants operating hybrid or multiple cloud environments should assess whether payment data is stored, replicated or processed outside Nigeria and, where necessary, implement appropriate technical or operational changes before the compliance deadline.

c. Vendor and Outsourcing Arrangements

Whilst it is commonplace for Payments System Participants to assign data processing and storage activities to third parties, the Circular does not appear to transfer the obligations from Payment System Participants to service providers in such instance. Accordingly, organisations should review their contractual arrangements with cloud service providers, payment processors, application programming interface (API) providers and other technology vendors to assess whether those arrangements support compliance with the localisation requirement. In particular, organisations should consider whether their contracts adequately address:

    • the requirements for payment data to be stored and managed within Nigeria;
    • restrictions on processing payment data outside Nigeria;
    • rights to conduct audits and facilitate regulatory inspections;
    • controls over the use of subcontractors that may have access to payment data;
    • obligations to promptly notify the Payment System Participant of any data breaches or incidents; and
    • termination rights where a vendor is unable to comply with the localisation requirements.
  1. How does the Circular Interact with the Nigeria Data Protection Act (NDPA)?

The Circular complements rather than replaces the NDPA. While the NDPA regulates the processing and international transfer of personal data through recognised transfer mechanisms and safeguards, the CBN Circular imposes an additional regulatory obligation applicable specifically to payment transaction data. Accordingly, compliance with the NDPA alone will not satisfy the CBN’s localisation requirements.

  1. Practical Compliance Steps

Pending any further guidance from the CBN, Payment System Participants should consider taking the following steps to prepare for implementation:

    1. conducting a comprehensive data mapping exercise to identify where payment data is stored, processed and transmitted;
    2. assessing existing cloud and infrastructure arrangements for localisation risks;
    3. reviewing third-party vendor relationships and contractual provisions;
    4. updating internal data governance, outsourcing and information security policies;
    5. establishing board and management oversight of the implementation programme; and
    6. maintaining adequate documentation to demonstrate compliance during regulatory inspections.

Conclusion

The CBN’s payment data localisation requirements represent a significant development in the regulation of Nigeria’s payments ecosystem. By requiring payment transaction data generated within Nigeria to be stored and managed in Nigeria, the Circular appears intended to strengthen regulatory oversight, enhance operational resilience and support the security of Nigeria’s payments infrastructure. For Payment System Participants, the immediate priority will be to assess whether existing technology infrastructure, data governance frameworks and third-party vendor arrangements are consistent with the new localisation requirement. Given the breadth of the obligation and the absence of detailed implementation guidance, organisations that begin assessing their compliance position ahead of the January 2027 implementation date will be better positioned to address any legal, operational or contractual gaps as further guidance emerges.

BEYOND LICENSING – CBN’S DRAFT GUIDELINES FOR FINANCIAL HOLDING COMPANIES IN NIGERIA

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BY ADERONKE ALEX-ADEDIPE AND ENIOLA SOGBESAN

BEYOND LICENSING – CBN’S DRAFT GUIDELINES FOR FINANCIAL HOLDING COMPANIES IN NIGERIA.

Introduction

On 10 June 2026, the Central Bank of Nigeria (CBN) issued an Exposure Draft of the Revised Guidelines for Licensing and Regulating Financial Holding Companies (FHCs) in Nigeria (the “Draft Guidelines”). The Draft Guidelines is the first review of Nigeria’s financial holding company framework since the introduction of the Guidelines for the Licensing and Regulation of Financial Holding Companies in Nigeria 2014 (the “2014 Guidelines”).

The Draft Guidelines seek to:

  1. strengthen the financial resilience of holding companies;
  2. improve group-wide governance and oversight;
  3. clarify ownership and control requirements;
  4. enhance regulatory supervision of financial groups; and
  5. address concerns arising from shared service arrangements and complex group structures.

For existing FHCs, banking groups, investors, and prospective promoters, the Draft Guidelines signal a shift from a regime focused primarily on licensing to one that places greater emphasis on governance, capital adequacy, ownership accountability, and consolidated supervision.

Key Highlights of the Draft Guidelines

  1. Definition and StructureThe Draft Guidelines introduce a clear definition of what constitutes a FHC. Under the Draft Guidelines, a FHC is defined as a non-operating holding company that has two or more direct subsidiaries, one of which must be a bank. The Draft Guidelines further stipulate that a FHC may adopt either a Parent HoldCo or Intermediate HoldCo structure.Under the Parent HoldCo structure, a parent holding company holds direct equity investment in each Nigerian subsidiary, however under the Intermediate HoldCo structure, an intermediate holding company is incorporated for the purpose of holding equity investment in foreign subsidiaries. Accordingly, all existing FHCs are required to notify the CBN of their preferred structure within six (6) months of the effective date of the Guidelines. Also, once the preferred structure is approved by the CBN, such FHC must operate that structure for a minimum of 5 years before it may elect to reverse or alter the approved structure.

    The Draft Guidelines list individuals, non-bank corporate investors and banks [commercial, merchant and non-interest] as eligible promoters of FHCs. This clarification provides greater regulatory certainty for investors considering the use of a holding company structure to expand their presence within Nigeria’s financial services sector.

  1. Permissible and Non-Permissible Activities
    Under the Draft Guidelines, the following activities are permissible for FHCs. These activities include-
    1. holding equity investment in subsidiaries engaged in financial services;
    2. investment in government securities or placement with banks;
    3. with the prior approval of the CBN, raising bonds and debentures;
    4. subject to the prior approval of the CBN, borrowing internationally to capitalize any of its subsidiaries and;
    5. providing either by itself or through any subsidiary, shared services to the group members in respect of facilities, legal and ICT services and other services that may be prescribed by the CBN from time to time.

However, FHCs are prohibited from engaging in the following activities –

    1. investing in entities not involved in financial services;
    2. pledging its shares in any subsidiary as collateral for any purpose;
    3. establishing, divesting or closing any subsidiary without the prior approval of CBN;
    4. interfacing with any customers of its subsidiaries and;
    5. bearing the expense of any of its subsidiaries.
  1. Corporate Governance Requirements
    In addition to the provisions of the Corporate Governance Guidelines for Financial Holding Companies in Nigeria, the Draft Guidelines introduce additional corporate governance rules for FHC’s.Some of these additional corporate governance are –
    1. subsidiaries of FHCs are prohibited from acquiring shares in the FHC and/or other subsidiaries of the FHC;
    2. Nominee companies that are subsidiaries of the FHC are prevented from investing client funds in the FHC or any other subsidiary;
    3. where a FHC loses control in the only or all Nigerian banking subsidiaries for a period that exceeds six (6) consecutive months, its license shall be revoked;
    4. where a FHC that has only two (2) subsidiaries loses control in either subsidiary for a period that exceeds six (6) consecutive months, its license shall be revoked;
    5. No employee of a FHC shall be appointed as a non-executive director in the FHC or any other subsidiary; and
    6. interlocking directorship within a FHC is limited to a maximum of one other company.More importantly, the Corporate Governance rules of the Draft Guidelines are required to be read in conjunction with the Nigerian Code of Corporate Governance 2018, Corporate Governance Guidelines for Financial Holding Companies in Nigeria and where applicable the SEC’s Code of Corporate Governance for Public Companies and Listed Entities in Nigeria.
  1. Intra-Group Transactions, Prudential Requirements & AML/CFT Compliance
    The Draft Guidelines make extensive provisions for intra-group transactions. More specifically, FHCs are prohibited from interfering in the daily operations of their subsidiaries and all transactions with their subsidiaries must be strictly on an arm’s length basis. In particular, the Draft Guidelines expressly prohibit the practice where board members of a subsidiary attend board meetings of the FHC and vice versa.All FHCs are required to maintain a minimum regulatory capital which shall exceed the sum of the minimum regulatory capital of its subsidiaries by at least 20%. In determining what constitutes minimum regulatory capital, the Draft Guidelines provide that only the paid up capital shall be recognized. Additionally, excess capital in one subsidiary shall not be computed to make up for a shortfall in the share capital of another subsidiary.Furthermore, the Draft Guidelines require all FHC’s to comply with all AML/CFT/CPF regulations and to appoint a compliance officer who shall not be below the grade of a senior management staff responsible for filing the required returns with the CBN.

What Should Financial Holding Companies Be Doing Now?

Although the Draft Guidelines remain in draft form, affected institutions should begin evaluating the potential implications of the proposed framework.

Key considerations include:

    1. assessing compliance with the proposed ownership thresholds;
    2. reviewing group structures and foreign subsidiary arrangements;
    3. evaluating shared service models and related documentation;
    4. assessing capital adequacy and funding arrangements;
    5. reviewing governance frameworks and board oversight mechanisms; and
    6. identifying areas that may require regulatory engagement or restructuring.

Conclusion

The Draft Guidelines appears to be more than a routine update of the 2014 Guidelines. It reflects a broader regulatory shift towards stronger governance, clearer ownership structures, enhanced prudential safeguards, and more effective consolidated supervision of financial groups. For financial holding companies and banking groups, the message is clear: regulatory expectations are evolving beyond licensing and corporate structure requirements only.

The practical implication of the Draft Guidelines is that financial holding companies must begin to reassess their governance frameworks, group structures, risk management systems, and compliance functions to ensure alignment with the heightened regulatory standards. As the Central Bank of Nigeria continues to strengthen its supervisory oversight of financial conglomerates, early preparation and strategic compliance will be critical to achieving long-term sustainability and regulatory success.

KEY REGULATORY UPDATE IN NIGERIA: THE CBN FOREIGN EXCHANGE MANUAL 2026

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BY SEUN TIMI-KOLEOLU & OLUWAYEMI IBIRINDE

Introduction

On June 1, 2026, the Central Bank of Nigeria (CBN) implemented the Fourth Edition of the Foreign Exchange Manual (the “2026 Manual”), replacing the Foreign Exchange Manual 2018 (the “2018 Manual”). The 2026 Manual introduces significant changes to currency and trade rules and consolidates various foreign exchange policies and directives into a single framework governing foreign exchange transactions in Nigeria. While the 2026 Manual introduces measures intended to improve access to foreign exchange and facilitate cross-border transactions, it also strengthens regulatory oversight and significantly increases the consequences of non-compliance.

In this newsletter, we highlight some of the key changes introduced by the 2026 Manual and their implications for financial institutions and other stakeholders.

Key Operational Adjustment

Increased Flexibility for Trade and Foreign Exchange Transactions

  1. Import and Export
    Under the 2018 Manual, importers were generally permitted to make advance payments of up to 15% of the Free on Board (FOB) value of physical imports. However, under the New Manual the permissible advance payment threshold for physical imports has been increased to 30% of the Free on Board (FOB) value of the goods. This adjustment provides importers with greater flexibility in negotiating payment terms with foreign suppliers and may reduce procurement challenges associated with international trade transactions.Also, to incentivize international trade and reduce processing hassles, the New Manual mandates that the processing of Form NXP for exporters shall now be entirely free of charge.  These measures are expected to simplify access to foreign currency held in domiciliary accounts and reduce administrative blockages associated with remittance transactions.
  2. Tuition Remittances
    Under the 2018 Manual, International tuition fee remittances were restricted to USD 15,000 per semester, capped at two semesters per year. However, the 2026 Manual raises this threshold to USD25,000 per semester. This provision provides greater clarity regarding the amount that may be accessed through official channels for educational expenses.

  3. Domiciliary Account Holders
    Also, the 2026 Manual removes the Form A requirement for outward remittances for holders of self funded domiciliary accounts.

    Similarly, Domiciliary account holders may now initiate direct telegraphic transfers of up to USD10,000 per day without triggering exhaustive trade documentation.

Export Proceeds and Inbound Remittances

The 2026 Manual provides that all exporters shall ensure that export proceeds are repatriated and credited to their export domiciliary account in the bank where the NXP was established, within 180 days from the Bill of Lading date for oil and gas exports and 90 days for non-oil exports. Failure to adhere to this timeline imposes a penalty of 1% of the amount involved.

Furthermore, the Manual provides that inbound foreign currency transfers shall be paid to beneficiaries in Naira or such other currency as may be determined by the CBN from time to time.

It further provides that cash withdrawals relating to inbound transfers shall not exceed the Naira equivalent of USD200, while amounts above this threshold must be paid through a bank account.

Revised Travel Allowance Framework

CBN previously prohibited cash payments of Personal Travel Allowance (PTA) and Business Travel Allowance (BTA) under its 2024 cashless directive. However, Under the 2026 Manual, 25% of the PTA and BTA may now be disbursed in physical foreign currency cash while the remaining 75% must be disbursed through electronic channels such as debit or credit cards. This policy shift aims to balance the digital payment objectives of the apex bank with the practical cash liquidity demands faced by international travelers.

Domestic Transactions and Naira Denomination Requirements

The 2026 Manual reaffirms the requirement that transactions involving goods and services exchanged between Nigerian entities must generally be denominated and settled in Naira.

However, exemptions continue to apply to certain sectors and transactions, including specified activities within the oil and gas, maritime, aviation and free trade zone sectors.

Regulatory Compliance and Enforcement

The New Manual introduces a high-stakes environment for Authorized Dealer Banks (ADBs) and corporate entities:

  1. Financial Sanctions: Banks processing transactions without adequate documentation face a ₦100 million flat fine, plus ₦10 million per affected transaction.
  2. Export Penalties: A 1% penalty applies to exporters failing to repatriate proceeds within the mandatory 90 days (non-oil) or 180 days (oil/gas) windows.
  3. Strict Documentation: The CBN has codified the use of the Electronic Certificate of Capital Importation (eCCI). Capital must be registered within 24–48 hours of inflow; failure to do so may permanently compromise the legal standing of the investment.
  4. Domestic Denominations: All domestic transactions must be priced and settled in Naira. Exemptions are strictly limited to specific sectors, including Oil & Gas, Maritime, Aviation, and businesses within Free Trade Zones.

Conclusion

The 2026 Foreign Exchange Manual represents an important development in Nigeria’s foreign exchange regulatory framework.

On one hand, the Manual provides businesses and individuals with greater flexibility through higher import payment thresholds, increased tuition remittance limits, simplified domiciliary account operations, and reduced export transaction costs. On the other hand, it introduces a more stringent compliance environment characterised by enhanced documentation requirements, stronger reporting obligations, and substantial penalties for non-compliance.

Accordingly, all stakeholders involved should undertake a comprehensive review of their foreign exchange policies, documentation procedures, transaction monitoring systems, and internal controls to ensure alignment with the new framework. Given the scale of the sanctions introduced by the Manual, compliance failures may no longer be viewed as routine administrative lapses but as material regulatory risks with potentially significant financial and operational consequences.

As implementation of the Manual progresses, we expect that further regulatory guidance will be put in place to provide additional clarity on the application of the 2026 Manual provisions.

Key Changes at a Glance

Area 2018 Manual 2026 Manual
Advance Import Payments 15% of FOB Value 30% of FOB Value
PTA/BTA Disbursement More restrictive cash framework 75% Electronic / 25% Cash
Tuition Fee Remittances Lower limits Up to USD 25,000 per Semester
Domiciliary Account Remittances Form A Required Form A Removed
Form NXP Processing Processing Fees Applicable Free of Charge
Documentation Violations Lower sanctions ₦100m + ₦10m per affected transaction
Export Proceeds Repatriation Existing obligations 1% penalty for non-compliance
Inbound Money Transfers Less detailed framework Enhanced payment and withdrawal restrictions

 

CBN CASH POOLING REFORM: IMPACT ON FOREIGN INVESTMENT AND THE OIL AND GAS SECTOR IN NIGERIA

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BY ADERONKE ALEX-ADEDIPE & PROMISE ITAH

Introduction

On 25 March 2026, the Central Bank of Nigeria (CBN) issued a circular on Removal of Cash Pooling Requirements for International Oil Companies (the “Circular”) removing the restrictions previously imposed on the repatriation of export proceeds by International Oil Companies (IOCs). Under the new framework, IOCs may now repatriate up to 100% of their export earnings immediately, reversing the 2024 “50/50 Rule”, which required a portion of export proceeds to remain in Nigeria for a specified period before repatriation.

In this newsletter, we briefly examine the background to the policy, the recent changes introduced by the CBN, some key documentation required by banks, and the implications for companies operating in Nigeria’s oil and gas sector.

  1. What is “Cash Pooling”?

    Cash pooling is a treasury arrangement used by multinational groups to manage the cash balances of their subsidiaries on a consolidated basis. Rather than leaving excess funds idle in separate accounts, the group centralises those funds and deploys them where they are most needed. This improves liquidity management within the group, enhances operational efficiency, and reduces reliance on external financing.

  1. The 2024 Policy Shift: The 50/50 Rule

    Before February 2024, IOCs operating in Nigeria could generally repatriate their US dollar export proceeds offshore, subject to local content requirements. However, due to foreign exchange liquidity pressures in early 2024, the CBN introduced restrictions permitting only 50% of export proceeds eligible for repatriation to be transferred immediately (or sold in the local foreign exchange market), while the remaining 50% had to be retained in Nigeria for at least 90 days.

    These measures were designed to increase foreign exchange liquidity and support stability in Nigeria’s foreign exchange market.

  1. The 2026 Circular: Restoration of Full Repatriation Rights

    As part of its efforts to further deepen and liberalise the Nigerian foreign exchange market, the CBN, through the Circular, removed the restrictions introduced in 2024. As a result, IOCs may now repatriate up to 100% of their export proceeds immediately upon receipt, subject to compliance with applicable documentation and reporting requirements. The previous 90-day retention requirement has been abolished, allowing companies greater flexibility in managing their export earnings and global treasury operations.

  1. Required Documentation
    Although the repatriation restrictions have been removed, Authorised Dealer Banks (ADBs) remain responsible for ensuring that all transactions are properly documented and reported to the CBN.

    Key documents required for processing repatriation requests may include:

  1. Evidence of export: Bills of lading, commercial invoices, and other documents evidencing the quantity, quality, and value of the exported crude oil.
  2. Clean Certificate of Inspection (CCI): Documentation issued by the relevant inspection authority confirming the quality and volume of the shipment.
  3. Evidence of foreign exchange inflow: Bank statements or confirmations showing that the export proceeds have been received into the IOC’s domiciliary account in Nigeria.
  4. Cash pooling agreement: The executed agreement between the Nigerian subsidiary and its parent company setting out the terms of the group’s cash pooling arrangement.

    These requirements are intended to promote transparency and ensure regulatory oversight of cross-border fund transfers.

  1. Key Market Impact:

    The policy change is expected to have important implications for Nigeria’s oil and gas sector.

  1. Foreign Investment

    The removal of the repatriation restrictions is expected to enhance investor confidence by assuring foreign investors and lenders that export proceeds can be accessed and transferred without delay. This may improve the attractiveness of Nigeria as a destination for upstream oil and gas investment, particularly for capital-intensive projects such as deepwater developments.

    In addition, the revised framework simplifies treasury operations for IOCs by eliminating the administrative burden associated with the previous 90-day retention requirement.

  2. Domestic Market Considerations

    The policy may also influence foreign exchange flows within the domestic market. While a greater proportion of export proceeds may now be transferred offshore immediately, the CBN appears to have concluded that prevailing market conditions can accommodate the change without undermining foreign exchange liquidity.

    The continued documentation and reporting obligations imposed on ADBs are expected to support regulatory oversight and help maintain market transparency.

Conclusion

The removal of the cash pooling repatriation restrictions marks a shift in Nigeria’s foreign exchange policy for the oil and gas sector. By restoring immediate access to export proceeds, the CBN has provided IOCs with greater flexibility in managing liquidity and participating in global cash pooling arrangements. For Authorised Dealer Banks, the focus shifts from monitoring retention periods to ensuring compliance with documentation and reporting requirements. Overall, the CBN expects the revised framework to strengthen investor confidence and support a more efficient and competitive foreign exchange market.

 

This newsletter provides a general overview of recent policy changes for informational purposes and does not constitute formal legal or financial advice. Because CBN guidelines can evolve, we recommend consulting a qualified professional regarding how these updates specifically apply to your business operations.

For further information on any of the issues covered in this newsletter, please contact us at info@pavestoneslegal.com. At Pavestones, we deliver quality and innovative legal support across diverse industries, helping businesses operate in compliance with applicable laws and regulations to drive sustainable business growth.

BANKING AND FINANCE REGULATION IN NIGERIA – INTEREST RATE DETERMINATION, NOFR BENCHMARK

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BY SEUN TIMI-KOLEOLU AND PROMISE ITAH

Introduction

On April 17, 2026, the Central Bank of Nigeria (CBN) announced the introduction of the Nigerian Overnight Financing Rate (NOFR) in collaboration with the Financial Markets Dealers Association (FMDA). The NOFR is a daily benchmark designed to reflect the actual cost of short-term borrowing between banks, based on real market transactions. According to the CBN, the introduction of the NOFR is aimed at enhancing transparency, strengthening monetary policy transmission, and deepening Nigeria’s money market.

In this newsletter, we highlight the rationale and framework of the NOFR, as well as its implications for the market.

What is the Rationale behind the NOFR?

Nigeria’s short-term interest rates have traditionally been guided by the Monetary Policy Rate (MPR) and interbank indicators such as the Open Buy Back (OBB) and Overnight (OVN) rates, which are meant to reflect the cost of overnight borrowing between banks.

However, these indicators do not always reflect actual transactions, as they may be influenced by estimates, limited trading activity, or inconsistent reporting. As a result, they may not accurately capture the true cost of short-term funding.

The Nigerian Overnight Financing Rate (NOFR) was introduced to address this gap by replacing indicative pricing with a benchmark based on actual transactions, thereby improving reliability and market confidence.

What is the Framework of the NOFR?

The NOFR is an average interest rate that reflects the actual cost of overnight lending between banks in naira, where the loans are secured by collateral, and based on real market transactions. The rate is calculated by giving more weight to larger transactions and removing unusually high or low rates (the higher 10% and the lower 10% percent volumes are excluded from the calculation), so that the final figure reflects normal market conditions and provides a more accurate picture of how banks actually price short-term funding.

The transactions used to calculate the NOFR must meet the following conditions:

  1. they must be carried out on the specific day the rate is being calculated (the fixing day);
  2. they must be reported by approved banks;
  3. Each transaction must be at least ₦5 billion, so that only significant market activity is included.

The rate is published daily at 10:00 a.m. for the preceding business day. Where there is insufficient qualifying transaction data, the previous day’s rate is retained and published to ensure continuity and stability. The CBN is responsible for the governance and regular publication of the NOFR. The rate can be accessed on the CBN website.

 

What are the Key Market Implications?

Some key market implications of the introduction of the NOFR are set out below:

  1. Corporate Borrowers: While the NOFR may not immediately reduce borrowing costs, it provides a clear and transparent base rate for floating-rate loans. This makes loan pricing more consistent and easier to compare. Borrowers may seek to review existing loan agreements, especially floating-rate clauses, as pricing will gradually shift to NOFR-based benchmarks, making interest costs more responsive to overall market conditions.
  2. Banks and Financial Institutions: In view of the improved accuracy in pricing short-term loans, banks will have a clearer view of funding costs, enabling more effective day-to-day liquidity management.
  3. Investors: The greater transparency and reliability of the NOFR may make it easier to price and value instruments such as treasury bills and bonds. This is expected to improve pricing consistency across the market and give both local and foreign investors greater confidence in expected returns.
  4. Legal/Contractual Considerations: The introduction of the NOFR means that existing financial agreements referencing older interbank rates or bank-specific pricing may need to be reviewed and updated to reflect the new benchmark. Going forward, new agreements are likely to adopt NOFR as the base rate, with an added margin. This makes it important to include clear provisions on benchmark use and replacement in new agreements.

Conclusion

The introduction of the NOFR marks a significant shift in how interest rates are determined in Nigeria and aligns the country with global benchmarks best practices such as the Secured Overnight Financing Rate (SOFR) in the United States and the Sterling Overnight Index Average (SONIA) in the United Kingdom. While the CBN expects the NOFR to enhance transparency, strengthen monetary policy transmission, and deepen Nigeria’s money market, its impact will ultimately depend on adoption and effective administration.

New CBN Measures on Diaspora Remittances: What They Mean for Market Participants

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BY ADERONKE ALEX-ADEDIPE AND PROMISE ITAH

Introduction

On March 24, 2026, the Central Bank of Nigeria (CBN) issued a circular on Measures to Further Deepen Diaspora Remittances and Compliance (the “Circular”). The Circular, which is effective from May 1, 2026, builds on the CBN’s revised guidelines for international money transfer services in Nigeria, and is aimed at enhancing  diaspora remittances, strengthening transparency, traceability, and effective monitoring of all remittance related transactions.

In this newsletter, we highlight the measures introduced by the CBN and assess their practical implications for participants.

What Are the New Measures?

The following measures have been prescribed by the CBN.

  1. Designated Naira Settlement Accounts: All transactions related to International Money Transfer Operators’ (IMTO) operations, including payments to beneficiaries and any settlements, must be processed through designated settlement accounts held with authorised dealer banks (ADBs or Banks). IMTOs may either open new accounts or use existing ones for this purpose and can maintain multiple naira settlement accounts based on their business needs. However, they are required to regularly provide the CBN with an updated list of these designated accounts through the Director of the Trade and Exchange Department.
  2. Account Funding Restrictions: The circular makes it clear that these settlement accounts can only receive money from remittances or foreign exchange transactions carried out by the IMTOs or their agents through authorized participants in the Nigerian Foreign Exchange Market (NFEM). This means that no other funds are allowed to be deposited into these accounts.
  3. Authorised Transfers to Other Market Participants and BDCs: To improve the flow of foreign exchange and support fair pricing, ADBs are permitted to process foreign currency transfers from IMTO settlement accounts to other ADBs and approved market participants, including licensed Bureau de Change (BDC) operators.
  4. Real-Time FX Pricing: IMTOs must set their remittance rates to reflect current market prices from Bloomberg’s BMatch platform rather than being set independently. By doing this, the CBN aims to ensure more accurate pricing, reduce information gaps between banks and IMTOs, and encourage greater use of the official FX market.
  5. Compliance and Record Keeping: In addition to complying with the above measures, all IMTOs (and ADBs) must strictly comply with anti‐money laundering and counter-terrorism financing rules. Detailed records of all remittance transactions (origins, amounts, beneficiaries, conversions, etc.) must also be kept for regulatory review and audit purposes.

 

What Are the Practical Implications?

The new measures may require certain operational changes. We have set out below, some key implications and action points for IMTOs, banks, BDCs and other stakeholders:

  1. IMTOs (Money Transfer Operators):

    In view of the above regulatory measures, IMTOs may require system upgrades and staff training and must also strengthen record-keeping and AML/KYC processes, maintaining detailed transaction logs for regulatory review.

  2. ADBs (Commercial Banks):

    ADBs should prepare for increased demand from IMTOs to open and manage multiple naira settlement accounts and streamline onboarding processes accordingly. Banks will also need to closely monitor these accounts to ensure they are used solely for remittance flows and comply with FX funding requirements, while supporting IMTOs in meeting AML/CFT obligations.

  3. BDCs:

    Since ADBs are permitted to process foreign currency transfers from IMTO settlement accounts, BDCs may engage ADBs and their IMTO partners to access this FX liquidity.

  4. General Market Effects:

    In general, the measures are expected to improve transparency by channeling remittance flows through the formal banking system, giving the CBN greater visibility into FX inflows. In the medium term, it is expected that this will reduce reliance on informal markets, support better rate alignment, and contribute to improved liquidity and stability in the FX market.

Conclusion

The CBN’s new measures on diaspora remittances are part of a series of significant steps toward formalising diaspora remittance flows and improving transparency in Nigeria’s foreign exchange market. By mandating designated settlement accounts, real-time pricing, and stricter compliance standards, the framework is expected to enhance liquidity, strengthen regulatory oversight, and reduce reliance on informal channels. While stakeholders will need to adjust their operations to meet the new requirements, the CBN expects that the reforms should, over time, support better price discovery and contribute to greater stability of the naira.

NIGERIA TRADE REGULATORY UPDATE: NATIONAL SINGLE WINDOW PLATFORM LAUNCH AND IMPORT RESTRICTIONS

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By Seun Timi-Koleolu and Omodele Fatodu

Introduction

Nigeria’s trade regulatory landscape has recently seen developments aimed at improving trade administration and strengthening import controls. In particular, the Federal Government has announced the launch of the National Single Window Platform (the “Platform”), a digital system designed to streamline import and export processes, while also announcing a ban on items prohibited from importation into Nigeria in 2026.

These developments form part of broader government efforts to modernise Nigeria’s trade infrastructure, enhance border control mechanisms, and promote local production.

1. National Single Window Platform

The Federal Government is set to launch the Platform on 27 March 2026 as a centralised electronic portal for the processing of trade-related documentation. The Platform is intended to allow importers and exporters to submit trade information through a single interface, which will then be automatically shared with the relevant government agencies for processing.

Nigeria has previously explored the introduction of a national single window system as part of broader trade facilitation reforms, with earlier initiatives dating back to the late 2000s. However, those efforts did not result in a fully integrated system. While aspects of Nigeria’s trade administration have been digitised through platforms such as the Nigeria Trade Portal, which provides information on import and export procedures and serves as an access point to certain trade related processes, regulatory approvals and trade documentation have historically been administered across multiple agency systems. For example, importers typically process a Form M (a mandatory import declaration form) through an authorised dealer bank, submit cargo documentation to the Nigeria Customs Service (“NCS”), and obtain product specific approvals or certifications from regulators such as the Standards Organisation of Nigeria (“SON”) and the National Agency for Food and Drug Administration and Control (“NAFDAC”).

The Platform is intended to address this fragmentation by enabling traders to submit trade data through a single electronic interface which can then be shared automatically among participating government agencies. It is expected to integrate several regulatory bodies within Nigeria’s trade ecosystem, including the NCS, SON, and NAFDAC. Through the Platform, traders will be able to submit documentation once, rather than interacting separately with multiple agencies. This approach is expected to reduce duplication of documentation requirements and facilitate greater coordination among regulatory authorities responsible for customs clearance, permits, and trade approvals.

Implementation of the Platform is expected to occur in phases. The initial rollout will focus on the online processing of import permits, electronic submission of cargo manifests, and a centralised risk management system. Subsequent phases are expected to incorporate additional trade processes, including export documentation and full system integration.

2. Federal Government Import Prohibition List

The Federal Government has also recently released a list of goods prohibited from being imported into Nigeria. The 2026 import prohibition list (the “Prohibition List”) covers a range of items across agricultural products, household goods, and manufactured items. By restricting the importation of certain products, the government aims to support domestic manufacturing capacity and reduce Nigeria’s reliance on imported consumer goods in specific sectors.

It is important to distinguish the Prohibition List from the foreign exchange restrictions previously imposed on certain imported goods which was lifted by the Central Bank of Nigeria (“CBN”) in October 2023. The Prohibition List imposes a ban on certain items into Nigeria while the former foreign exchange restrictions barred access to official foreign exchange for the importation of specified items.

Examples of items included in the Prohibition List include:

i. Frozen poultry products

ii. Used motor vehicles older than twelve years from the year of manufacture

iii. Spaghetti and noodles

iv. Fruit juice in retail packs

v. Bagged cement

vi.Certain pharmaceutical products such as paracetamol, chloroquine, and metronidazole

Importation of goods that fall within the prohibited categories is not permitted and can result in enforcement actions by customs authorities, including the immediate seizure and destruction of goods, legal action, and the imposition of applicable penalties.

Conclusion

Nigeria’s ongoing trade policy reforms reflect an effort to balance trade facilitation with regulatory oversight. The upcoming launch of the National Single Window Platform represents an important step toward modernising Nigeria’s trade administration through the digital integration of regulatory agencies.

For importers, exporters, and logistics operators, the Platform may improve the efficiency of documentation processes and potentially reduce administrative delays associated with multi-agency approvals. Over time, the system could contribute to more streamlined customs clearance procedures and improved transparency in trade administration.

At the same time, the updated import prohibition list serves as a mechanism for regulating imports and supporting domestic economic policy objectives. Businesses involved in international trade and distribution activities should ensure that internal compliance processes include verification of import eligibility under Nigerian customs regulations.

Foreign Exchange Controls in Nigeria: Updated Rules for BDCs

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BY SEUN TIMI-KOLEOLU AND PROMISE ITAH

Introduction

On February 10, 2026, the Central Bank of Nigeria (CBN) issued a circular on Participation of Licenced Bureau De Change in the Nigerian Foreign Exchange Market (NFEM) (the “Circular”) allowing licensed Bureau de Change (BDC) to operate as intermediaries in the NFEM (the official foreign exchange market). This represents a significant policy shift, as BDCs had been excluded from accessing foreign exchange (FX) through official channels since July 2021 due to practices deemed to have contributed to exchange rate instability.

The Circular builds on the 2024 regulatory reforms, which strengthened capital requirements, licensing standards, reporting obligations, and compliance expectations for BDCs. According to CBN, the decision to re-admit BDCs aims to improve FX liquidity and ensure that legitimate end users can access foreign exchange more reliably.

In this newsletter, we highlight the key rules for BDC participation in the foreign exchange market and their practical implications.

What Are the New Rules for BDC Participation?

Under the Circular, licensed BDCs may participate in the NFEM, subject to the following requirements.

a. Weekly FX Purchase Limit: To manage liquidity and prevent excessive exposure, each licensed BDC may purchase up to $150,000 per week from any authorized-dealer bank. All purchases must be conducted at the prevailing market rate, with no preferential pricing arrangements.

b. Mandatory Resale Timeline and Position Restrictions (NFEM-Sourced FX): Any FX acquired under this scheme must be sold or used within 24 hours. BDCs cannot hold NFEM-sourced FX in their accounts beyond this period, and any unused balances must be returned to the market the next day. This rule prevents speculative hoarding and ensures that FX flows efficiently to end-users.

c. Settlement and Payment Structure: All FX transactions must be processed through bank accounts at licensed financial institutions. BDCs cannot route FX through third parties or non-customer intermediaries. Cash settlement is permitted, but it is strictly limited to no more than 25% of the transaction value, with the remainder required to pass through the banking system. This ensures that FX flows are traceable and transparent.

d. Compliance and Regulatory Oversight: In addition to operational limits, BDCs remain subject to enhanced compliance obligations:

i. Authorised dealers must perform full Know Your Customer (KYC) and due diligence on any BDC client before selling FX.

ii. Licensed BDCs are required to submit timely electronic reports of their transactions to the CBN and comply fully with all Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) rules.

iii. Anonymous transactions or round-tripping (buying FX at official rates and reselling it elsewhere for profit rather than for legitimate use) are strictly prohibited.

The Circular further reinforces that BDCs must operate within the broader Regulatory and Supervisory Guidelines for Bureau de Change Operations in Nigeria 2024.

What Are the Practical Implications?

a. For BDC operators:

i. Immediate Turnaround: BDCs must find buyers immediately or face the administrative burden of selling funds back to the NFEM within 24 hours;

ii. Strategic Forecasting: To avoid the inconvenience and potential losses involved in returning unused funds, BDCs must accurately forecast customer demand before purchasing their weekly $150,000 limit;

iii. Digital Accountability: The new framework emphasizes a “digital footprint,” requiring BDCs to integrate their IT systems with the CBN for real-time monitoring and reporting.

b. For the market and the public:

i. Easier access: The participation of BDCs in the official exchange market is expected to make it easier for the average person (travelers, students etc.) to obtain FX. Since BDCs are widely accessible to these users and are required to sell NFEM-sourced FX within 24 hours, supply of FX is expected to circulate more quickly to end users.

ii. Price stability: By prohibiting the hoarding of FX, the rules are expected to help reduce the extreme price jumps often seen in the parallel market.

Conclusion

The reintegration of licensed BDCs into Nigeria’s FX market provides a transparent and reliable channel for accessing foreign exchange. For businesses, it is likely to enhance predictability and reduce reliance on informal sources, while for BDCs, it reinforces the need to operate strictly within the established regulatory framework. The CBN expects that, when properly implemented, this structure will promote smoother FX flows, support effective business planning, and contribute to overall market stability.

 

For further information on any of the issues covered in this newsletter, please contact us at info@pavestoneslegal.com. At Pavestones, we deliver quality and innovative legal support across diverse industries, helping businesses operate in compliance with applicable laws and regulations to drive sustainable business growth.

THE 2026 CBN FINTECH REPORT; DEFINING THE FUTURE OF FINTECH IN NIGERIA

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BY ADERONKE ALEX-ADEDIPE AND ENIOLA SOGBESAN

Introduction

The publication of the Fintech Report (the “Report”) by the Central Bank of Nigeria on February 2, 2026 represents a significant milestone in Nigeria’s fintech regulatory landscape. It is the first sector-wide review after the release of the Payment Systems Vision 2025 in 2022. The Report signifies a shift towards more coordinated regulation, simplified licensing processes and deeper institutional engagement with the fintech ecosystem. In summary, the Report reinforces CBN’s intention to balance innovation with stability of the financial system and market confidence.

Key Report Insights

Based on engagement with the fintech ecosystem, the Report identified several key challenges that will guide policy development and regulatory priorities going forward. These include:

  1. Persistent infrastructure gaps
  2. Increased regulatory compliance costs
  3. Longer time-to-market due to compliance bottlenecks
  4. Increased use of artificial intelligence in driving real-time payments
  5. Split perception of regulatory framework(s).

Based on the key insights obtained from engagement with the fintech ecosystem, the Report identified three (3) top-level objectives that will guide Nigeria’s fintech policy framework –

  1. Enable innovation-friendly regulation
  2. Advance financial inclusion through digital infrastructure
  3. Strengthen system integrity and reputation

These objectives will serve as the foundation of the proposed CBN reforms for the fintech ecosystem. These reforms are timely, given that notwithstanding the sustained expansion of Nigeria’s fintech ecosystem, operators continue to grapple with practical regulatory challenges—ranging from unclear compliance obligations, extended approval timelines, limited inter-agency coordination and a lack of clear oversight of emerging areas.

Policy Priority Initiatives

Following stakeholder feedback and guided by the three (3) top-level objectives, the Report outlines ten (10) priority areas that will guide CBN policy formulation for the ecosystem. These priority areas are –

  1. Launch a Standing Fintech Engagement Forum – This forum will serve as a dedicated, institutionalized platform for engagement between regulators and operators. To complement this forum, the CBN will support the establishment of a Self-Regulatory Organisation (SRO) within the fintech ecosystem, building on the progress of existing bodies, like FintechNGR.
  1. Operationalize a Single Regulatory Window – Establish a digital portal to coordinate licensing and supervisory processes across regulatory bodies. While the Report recognizes that a fully integrated system might be ambitious, this step would help streamline compliance frameworks and improve time-to-market timelines for regulated entities.
  1. Expand Regulatory Sandbox and Innovation Pilots – The expansion of the regulatory sandbox to support experimentation in emerging areas like artificial intelligence, cross-border payments etc. This will also include the expansion of the sandbox to a broader range of institutions such as MFB’s, PSBs, and Telco’s in pilot schemes. 
  1. Creation of an Industry-Government Digital Trust Charter – The Charter will serve as a shared framework between regulators and service providers. It will define areas such as responsible innovation, data governance, cybersecurity standards and consumer protection. The Charter may take the form of a voluntary code of conduct or may be embedded within licensing frameworks.
  1. Expansion of Digital Banking Licenses to Support Inclusive Financial Services – The CBN will assess how a dedicated digital banking framework could enable new market entrants to safely offer credit and savings services, subject to appropriate safeguards. To avoid conflicts with existing PSBs and MFB’s frameworks, the framework could create a consolidated digital banking license, rather than introducing an entirely new license category.
  1. Accelerate Open Banking Implementation -The Report emphasizes the timely rollout of Nigeria’s open banking protocols, including technical standards, governance structures, and dispute resolution mechanisms.
  1. Expansion of access to Digital Identity Infrastructure – Under this initiative, the CBN will work with relevant authorities to reduce barriers to affordable, API-based digital identity verification for regulated entities. This is designed to reduce onboarding friction and support more inclusive access to credit and other services.
  1. Strengthen Data Sharing and Credit Infrastructure – The CBN will review data-sharing rules and pricing models to support interoperability and reduce the cost of access to credit reference systems for fintechs and non-bank financial institutions.
  1. Advance Regional Regulatory Harmonization – The Report encourages CBN to engage with regional central banks and economic blocs such as ECOWAS to pilot the mutual recognition of licenses or establish regional sandbox programs.
  1. Position Nigeria as a Hub for Responsible AI in Finance – The Report further encourages the CBN to adopt a ‘test-then-codify’ approach, where learnings from the regulatory sandbox are converted into formal rulebooks / regulations.

Actionable Framework

To implement these policy priorities, the Report proposed the development of the following frameworks/digital portals:

  1. Regulatory Engagement Platform (REP)
  2. Smart Licensing and Supervisory Gateway (SLSG)
  3. Open Finance Lab (OFL)
  4. Fintech Trust and Safety Charter (FTSC)
  5. Fintech Credit Guarantee Window (FCGW)

Implementation

As set out in the Report, the proposed policy reforms are to be implemented in phases as follows:

Phase 1: Immediate Priorities (0–3 months)

  1. Establish Fintech Engagement Forum under CBN leadership.
  2. Issue implementation roadmap for Open Banking and initiate industry sensitization.
  3. Begin technical scoping for Single Regulatory Window and Smart Licensing Gateway.
  4. Coordinate cross-agency review of PSB lending restrictions and digital ID access

Phase 2: Near-Term Reforms (3–9 months)

  1. Launch pilot cohort for Regulatory Sandbox 2.0 including AI and RegTech use cases.
  1. Operationalize Fintech Credit Guarantee Window in collaboration with DFIs.
  1. Issue guidance on data portability and consumer protection under Open Finance.
  1. Initiate bilateral consultations on regulatory passporting (Ghana, Kenya, Senegal).

Phase 3: Institutionalization and Scale (9–18 months)

  1. Formalise Fintech Advisory Council to oversee implementation and course correction.
  2. Launch Regulatory Engagement Platform and public calendar of consultations.
  3. Embed supervisory analytics and early-warning tools through SupTech pilots.
  4. Participate in ECOWAS and AU regulatory alignment fora to shape continental norms.

Conclusion

With the Report indicating a shift towards a more organized and collaborative regulatory regime, these proposed reforms are designed to achieve the overarching top-level objectives of the CBN. However, the effective implementation of the proposed reforms will rely on the sustained engagement between regulators and the fintech ecosystem, strengthened supervisory capacity and effective alignment with regional and development partners.

For fintech service providers, the immediate priority is to gradually align internal operational frameworks with anticipated regulatory tools particularly around licensing, supervisory reporting, digital identity, and cross-border operations. If implemented correctly, these reforms will consolidate Nigeria’s position in the fintech ecosystem as a continental pacesetter while balancing innovation with systemic integrity and regulatory compliance.