The Central Bank of Nigeria’s 2025 Guidelines for the Operations of Agent Banking in Nigeria introduce stricter exclusivity rules, dedicated agent accounts, real-time and two-factor transaction mandates, and stronger AML/CFT and data-protection standards. They reshape Nigeria’s agency banking landscape by tightening supervision of agents, super agents, and PTSAs (Payment terminal Service Aggregators).
Our fintech lawyers’ insight highlights key regulatory changes, practical implications, and what they mean for banks, MMOs, fintech aggregators, and financial inclusion in Nigeria.
Background
The 2025 Guidelines for the Operations of Agent Banking in Nigeria, replaced the 2013 Guidelines for the Regulation 0f Agent Banking and Agent Banking Relationships in Nigeria.
The revised Guidelines consolidate all circulars into one comprehensive rulebook that aligns the sector with the realities of digital payments, POS proliferation, and fintech partnerships.
Aimed at deepening financial inclusion and prudential assurance, strengthening consumer trust, and standardising agent oversight in Nigeria’s payments.
What Changed and Why It Matters
- Exclusivity Reversed
Nigeria’s 2013 guidelines allowed agents to serve multiple financial institutions – promoted shared agent network. Now, each agent is exclusive to one principal, though a super-agent may aggregate for several principals.
Implication: This reduces brand confusion and simplifies accountability for fraud or KYC breaches. But small agents that once earned from multiple banks may see revenue compression, forcing them to choose stronger partners.
Additionally, uptime, service availability, and agents’ welfare packages may become key drivers for agent’s retention. Although we hope to see extensive notice periods for termination of agency contracts.
2. Dedicated Agent Accounts & Geo-fencing
For the first time, all agent transactions must run through a dedicated account or wallet with the principal, and POS devices must be geo-tagged to that location.
Operating outside that account is a regulatory breach that can trigger blacklisting.
Implication: Under the new 2025 regime, transactions must originate and terminate within each agent’s dedicated account. This means cross-border or third-party funding workarounds are no longer permissible. For example, Shuaib in Ghana can no longer send money to Musa’s Access Bank account for a Moniepoint POS payout in Lagos, nor can Adaugo, a Zenith Bank cardholder, fund Kester’s GTBank account to cash out through his firstmonie POS terminal. These were loopholes for untraceable settlements and fraud under the old framework – now closed through geo-fencing and account-level traceability.
3. Expanded Role of Super Agents and PTSAs
The Guidelines for the Operations of Agent Banking in Nigeria introduce explicit duties for PTSAs to geo-fence POS devices, link them to CBN’s Automated Regulatory Data Solution (“CARDS”) database and submit monthly transaction reports.
Implication: Previously, some PSSPs operated several POS devices under one Terminal ID, making fraud tracing difficult. The 2025 Guidelines now require unique terminal IDs, CARDS integration, and geo-fencing for every POS. Each device must be linked to a verified agent account, turning oversight from after-the-fact investigations into real-time regulatory visibility.
4. Higher Due-Diligence Thresholds
The CBN strengthens “Know Your Agent” requirements
- Individual agents must have valid BVN and NIN;
- Non-individual agents need CAC registration, three years’ tax clearance, and TIN records.
- Agents with non-performing loans or criminal records are ineligible.
Implication: We expect fewer informal operators and a gradual migration toward structured micro-enterprise models.
5. Operational and Transaction Limits
Daily customer cash-in/cash-out is capped at ₦100,000, weekly ₦500,000; agents’ own daily cash-out limit is ₦1.2 million.
Implication: This curbs AML exposure and encourages digital wallet adoption for larger transactions, shifting the market toward e-money solutions.
6. Real-Time and Two-Factor Mandates
All agent transactions must be real-time. Delayed value delivery or network failure must trigger instant reversal. A new two-factor authentication requirement per customer, per transaction, further elevates security.
Implication: POS payments were card-present transactions that required PIN only. The 2FA and customer identification introduces an additional verification step. While it enhances transaction security, it may slow down processing times and limit access for low-literacy or unbanked users, potentially affecting financial inclusion.
7. Data and Consumer Protection Reinforced
Principals must set up complaint centres, resolve all disputes within seven working days, and educate customers on PIN safety and data sharing risks.
Agents must issue receipts for every transaction and display branding that clearly shows they are service outlets, not banks.
8. Reporting and Transparency Obligations
Financial institutions must render monthly returns to the CBN covering transaction volumes, fraud incidents, customer complaints, training records, and geo-distribution of agents.
All returns must be signed by the MD/CEO and Chief Compliance Officer.
What Improved
- Clarity: Definitions and responsibilities are simpler and better segregated for Principals, Super Agents, Agents and PTSAs.
- Security: Mandatory 2FA, encryption standards and geo-fencing strengthen the trust layer.
- Fraud monitoring: Where applicable, principals and Super-agents must verify an agent’s previous engagement.
- Risk Alignment: CBN now links transaction limits to agent risk scores and liquidity profiles, a best practice long seen in Kenya and India.
- Governance: Board-level approval for each agent banking relationship reduces outsourcing abuse.
- Customer Focus: The seven-day complaint resolution deadline and branding rules protect consumers from identity fraud and fee gouging.
Practical Implications for Industry Players
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Conclusion
The 2025 CBN Guidelines for the Operations of Agent Banking in Nigeria signal a mature phase for Nigeria’s agency banking ecosystem. What began as a financial-inclusion experiment is now a regulated infrastructure layer with bank-grade obligations for every participant.
For fintechs and banks, the path forward is compliance by design – embedding real-time reporting, 2FA security, and strong data protection into every agent touchpoint.
At SRJ Legal, we believe this is a positive step toward building a more trusted cashless economy where agents are not just cash-handlers, but credible ambassadors of Nigeria’s banking system.
We help innovators, banks, and payment companies navigate Nigeria’s fast-evolving digital finance landscape. We advise on licensing, product design, open banking, agency banking, data protection, and regulatory compliance, and digital financial consumer protection.
