See the details about the CBN’s regulatory framework for Mobile Money Services aiming to drive financial inclusion


See the details about the CBN’s regulatory framework for Mobile Money Services aiming to drive financial inclusion

In an effort to enhance financial inclusion, the Central Bank of Nigeria (CBN) has recently released Regulatory Guidelines and Framework for Mobile Money Services in the country.

According to the CBN, the advent of mobile telephony in Nigeria, its fast development and acceptance, and the recognition of person-to-person payments as a viable approach for financial inclusion has made it critical to use the mobile channel to drive financial inclusion among the unbanked.


Financial inclusion continues to gain traction among policymakers, scholars, and development organizations all around the world. Its significance stems from the potential it presents as a vehicle for economic growth, notably in terms of poverty reduction, job creation, wealth creation, and increasing welfare and overall living standards.

Under Section 47(2) of the Act of 2007, the Central Bank of Nigeria (CBN) shall be empowered to foster and facilitate, in accordance with its mandate to promote a sound financial system in Nigeria, the establishment of an efficient and effective trading arrangements including electronic payment systems. CBN has therefore introduced the Mobile Money Services Guidelines in Nigeria in a bid to promote financial development.

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This Guideline covers business regulations governing mobile money service operations and describes the required fundamental features of any mobile payment service and solution in Nigeria. It describes and defines the participants in the mobile money services system in their expected roles and duties. It also lays the groundwork for regulating services provided at various levels by participants.

Key takeaways from CBN guidelines

These guidelines have defined two models for implementing mobile money services: bank-led (bank and/or its consortium as lead initiator) and non-bank-led (a corporate entity legally regulated by the CBN as lead initiator).

The Bank-Led Model

This is a model in which a bank, either alone or as part of a consortium of banks, aims to supply financial services through the mobile payments system. This model can be used in situations where the bank operates independently or in partnership with other banks and other permitted organizations. A bank or a group of banks will serve as the Lead Initiator.

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The non-bank led approach

This approach permits a corporate entity that has been properly licensed by the CBN to provide mobile money services to users. A corporate organization (other than a deposit money bank, a national primary mortgage bank, a national microfinance bank, or a telecommunication corporation) that has been explicitly licensed by the CBN to provide mobile money services in Nigeria shall be the Lead Initiator.

The following practices are prohibited for mobile money operators:

The grant of any type of loan, advance, or guarantee (directly or indirectly).

Acceptance of foreign currency deposits.

Dealing in the foreign exchange market except as permitted by Section 4.1 (ii) and iii) of the current Guidelines for Licensing and Regulation of Payment Service Banks in Nigeria.

Insurance underwriting.
Accepting any closed scheme electronic value (e.g. airtime) as a form of deposit or payment.

Establishing any subsidiary and engaging in any other transaction not permitted by these Guidelines, as well as any other conduct that the CBN may deem illegal.

Mobile Money Operators (MMOs) must establish specific processes that cover the full solution delivery process, including user registration and management, agent recruiting and management, consumer protection, dispute resolution procedures, risk management procedures, and transaction settlement. All participants in the mobile money ecosystem will be covered by these processes, which will cover the entire value chain.

The savings wallet fund shall be invested only on Nigerian Treasury Bills (NTB), the MMO’s will be treated as CBN’s mandate customers for NTB subscription through a CBN NTB window. The MMO’s will use their Savings Wallet Principal Pool accounts as a process to determine the appropriate balance of cash, which will meet the customers’ savings wallet withdrawal requirements at all times.


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