title: Nigeria — Conduct, Safeguarding & Promotions | World Payments Monitor canonical: https://payments.gi/jurisdictions/nigeria/w1b/ publisher: Asymmetric Intelligence ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-06-23 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. Standing sub-brief · as of 26 June 2026 177 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Promotions The Nigerian safeguarding mechanism for non-bank e-money rests on a combination of trust-account segregation and deposit-insurance-style cover. Under the CBN Mobile Money Services Framework (July 2021), MMO customer mobile-money balances are held in nominee accounts on behalf of customers under CBN Payments System Management Department conditions, and the total outstanding unspent subscriber float must be insured up to the applicable NDIC coverage level. This is the functional analogue to UK and EU safeguarding regimes, relevant to any operator holding subscriber balances. 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. Periodic update · new data 2026-08-25 #### 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)** 1. T3 [https://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]](https://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]) 2. T1 [https://www.cbn.gov.ng/Out/2021/CCD/Framework%20and%20Guidelines%20on%20Mobile%20Money%20Services%20in%20Nigeria%20-%20July%202021.pdf](https://www.cbn.gov.ng/Out/2021/CCD/Framework%20and%20Guidelines%20on%20Mobile%20Money%20Services%20in%20Nigeria%20-%20July%202021.pdf) retrieved 2026-06-23 3. T3 [https://www.nigerianjournalsonline.com/index.php/COOUJPPL/article/download/3959/3849 [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://www.nigerianjournalsonline.com/index.php/COOUJPPL/article/download/3959/3849 [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 4. T3 [https://manifieldsolicitors.com/licensing-in-nigerias-fintech-industry-understanding-the-cbns-framework/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://manifieldsolicitors.com/licensing-in-nigerias-fintech-industry-understanding-the-cbns-framework/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication])