NigeriaCBN Guidelines for the Operations of Agent Banking, October 2025, Security, Authentication and Geo-Fencing Controls
Guidelines for the Operations of Agent Banking in Nigeria, October 2025, ss. 9.3, 9.4 and 10.5 to 11
archived copy
Read from a public archive copy, not the publisher directly. The publisher does not serve this page to automated readers, so a direct fetch was not an option here; how we access sources. Archived 2025. Publisher's page: https://www.cbn.gov.ng/Out/2025/CCD/CIRCULAR%20AND%20GUIDELINES%20FOR%20THE%20OPERATIONS%20OF%20AGENT%20BANKING%20IN%20NIGERIA%20OCTOBER%206…In force.
A sector security regimes rule binding private bodies.
- Instrument type
- a regulation made under an act
- Obligation class
- Security
As of .
What it requires
- This binds a financial institution licensed by the Central Bank of Nigeria to act as a Principal in agent banking, meaning a commercial bank, non-interest bank, payment service bank, microfinance bank or mobile money operator (reached by declaring that you are a bank or a payment provider), and places duties on a Super Agent and on a Payments Terminal Service Aggregator where a section below names one.
- Make the technology you use for Agent banking transmit transaction information in a secure manner, reject suspicious transactions automatically, prevent an Agent automatically from exceeding the daily limit allowed or performing unauthorized transactions, and apply a minimum of Two-Factor Authentication per customer, per transaction (section 10.5).
- Put in place systems that address, at the minimum, physical and logical security of infrastructure, availability of services, data confidentiality and integrity, encryption of PIN and electronic transactions, customer accountability and non-repudiation of transactions, and error messaging and exception handling (section 10.6).
- Institute systems and personnel to monitor and control Agent banking operations on an ongoing basis, and maintain an incidence register with resolution timelines for reported incidents (section 10.7).
- Geo-fence or tag every device deployed to an Agent or used by an Agent so that it operates only within the agreed registered Agent premises or location (section 11).
- As a Payments Terminal Service Aggregator, register each PoS terminal deployed for Agent banking on your platform, facilitate its geo-fencing or geo-location, and integrate your Terminal Management System with the CBN Automated Regulatory Data Solutions (section 9.4).
- As a Super Agent, implement appropriate technologies for monitoring the online real time activities of Agents (section 9.3.2).
These lines are LexLint's reading of the law's text, as of .
If you get it wrong
Penalty structure
Item 13 of Appendix I to the Guidelines: a fine of not less than N5,000,000 for the offence and N300,000 for each day that the default persists, for a Principal or Super Agent that fails to implement the control parameters for its Agent banking operation, such as geo-locking the equipment. Section 14.3 adds sanctions against a Principal that include suspension from Agent banking business, a prohibition on onboarding new Agents and revocation of the Agent banking approval.
- Rule
- Per violation only
- As of
- Minimum
- 5,000,000
- Currency
- NGN
- Per violation unit
- Day
- Per violation amount
- 300,000
Over one month of continuous breach, NGN 9,132,000.
Who enforces it
Enforcement body
The Central Bank of Nigeria, which may invoke the sanctions in section 14 of the Guidelines against any defaulting participant in the Agent banking system.
What this law does
Section 10.5 of the Guidelines requires technology implemented by a Principal for Agent banking to include a minimum of Two-Factor Authentication per customer, per transaction. Section 10.5 of the Guidelines requires that technology to transmit transaction information in a secure manner. Section 10.5 of the Guidelines requires that technology to reject suspicious transactions automatically.
Section 10.5 of the Guidelines requires that technology to prevent an Agent automatically from exceeding the daily limit allowed or performing unauthorized transactions.
Section 10.6 of the Guidelines requires a Principal to put in place systems that address, at the minimum, physical and logical security of infrastructure, availability of services, data confidentiality and integrity, encryption of PIN and electronic transactions, customer accountability and non-repudiation of transactions, and error messaging and exception handling.
Section 10.7 of the Guidelines requires a Principal to institute systems and personnel to monitor and control Agent banking operations on an ongoing basis. Section 10.7 of the Guidelines requires a Principal to maintain an incidence register and provide resolution timelines for reported incidents.
Section 11 of the Guidelines requires any device deployed to an Agent or used by an Agent in carrying on Agent banking services to be geo-fenced or tagged to operate within the agreed registered Agent premises or location. Section 9.4 of the Guidelines requires a Payments Terminal Service Aggregator to register each PoS terminal deployed for Agent banking on its platform and to facilitate geo-fencing or geo-location of the terminal.
Section 9.4 of the Guidelines requires a Payments Terminal Service Aggregator to integrate its Terminal Management System with the CBN Automated Regulatory Data Solutions. Section 9.3.2 of the Guidelines requires a Super Agent to implement appropriate technologies for monitoring online real time activities of Agents.
Item 13 of Appendix I to the Guidelines sets a fine of not less than N5,000,000 for the offence and N300,000 for each day that the default persists, for the failure of a Principal or Super Agent to implement the control parameters for its Agent banking operation, such as geo-locking the equipment. The Guidelines apply to all Financial Institutions licensed by the CBN and authorised to engage in Agent banking activities.
The Guidelines define a Principal as any of the following entities, commercial banks, non-interest banks, payment service banks, microfinance banks, mobile money operators, and any other category of financial institution that the CBN shall authorize to accept deposit and carry out Agent banking activities. The Guidelines supersede all other CBN guidelines on Agent banking and Agent banking relationships. The Central Bank of Nigeria issued the Guidelines in October 2025.
Section 14 of the Guidelines provides that the CBN may, in the event of a breach of any provision of the Guidelines, invoke any or all of the sanctions in that section against any defaulting participant in the Agent banking system.
When LexLint raises it
When your app profile says your app is a bank or is a payment provider.