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Operational resilience is governed primarily by the CBN Risk-Based Cybersecurity Framework, first effective 1 January 2019 for DMBs/PSPs and replaced by a May 2024 version for DMBs and Payment Service Banks (with a separate 2022 OFI framework), structured around governance/oversight, risk management, operational resilience, metrics/monitoring/reporting and statutory compliance. It mandates a board-level CISO, annual cybersecurity self-assessment by 31 March, and incident reporting to the CBN within 24 hours. The financial sector is designated Critical National Information Infrastructure, and the framework reads with BOFIA 2020 and NDPA 2023.
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That perimeter is widening. In a 30 March 2026 circular the CBN mandated DMBs, PSBs, microfinance lenders, fintechs and other institutions to complete a newly deployed Cybersecurity Self-Assessment Tool (CSAT) capturing governance, third-party exposures, incident response and operational resilience, reflecting data as of 31 December 2025. This extends formal third-party-exposure and resilience self-assessment beyond banks to fintechs and MFBs, signalling a widening operational-resilience supervisory perimeter.
Outlook
Resilience supervision is escalating. The CSAT extension to non-bank operators is the clearest signal that the supervisory perimeter is broadening; absent a dedicated DORA-equivalent, the cybersecurity framework remains the vehicle through which operational-resilience expectations are imposed.
no periodic updates on record for this sub-brief
Sources and findings (4)
- T1https://www.cbn.gov.ng/Out/2024/BSD/CBN%20Risk-Based%20Cybersecurity%20Framework%20for%20DMBs%20and%20PSBs_2024.pdfretrieved
- T3https://www.cyberkach.com/2020/04/25/cbn-framework [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T3https://businessday.ng/news/article/cbn-gives-banks-three-weeks-to-deploy-cybersecurity-self-assessment-tools/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T3https://tnp.com.ng/insights/dissecting-the-central-bank-of-nigeria-risk-based-cybersecurity-frameworks-and-guidelines-for-deposit-money-banks-and-payment-service-providers [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]