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Circular on Introduction of Market Structure Requirement, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigeria Payments System

Finance & Economy
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Overview

This is a circular issued by the Central Bank of Nigeria (CBN) on June 15, 2026, introducing new regulatory measures for the Nigerian payments system. The document addresses four key areas: (1) Ultimate Beneficial Ownership (UBO) disclosure, requiring all Deposit Money Banks, Payment Service Providers, and other financial institutions to disclose the UBO of significant shareholders in line with AML/CFT/CPF regulations and maintain accurate records accessible to CBN; (2) Data localisation, mandating that all payments transaction data generated in Nigeria be stored and managed within the country, with full compliance required by January 1, 2027; (3) Market structure requirements to limit concentration risk: any entity with more than 25% market share in consumer issuing cannot hold more than 15% market share in merchant acquiring, and vice versa, as measured over rolling twelve-month periods; entities must submit monthly market share returns and achieve full compliance by December 31, 2026; (4) Systemic oversight measures to enhance the resilience and integrity of the payments ecosystem. The circular is issued to address concerns about market concentration, operational dependence, transparency of ownership, and localisation of critical payment data. It applies to all licensed operators in the Nigerian payments ecosystem including banks, mobile money operators, switching and processing companies, and payment service providers. The CBN will monitor compliance and enforce these requirements.

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