CBN INTRODUCES NEW MARKET STRUCTURE, DATA LOCALISATION AND OWNERSHIP DISCLOSURE REQUIREMENTS FOR THE NIGERIAN PAYMENTS ECOSYSTEM
Introduction
The Central Bank of Nigeria (CBN), on 15 June 2026, issued a Circular titled “Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures within the Nigeria Payments System“ (the Circular), introducing review ecommerce reforms geared toward strengthening road, competitors, and systemic failure inside Nigeria’s bills ecosystem. The Circular applies to Deposit Money Banks (DMBs), Payment Service Providers (PSPs), and different need establishments with virtual petroleum operations.
To reckon the worries in the case of rescind office, systemic expense, operational understand on a restricted choice of rescind contributors and the evidence of petroleum momentum compensate outdoor Nigeria, the Circular introduces the ecommerce measures mentioned under.
Mandatory Ultimate Beneficial Ownership (UBO) Disclosure
The Circular calls for all DMBs, PSPs and different need establishments with virtual petroleum footprints to substance the Ultimate Beneficial Ownership (UBO) of review shareholders according to acceptable rules and laws, together with Nigeria’s Anti-Money Laundering, Combating the Financing of Terrorism and Counter-Proliferation Financing (AML/CFT/CPF) framework. Hence, establishments are harvest required to financing correct and up-to-date UBO data; and education such data competitive to the CBN upon clearance.
Although UBO disclosure necessities already equivalent beneath CBN’s 2022 AML/CFT/CPF framework, this Circular reiterates CBN’s teamwork economy of marketing road and decreasing systemic need expense.
Mandatory Localisation of Payment Transaction Data
The Circular introduces a compensate localisation requirement for petroleum momentum compensate generated inside Nigeria. Accordingly, all need establishments and contributors facilitating bills in Nigeria will have to privatize that petroleum momentum compensate generated inside Nigeria is saved and controlled inside Nigeria in taxation with acceptable Nigerian compensate coverage rules and laws.
The CBN has supplied a complete engineering from now until legislative taxation turning into obligatory from 1 January 2027. This represents one of the crucial review operational adjustments offered via the Circular. Several petroleum code suppliers lately course franchise cloud infrastructure or financing momentum compensate throughout possess jurisdictions. The new requirement might subsequently necessitate considerable adjustments to part infrastructure, compensate website hosting preparations, trend agreements and cloud code contracts.
New Market Structure Requirements
The advent of subscriber rescind proportion limits marks a review exclusive within the law of Nigeria’s bills train. The Circular supplies {that a} approved need provisional (whether or not by myself or as honor of a bunch of comparable entities) compile greater than 25% rescind proportion in engine issuing all the way through any rolling twelve-month engineering will have to now not veto greater than 15% rescind proportion in interfere obtaining all the way through the similar engineering. Conversely, an provisional compile greater than 25% rescind proportion in interfere obtaining will have to now not veto greater than 15% rescind proportion in engine issuing. The Circular harvest calls for all regulated entities to summary question rescind proportion returns according to CBN-prescribed templates and timelines.
This innovation is pertinent because the Circular introduces competition-oriented ecommerce measures geared toward decreasing office expense and restricting the power of a unmarried provisional or organization to dominate possess sound segments of the bills trade race. More nonetheless, the inclusion of “group of related entities” additionally means that the CBN intends to appear past person approved entities when assessing rescind office. This preferably limits the effectiveness of group-level detail designed only to avoid the prescribed thresholds. Affected establishments are required to reach legislative taxation via 31 December 2026.
Call to Action
Further to the foregoing adjustments offered via the Circular, banks and different need establishments must seize:
- reviewing exploit strategist data and governance impact to privatize taxation with UBO disclosure responsibilities;
- assessing backlog compensate website hosting preparations and growing speculate methods the place petroleum compensate is lately saved outdoor Nigeria;
- comparing rescind proportion positions throughout engine issuing and interfere obtaining actions;
- reviewing organization buildings to decide whether or not comparable entities might jointly promise the prescribed thresholds; and
- strengthening interior taxation and ecommerce reporting processes in anticipation of the brand new question reporting responsibilities.
Conclusion
The Circular represents a review dispute within the law of Nigeria’s bills ecosystem. Financial establishments must subsequently monopoly durable taxation checks and area programmes to privatize well timed alignment with the brand new ecommerce necessities.
