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Conduct and safeguarding for Nigerian PSPs flow from the structural rule that only MMOs/PSBs hold customer funds, plus the CBN Consumer Protection Regulation 2019 and Consumer Protection Framework 2016. MMO customer balances are held in nominee/trust-style accounts and the unspent mobile-money float is insured by the NDIC up to the applicable coverage level. PSSPs and other non-fund-holding fintechs cannot hold funds, so they rely on bank/MMO partnerships. The CBN's Consumer Protection and Financial Inclusion Department (CPFD) supervises conduct, and the Nigeria Data Protection Act 2023 adds data-protection obligations.
The firm-type distinction is central here: this safeguarding architecture applies to non-bank PIs/EMIs operating as MMOs that hold subscriber float, whereas bank-PSPs and PSBs hold funds as deposits under the prudential regime rather than as segregated e-money float. The mechanism maps to a trust-account model, with NDIC insurance forming a secondary protective layer for non-bank e-money float.
Outlook
The safeguarding position is established. The forward conduct development to watch is the APP-fraud reimbursement draft (carried in W10), which would add a mandatory consumer-redress liability layer on top of the existing fund-protection architecture.
Conduct, Safeguarding & Financial Promotions
Nigeria's conduct-regulation posture shifted from advisory toward mandatory this cycle. The Central Bank of Nigeria's 2026 rule package introduces authorised-push-payment fraud liability-sharing, under which fintechs may be required to reimburse fraud losses even where the underlying transaction was self-initiated by the user, with liability split between sending and receiving institutions and full-loss exposure attaching where an institution fails to flag a suspicious account. This is paired with a mandatory real-time transaction-monitoring requirement for regulated payment institutions, to be rolled out in phases and accompanied by audit requirements.
Together these two obligations represent a materially higher compliance-cost baseline for regulated payment-service providers than previously existed, and industry-side evidence corroborates the burden: a survey reported that 87.5 percent of surveyed Nigerian fintechs say compliance costs are actively limiting their ability to innovate. This is a directional signal of industry strain rather than a confirmed market-wide metric, but it is consistent with the scale of the conduct obligations introduced alongside the market-concentration measures covered elsewhere this cycle.
The shift from advisory guidance to binding liability-sharing and monitoring obligations is more structurally significant than the compliance-cost survey itself: it changes the default allocation of authorised-push-payment fraud risk in Nigeria's payments market, with direct implications for how non-bank payment institutions in particular price and resource their fraud-control functions.
Outlook
Whether the compliance-cost strain reported by surveyed fintechs translates into consolidation, exit, or M&A activity among smaller non-bank payment-service providers ahead of the December 2026 divestiture deadline is the key development to watch, alongside the phased rollout timeline for mandatory real-time transaction monitoring.
Sources and findings (4)
- T3https://www.goldsmithsllp.com/the-new-central-bank-of-nigeria-regulatory-framework-and-guidelines-for-mobile-money-services-in-nigeria/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T1https://www.cbn.gov.ng/Out/2021/CCD/Framework%20and%20Guidelines%20on%20Mobile%20Money%20Services%20in%20Nigeria%20-%20July%202021.pdfretrieved
- T3https://www.nigerianjournalsonline.com/index.php/COOUJPPL/article/download/3959/3849 [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T3https://manifieldsolicitors.com/licensing-in-nigerias-fintech-industry-understanding-the-cbns-framework/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]