Introduction
Nigeria’s digital payments ecosystem has experienced remarkable growth over the past decade. In response, the Central Bank of Nigeria (CBN) issued its circular titled “Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigeria Payments System.” The circular introduces a comprehensive framework to strengthen competition, improve transparency, enhance operational resilience, and safeguard the country’s payment infrastructure.
For banks, fintech companies, payment service providers (PSPs), investors, and corporate groups operating within Nigeria’s payments ecosystem, the circular represents more than just another compliance obligation and raises interpretive and structural questions that will require reassessing business models, ownership structures, technology infrastructure, and expansion plans.
Why the CBN Introduced These Measures
According to CBN, the reforms became necessary following the rapid expansion of electronic payments and digital financial services across the country. The rapid evolution of the digital landscape and increasing digitalisation of financial services have driven the growth of electronic payments, delivering significant benefits including improved efficiency in payment systems. At the same time, there have been several emerging risks such as the increased concentration of market power among a few dominant operators, growing dependence on foreign infrastructure for critical payment data, and limited transparency regarding the true owners of payment institutions.
