title: Nigeria — Consumer Protection & APP Fraud | World Payments Monitor canonical: https://payments.gi/jurisdictions/nigeria/w10/ publisher: Asymmetric Intelligence ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-06-23 Consumer protection sits with the CBN's Consumer Protection and Financial Inclusion Department (CPFD) under the Consumer Protection Regulation 2019 and Framework 2016, with the FCCPC and NCC as adjacent regulators; complaints route to the provider first then escalate to CPFD. A landmark development is the CBN's draft Guidelines for Handling Authorised Push Payment (APP) Fraud (dated 26 November 2025), introducing mandatory reimbursement: institutions acknowledge complaints within 24 hours, investigate within 14 working days, reimburse within 48 hours of conclusion (16 working days end-to-end), with customers required to report within 72 hours. There is an active debate about creating an independent financial ombudsman. Electronic-payment fraud reportedly fell 51% in 2025 after tighter controls. Horizon · 2026-H2 (± six months) CBN APP-fraud mandatory reimbursement guidelines finalisation_Consultation · Tier 1 source_ Horizon · 2026-04 (± a quarter) POS agent geo-tagging/location-compliance tightening_In force · Tier 3 source_ Standing sub-brief · as of 26 June 2026 235 words · last cycle 2026-10-18 #### Consumer Protection & APP Fraud The headline development is the CBN's draft Guidelines for Handling Authorised Push Payment (APP) Fraud, an exposure draft dated 26 November 2025, introducing mandatory reimbursement: institutions acknowledge complaints within 24 hours with a unique case reference, investigate within 14 working days, and reimburse within 48 hours of conclusion (16 working days end-to-end); customers must report within 72 hours; and where neither sending nor receiving bank is at fault but the customer qualifies, the two institutions share the refund equally. Electronic-payment fraud reportedly fell 51% in 2025. The regime is functionally analogous to the UK PSR model and materially shifts fraud-liability economics onto bank-PSPs, though it remains an exposure draft not yet in force. The standing redress architecture sits with the CBN Consumer Protection & Financial Inclusion Department under the Consumer Protection Regulation 2019 and Framework 2016. Complaints route provider-first then escalate to the CPFD, which operates 24/7 with a 94% timely-resolution rate. In H1 2025 the CBN resolved 9,771 of 10,704 complaints (up 143.3% year on year), with electronic-transaction and card issues at 51.5% and fraud at 39.27%, and refunds of ₦7.17bn. Consumer advocates support exploring an independent financial ombudsman. #### Outlook Consumer protection is escalating. The APP-fraud reimbursement draft is expected to be finalised in H2 2026, at which point fraud-liability economics shift onto banks and PSPs; the ombudsman debate signals a possible future structural change to the redress layer. Periodic update · new data 2026-09-28 #### Consumer Protection & APP Fraud Nigeria introduced a materially different Authorised Push Payment fraud liability regime in 2026: fintechs may now share or fully absorb losses from APP fraud even where the user initiated the transaction, a shift away from a purely user-responsibility default toward shared institutional accountability for fraud losses. This is a substantive consumer-protection change with direct commercial implications for fintechs' loss-provisioning and fraud-prevention investment decisions. Alongside the liability-sharing reform, real-time transaction monitoring became mandatory in 2026, with an audit-backed enforcement rollout timeline cited in reporting, though the precision of that rollout timeline carries some uncertainty in the underlying sourcing. The intended effect is that mandatory real-time monitoring should reduce the incidence of APP fraud reaching completion, which would in turn reduce the loss exposure fintechs face under the new liability-sharing rule; the two measures are complementary in their evident policy logic even though they were reported through separate sourcing. Both developments represent a tightening of the consumer-protection environment for Nigerian payments users, shifting a portion of fraud risk away from consumers and onto the institutions best positioned to detect and prevent it through monitoring infrastructure. #### Outlook The practical effect of the liability-sharing reform will depend on how disputes over "user-initiated" transactions are adjudicated in practice, and whether the real-time monitoring mandate's enforcement timeline holds firms to a meaningfully shorter fraud-detection window. Both measures merit continued tracking as concrete dispute or enforcement data emerges. **1 earlier distinct update(s)** Periodic update · new data 2026-08-25 #### Consumer Protection & APP Fraud Nigerian consumers gained materially stronger authorised-push-payment fraud protection this cycle through the Central Bank's shift from advisory to mandatory conduct rules. Under the new liability-sharing regime, fintechs may be required to reimburse APP-fraud losses even where the consumer self-initiated the transaction, with liability apportioned between sending and receiving institutions and full-loss exposure attaching to an institution that fails to flag a suspicious account. This is paired with a mandatory real-time transaction-monitoring requirement for regulated payment institutions, intended to detect fraudulent transaction patterns before losses crystallise. From a consumer-protection perspective, the structural significance of this shift is that it moves loss-allocation risk away from the individual consumer and onto the regulated institutions in the payment chain, reversing what has historically been a self-initiated-transaction defence available to payment-service providers in APP-fraud disputes. Industry-reported compliance-cost strain, 87.5 percent of surveyed fintechs reporting that compliance costs are limiting their ability to innovate, is the visible cost side of this consumer-protection gain, though this survey finding rests on a single source and should be read directionally rather than as a precise market-wide figure. #### Outlook How Nigerian payment-service providers operationalise the liability-sharing rules in individual fraud disputes, and whether the mandatory real-time monitoring requirement measurably reduces APP-fraud incidence once its phased rollout completes, are the developments most likely to indicate whether this cycle's consumer-protection shift delivers in practice rather than only on paper. **Sources and findings (5)** 1. T1 [https://www.cbn.gov.ng/Out/2025/CCD/Exposure%20draft%20of%20the%20Guidelines%20for%20Handling%20Authorised%20Push%20Payment%20Fraud.pdf](https://www.cbn.gov.ng/Out/2025/CCD/Exposure%20draft%20of%20the%20Guidelines%20for%20Handling%20Authorised%20Push%20Payment%20Fraud.pdf) retrieved 2026-06-23 2. T3 [https://punchng.com/cbn-orders-48-hour-refunds-for-app-fraud-victims/](https://punchng.com/cbn-orders-48-hour-refunds-for-app-fraud-victims/) retrieved 2026-06-23 3. T3 [https://techcabal.com/2025/12/02/nigerian-banks-16-days-fraud-refund-cbn/](https://techcabal.com/2025/12/02/nigerian-banks-16-days-fraud-refund-cbn/) retrieved 2026-06-23 4. T3 [https://www.legit.ng/business-economy/money/1693950-nigerian-bank-customers-complaints-surge-electronic-transactions-fraud-top-list/](https://www.legit.ng/business-economy/money/1693950-nigerian-bank-customers-complaints-surge-electronic-transactions-fraud-top-list/) retrieved 2026-06-23 5. T3 [https://efina.org.ng/wp-content/uploads/2025/12/Ask-the-Regulator-Communique-1.1-December-2025.pdf](https://efina.org.ng/wp-content/uploads/2025/12/Ask-the-Regulator-Communique-1.1-December-2025.pdf) retrieved 2026-06-23