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:
- Persistent infrastructure gaps
- Increased regulatory compliance costs
- Longer time-to-market due to compliance bottlenecks
- Increased use of artificial intelligence in driving real-time payments
- 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 –
- Enable innovation-friendly regulation
- Advance financial inclusion through digital infrastructure
- 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 –
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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:
- Regulatory Engagement Platform (REP)
- Smart Licensing and Supervisory Gateway (SLSG)
- Open Finance Lab (OFL)
- Fintech Trust and Safety Charter (FTSC)
- 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)
- Establish Fintech Engagement Forum under CBN leadership.
- Issue implementation roadmap for Open Banking and initiate industry sensitization.
- Begin technical scoping for Single Regulatory Window and Smart Licensing Gateway.
- Coordinate cross-agency review of PSB lending restrictions and digital ID access
Phase 2: Near-Term Reforms (3–9 months)
- Launch pilot cohort for Regulatory Sandbox 2.0 including AI and RegTech use cases.
- Operationalize Fintech Credit Guarantee Window in collaboration with DFIs.
- Issue guidance on data portability and consumer protection under Open Finance.
- Initiate bilateral consultations on regulatory passporting (Ghana, Kenya, Senegal).
Phase 3: Institutionalization and Scale (9–18 months)
- Formalise Fintech Advisory Council to oversee implementation and course correction.
- Launch Regulatory Engagement Platform and public calendar of consultations.
- Embed supervisory analytics and early-warning tools through SupTech pilots.
- 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.
“Aderonke is the Managing Partner and Co-founder of Pavestones, a modern, client-focused, full-service law Practice situated in Nigeria, with a global reach”
