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Anatomy of Fintech Law

Data access, analytics, and innovative aggregation are crucial to exploring entrepreneurial opportunities in Nigeria’s 2023 Open Banking Guidelines. The Open Banking Guidelines aim to democratize data for product information services, market insights, and scoring through consensual personal information and financial transaction data.


Open banking will transform Nigeria’s financial services industry by promoting competition, innovation, and customer-centred products and services.

The Central Bank of Nigeria (“CBN”) introduced the Regulatory Framework for Open Banking in Nigeria (the “Open Banking Regulation”) in February 2021.

In March 2023, the CBN issued Africa’s first Operational Guidelines for Open Banking in Nigeria (the “Open Banking Guidelines”) to facilitate secured sharing of financial data between banks and other financial institutions such as Fintech and licensed third-party providers (“TPPs”).

Licenced TPPS include businesses, namely, logistics and courier, retailers and supermarkets, Fast-Moving Consumer Goods (FMCGs), or payroll service bureaus.

There are four-tiered participants in the open banking registry as follows:

  • Tier 0: Product Information Service Touchpoint (PIST)
  • Tier 1: Market Insight Transactions (MIT)
  • Tier 2: Personal Information and Financial Transaction (PIFT)
  • Tier 3: Profile, Analytics and Scoring Transaction (PAST)

Tiers zero and one need not be CBN-supervised entities. Two and three must sponsor Tiers zero and one to the Open Banking Registry (OBR).

Identifying entrepreneurial opportunities in open banking in Nigeria requires careful consideration of legal and regulatory requirements to ensure compliance and foster a thriving open banking ecosystem.

What is Open Banking?

Open Banking in Nigeria refers to sharing and exchanging financial data between banks and authorized TPPs through open APIs (Application Programming Interfaces) – with the customer’s consent unless required by a court of law.

Open Banking is a financial inclusion tool because it will promote customer-centred product design and product or service adoption.

With Open Banking, customers enjoy greater control over their financial data and access to personalized financial services.

Open Banking Guidelines regulate how banks and TPPs process and aggregate data in Nigeria’s financial services sector.

Open Banking is in its early stages in Nigeria. It can drive positive changes in the banking industry and improve the overall customer experience.

Entrepreneurial Opportunities in Open Banking

We highlighted the four-tiered services in Open Banking above. We do not claim that the business opportunities discussed below are exhaustive – an idea against the entrepreneurial spirit.

Third-Party Payment Services: As a licensed TPP, there are opportunities to provide innovative payment solutions that leverage open banking.

Nigerian Regulators such as the NCC informs us that Nigeria has over 222 million active telephone subscribers.

We submit that such data need more aggregation and can misinform policymakers and partners. Why? On average, every adult Nigerian subscribes to two telephone numbers and ISP (internet service provider). We may have less than 100 million active telephone subscribers in Nigeria.

Similarly, every adult Nigerian has more than one active bank account. Data aggregation services are available in Open Banking.

Home grown data intelligence – data aggregated by Nigerians in Nigeria – is critical to our national development because governments rely on data aggregated by non-Nigerians outside Nigeria.

With data intelligence, entrepreneurs can develop mobile payment apps, digital wallets, or peer-to-peer payment platforms to enable seamless and secure financial transactions for the underbanked and the unbanked.

By utilizing open banking APIs and integrating with banking systems, entrepreneurs can offer convenient payment services to identified cloisters of underserved individuals and businesses.

Financial Data Aggregation and Analytics: Open Banking allows for secure financial data sharing. Open Banking presents opportunities to aggregate and analyze financial consumers’ data to provide valuable insights.

Policymakers, regulators, products and service providers will benefit from intelligent data in Open Banking. Entrepreneurs can develop platforms or services that aggregate data from multiple banks and financial institutions, offering individuals and businesses a comprehensive view of their financial health.

NIBSS is a handy partner for payments and payment processing data in Nigeria. Open Banking APIs must be interoperable and capable of interacting with banking and payment infrastructure.

Leveraging advanced analytics and data visualization techniques enables entrepreneurs to deliver personalized financial management tools, budgeting apps, or investment advisory services.

Personal Finance Management: Open banking provides access to real-time financial data, enabling entrepreneurs to develop unique finance management solutions.

Entrepreneurs can create apps or platforms that help individuals track their expenses, set financial goals, and receive customized recommendations for budgeting and saving.

Although pension contribution is compulsory in Nigeria, customer experience and customer-centred services require PFAs (Pension Fund Administrators) to utilize aggregated data in Open banking to promote personalized pension services that enable employees voluntarily contribute more to the pension pool.

Credit Scoring and Loan Services: Access to real-time financial data through open banking can revolutionize the credit assessment process.

An integrated credit scoring and assessment approach requires centralized access to banks and other lending firms’ customers’ financial data.

The CBN’s led National Collateral Registry is an underutilized asset – only CBN-supervised entities can input data on the national collateral registry.

With Open Banking, digital and traditional money lenders can develop Open Banking APIs that interface with the national collateral registry and enhance collateralization – a key challenge in money lending in Nigeria.

Entrepreneurs can develop credit scoring models and lending platforms that utilize this data to provide quick and accurate loan assessments.

By leveraging open banking APIs and analyzing various data points, such as income, spending patterns, and repayment history, entrepreneurs can offer innovative loan products, microcredit services, or alternative lending platforms to individuals and small businesses.

Identity Verification and KYC Solutions: Open Banking Guidelines emphasize the importance of secure customer identification and know-your-customer (KYC) procedures. Entrepreneurs can explore business opportunities in developing robust identity verification solutions that comply with Open Banking regulatory requirements.

Identity and identification are critical challenges in Nigeria. It is challenging for governments to identify a deceased beneficiary. Identification is still speculative in Nigeria because of bespoke centralized life-cycle means of identification from birth to death.

There are no available digital dashboards to access the death registry, criminal records, or birth registry. Critical information to public governance and public services such as probate, asset tracing and recovery, social insurance, payments and pension.

With an integrated access point for critical data, Open Banking API solutions can leverage biometric authentication, facial recognition, or other advanced technologies to streamline public service and customer onboarding processes for private and public enterprises.

Financial Education and Literacy: Open banking should promote financial education and literacy in Nigeria. Entrepreneurs can develop financial educational platforms, apps, or services that empower individuals to make informed financial decisions.

By leveraging open banking data and providing accessible financial educational resources, entrepreneurs can offer financial literacy programs, investment guides, or interactive learning platforms that enhance financial knowledge and promote responsible economic behaviour.


Entrepreneurial opportunities under the Open Banking Guidelines include accessible financial data, analytics, aggregation, and agility.

Open Banking promotes democratized data for product information services, market insights, and scoring through consensual personal information and financial transaction data.

Businesses in Open Banking include third-party payment services, financial data aggregation and analytics, personal finance management, credit scoring and loan services, identity verification and KYC solutions, and financial education and literacy.

These opportunities leverage the power of open banking APIs, real-time financial data, and advanced technologies to provide innovative and customer-centric financial services.

However, entrepreneurs must navigate the legal and regulatory landscape to ensure compliance and foster a thriving open banking ecosystem. Banks and Fintech sponsor other stakeholders to the Open Banking Registry (OBR).

Open Banking Guidelines embedded the principle of collaboration. Collaboration among financial institutions, fintech companies, and other stakeholders is essential – to access necessary data and APIs and build customer trust.

Open Banking can transform the financial services industry by promoting competition, innovation, and financial inclusion.

Entrepreneurs who seize these opportunities can play a pivotal role in shaping Nigeria’s financial services future – and reap the huge financial and social benefits.


Fintech lawyers at SRJ are willing to accompany you through your journey. From conceptualization, licencing and strategic relationship, API compliance audit, sandbox testing, and Go Live – the entire funding cycle. Would you consider speaking with us today or booking a Call?

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