Overview
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.
