Central Bank of Nigeria (CBN)
There is a moment in every industry when one player stops following the trend and starts setting it. For African fintech, that moment may have just arrived, and it is coming from Lagos, Nigeria
The Central Bank of Nigeria has just released its first
dedicated fintech policy report, a sprawling, data-rich document that runs the
full length of the continent’s most active innovation ecosystem.
On the surface it is a national policy
paper. Underneath, it is something far more consequential: a
declaration that Nigeria intends to stop being simply the fastest- growing fintech
market in Africa
and start becoming
the one that writes the playbook that will
guide structured and sustainable scale across the continent.
For regulators in Nairobi, Cape Town, Accra and Dakar,
for investors watching
where the next wave of capital will flow, and for the millions of Africans who still lack access to basic financial services, this report deserves
more than a passing glance. It deserves a seat at the table.
THE BIGGER PICTURE
Nigeria is not the first African country to publish a
fintech strategy. Kenya did it years ago, riding the M-Pesa wave. South Africa
has long positioned itself as the continent’s financial gateway. Ghana
and Senegal have quietly built
some of the tightest regulatory sandboxes on the continent. Each of those countries
has a legitimate claim to fintech leadership.
But none of them have done what Nigeria is now attempting
to do in a single, consolidated document: lay out a comprehensive, sequenced, multi-stakeholder roadmap
that stretches from regulatory plumbing all the way to
cross-border passporting, and back to the last-mile farmer who still does not
have a bank account. That ambition, paired with the institutional weight of the
CBN behind it, is what makes this different.
The report is, in
essence, Nigeria drawing a line in the sand. It is saying:
we have the payments infrastructure, we have the ecosystem, we have the volume, and now we are going
to build the governance architecture to match. If
it delivers on even half of what it promises, the implications ripple across
every other fintech market on this continent.
THE ARCHITECTURE OF AMBITION
The CBN has organised its strategy around
three pillars, and each one reveals a different
dimension of Nigeria’s game-changing bet.
First:
Innovation-Friendly Regulation. Nigeria
is not pretending that its regulatory environment is already perfect.
The report is remarkably candid:
87.5% of fintech
operators say compliance
costs are materially dampening their ability to innovate. 37.5% say it takes
more than a year to bring a new product to market, while 62.5%point to delays
in approvals and ambiguity in guidelines as their top regulatory friction. The
CBN’s answer is not a vague promise of “streamlining”. It is a
concrete proposal for a Single
Regulatory Window, a standing fintech engagement forum, and a
Compliance-as-a-Service utility that would take the grinding weight of
duplicative reporting off smaller firms. If those mechanisms land,
time-to-market could compress dramatically, and the firms that benefit will not
just be Nigerian.
Second: Inclusion
Through Digital Infrastructure. This is where the report moves from
clever policy design to genuinely transformative territory. Nigeria still has
26% of its adult population financially excluded, rising to 47% in the North.
The CBN is not blaming mobile operators or blaming the market. It is diagnosing
the problem with surgical precision: fragmented digital identity systems, API
access that is too expensive, credit data that does not flow across platforms,
and USSD infrastructure that remains the lifeline for hundreds of millions of
feature-phone users across Africa. The proposals here, affordable digital-ID
APIs, expanded digital banking licences, interoperable credit rails, read less
like a Nigerian policy document and more like a continental infrastructure
blueprint.
Third: System
Integrity and Reputation. This is the
pillar that turns this report into something other countries cannot easily
replicate, because it requires a particular kind of honesty. Nigeria carries a
reputational burden in global finance. The CBN does not flinch from it. The
report acknowledges the fraud problem head-on, but it also makes a case that is
both evidence-based and compelling: a significant share of digital financial
crimes attributed to Nigeria are orchestrated by foreign actors using the
country as a proxy. Nigeria’s exit from the FATF grey list is the headline
proof that the enforcement machinery is real. Pairing that enforcement
credibility with transparent communication is, the report argues, the key to
unlocking the next wave of international investment. It is a mature, unsentimental approach to
reputation. Rare anywhere. Rarer still in Africa.
THE CONTINENTAL VIEW
The temptation, when a single country makes a bold policy play, is to treat it as a local story.
A regulatory reshuffle here, a new sandbox there. But Nigeria’s report
is not a local story. It is a strategic repositioning with direct consequences
for every other fintech market on this continent, and the logic is worth
tracing carefully.
For regulators
across Africa, the most consequential
proposal in the CBN report may be the one that gets the least headline
attention: regulatory passporting. Nigeria is proposing bilateral pilots with
Ghana, Kenya, Senegal and South Africa, frameworks that would allow mutual
recognition of licences across borders. If those pilots work, they do not just
ease expansion for Nigerian
fintechs. They create
a template. They lower the bar for every startup
on this continent that has ever been told, “You need a separate licence in every single market.” For investors, the report sends a signal that Nigeria is serious about
reducing the risk premium that has historically attached to African fintech. A
Fintech Credit Guarantee Window, secondary-market mechanisms for fintech debt,
and the kind of regulatory predictability that the Single Regulatory Window
promises, these are the building blocks of an ecosystem that institutional
capital can actually scale into. The numbers already tell part of the story:
Nigerian startups raised over US$520 million in 2024. That figure could look
very different if the infrastructure underneath it finally catches up.
For the
unbanked, the report’s language about
inclusion is not aspirational fluff. It is operationally specific in a way that
matters. Tiered KYC. Affordable digital-ID APIs. USSD channels that actually
work. Digital banking licences that allow new entrants to offer credit, not
just payments. The shift the CBN is signalling, from payments penetration to
productive finance, from transactions to credit, savings and capital formation
for informal enterprises, is the kind of policy evolution that other African
central banks have been circling
for years without committing.
THE TURNING POINT
Something rare is happening inside this report, and it is
worth pausing on. The CBN is not writing policy in a vacuum. This document is
the direct product of a quantitative survey of fintech operators, a closed-door
workshop where industry leaders spoke candidly, and a high- level roundtable held in October
2025. The ecosystem did not just get consulted, it co-authored the
agenda. That kind of genuine, structured partnership between regulator and
industry is exactly the condition under which African fintech policy has
historically stalled. Nigeria is breaking that pattern.
And the groundwork is already laid in ways that matter.
The policy frameworks are not aspirational, they are in place. PSV2025, the AML
regulations, the cybersecurity guidelines, the open banking rules: these
are not future
intentions. They are operational foundations. What the CBN is now
doing is turning foundations into momentum. The phased roadmap, three months,
nine months, eighteen, is specific enough to be credible and ambitious enough
to be transformative. A Fintech
Advisory Council to oversee execution. A dedicated implementation secretariat to sustain it.
System-level indicators to measure it. These are the scaffolding of an
ecosystem that is not just planning to move, it is built to accelerate.
Once that momentum takes hold, and the signals strongly
suggest it will, the effects will compound fast. A Single Regulatory Window does not just save time for Nigerian startups. It creates a model that every other African regulator will be
under pressure to replicate.
Passporting pilots with Ghana, Kenya and Senegal do not
just ease one corridor. They open a door that, once opened, is very difficult
to close. And a Fintech Credit Guarantee Window backed by development finance
institutions does not just de-risk
one cohort of MSME lenders. It proves that inclusive finance
can be commercially viable at scale. Each piece of this architecture reinforces the others. That is not incremental reform.
That is a system designed
to tip.
THE BOTTOM LINE
THIS IS NOT
JUST NIGERIA’S STORY. IT IS AFRICA’S.
Every fintech operator on this continent has felt, at
some point, the weight of fragmentation. Different rules in every market.
Compliance costs that eat into margins before a product even launches. Identity
systems that do not talk to each other. Credit data that disappears at the
border. Nigeria’s CBN report does not solve all of those problems. Nothing
written in a single document ever could. But it does something that no other
African regulator has done at this scale and with this degree
of specificity: it names the problems, proposes
the solutions, sets the
timeline, and invites the ecosystem to hold it accountable.
That
is what a game changer
looks like, not a revolution overnight, but a credible, sequenced bet that Nigeria is going to
stop waiting for the continent to catch up and start building the
infrastructure that lets everyone move faster together.
The rest of
Africa should not just be watching. It should be taking notes.