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Anatomy of Nigerian Fintech Laws

In July 2022, the CBN permitted the customer-presented mode in Nigeria’s QR Code payments as an alternative to the merchant-presented. Our commentary determines if the customer-presented mode in QR Code Payments is a market-oriented approach to regulating technology in Nigeria.


QR (Quick Response) Code payments is a type of contactless payment. My colleague, Titilayo Ibisagba and I examined the CBN’s (Central Bank of Nigeria) Exposure Draft for Contactless Payment in Nigeria here.

As the CBN struggles to keep pace with payment technologies, operators in Nigeria’s payment systems are rolling out contactless payments.

Switchio insists that it associated with Skye Bank to implement contactless payments in Nigeria’s Lagos public transport buses.

Irfan Bashir et al[1]. submit that Quick Response (QR) code radically ousted the bar code era. QR code is a classic technological advancement, transforming how consumers interact with sellers and service providers.

Although Irfan Bashir et al., in their 2013 journal publication did not precisely foresee the use of QR codes in the payment systems. They posited QR codes’ uses in mobile operating systems, the retail industries, restaurants, libraries, textile apparel, and education.

In 2021, the CBN issued the Framework for Quick Response (QR) Code Payments in Nigeria (the “QR Code Payment Framework”) and revised the QR Code Payment Framework in July 2022.

CBN insists that QR codes payments can present, capture and transmit payment information across payments infrastructure. QR code payments technology enables a mobile channel to facilitate payments and presents a veritable avenue for promoting electronic payments for micro and small enterprises.

QR Codes Payments in Nigeria

All QR codes payments integrated into Nigeria’s payment system must be EMV®[2] QR Code compliant. The CBN may approve any other kind of QR Code payment standard, provided it is secured with the required interoperability.

Cost-effectiveness to the end-users (merchants and customers) appeals to the CBN’s approval. Any QR code payments in Nigeria shall support account, wallet, card and token based QR Code Operations.

Fundamental Change in the 2022 Revised QR Code Payment Framework

The 2021 QR Code Payment Framework allowed merchant-presented mode only. Merchant-presented mode is where merchants present the QR Code payments (platform) for buyers to accept to conclude payment transactions.

The merchant-presented mode was a single approach with the attendant hardship. Once the merchant’s QR code payments service provider’s platform suffers a downtime, QR code payments fail.

The customer-presented mode that the revised QR Code Payment Framework introduced widened customers’ QR code payment choices. Customers could present a QR code payments application different from the merchants, in any case.

Participants in the QR Code Payments

Stakeholders in the QR code payments include:

  • Merchants
  • Customers
  • Issuers (Banks, MMOs and Other Financial Institutions)
  • Acquirers (Banks, MMOs and Other Financial Institutions)
  • Payments Service Providers

Each participant enjoys duties and rights under the QR Code Payments Framework. Interoperability is a crucial aspect of QR code payments. All issuers, acquirers, switches, processors and other participants in QR payments in Nigeria shall ensure full interoperability of QR Code Schemes in Nigeria.

Risk management principles in QR Code payments include AES (advanced encryption system). Updates and patches shall be duly certified by the Payment Terminal Service Aggregator (PTSA) – usually NIBBS -, and only PTSA-certified QR code will be recognized in the payment system.

Issuers and Acquirers should agree on minimum due diligence guidance for merchant on-boarding without prejudice to CBN’s KYC/AML requirements of the Bank.

CBN’s industry fraud desk framework applies together with other CBN regulatory frameworks for Nigeria’s payment system.


Adoption of QR code payments is slow in Nigeria, unlike other West African Francophone countries where QR code payments are mainstream payment options.

A customer-presented mode is a market-driven approach to regulating financial technology. The CBN and operators in the payment systems hope that a customer-presented mode in the QR code payment may deepen the adoption of QR code payment in Nigeria.

It appears too early to assess the adoption of QR code payments following the July 2022 revised QR Code Payments Framework.

Operators and exceptionally agile fintech that want to play in the QR code payments must innovate on the best route to the Quick Response (QR) code payments market.

We take for granted that the Nigerian consumer is also aspirational.

[1] Irfan Bashir,  Krishna Naik,  C. Madhavaiah Potential Business Applications of Quick Response (QR) Codes, <> accessed on 19.01.2023

[2] Euromoney Mastercard Visa specifications

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